Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15277

 1                           Tuesday, 2 February 2010

 2                           [Open session]

 3                           --- Upon commencing at 9.10 a.m.

 4                           [The accused entered court]

 5             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, could you please

 6     call the case.

 7             THE REGISTRAR:  Thank you, and good morning, Your Honours.

 8             This is case number IT-03-67-T, the Prosecutor versus

 9     Vojislav Seselj.

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

11             This is Tuesday, February 2nd, 2010, and I first greet the

12     members of the OTP in the courtroom, Mr. Seselj, and everyone helping us.

13             In a few minutes, we will bring a witness in the courtroom.  This

14     witness has protective measures.

15             Let me tell you right away that as far as next week is concerned,

16     we were supposed to hear VS-034.  Unfortunately, he will not come.  He's

17     ill.  He has a health problem, so he will not be able to come next week.

18     And we're trying to schedule him at another time.  However, the week

19     after that, February 16 and 17, we'll be hearing VS-067.  He is

20     available, but given his health, this will be a video conference.  And on

21     the week after, VS-0032, we also have a problem because he's also ill, so

22     there will probably not be any hearing, given his health.  We're also

23     trying to reschedule him.  However, the week after, March 2nd and 3rd,

24     there's no problem, VS-017 is available.

25             So as you see, we're confronted with health situations, and

Page 15278

 1     because of that we have to reschedule a number of witnesses.

 2             Mr. Seselj, I hope that you have noted down all of this.

 3             THE ACCUSED: [Interpretation] Well, I'm just not clear on one

 4     thing, Mr. President.  What does it mean to reschedule him for later?  Is

 5     that a permanent illness or an acute infection and then we can put it off

 6     for a week, whereas reschedule him, well, who knows how long that can

 7     take.

 8             JUDGE ANTONETTI: [Interpretation] As of now, all -- the situation

 9     is very temporary.  We're trying to postpone by a week.  We are awaiting

10     medical records to see whether the witness can actually travel or not.

11     If he cannot travel, then we have to organise a video conference.  But as

12     far as the Trial Chamber is concerned, we are doing our utmost to make

13     sure that they come as soon as possible.  Unfortunately, between what the

14     Trial Chamber wishes and medical treatment, there is a problem.  We just

15     heard that a witness had just had surgery.  Of course, because he just

16     had surgery, he cannot travel, which is why we are running late or he is

17     running late.  This is the kind of problem that we are running into, but

18     the schedule is as I just told you.

19             Mr. Seselj, let me take this opportunity to ask you the

20     following:  Given the schedule for Court witnesses, at first glance, and

21     it's just, you know, an estimation, we should be done with the Chamber

22     witnesses or Court witnesses during the month of March, probably at the

23     end of March, so we will no longer have any witnesses.  I'd already asked

24     you this question, but I will put it to you again.  As far as Rule 98 bis

25     is concerned, are you going to need any time between the end of the

Page 15279

 1     testimony of the last witness to prepare, or do you need no time for

 2     preparation, or do you just decide not to use Rule 98 bis?

 3             THE ACCUSED: [Interpretation] Mr. President, I've already said it

 4     on two occasions, that I will use that Rule, and two or three days will

 5     be sufficient for my preparations.  So let's not lose even one week.

 6     When we finish with a witness within one week, to the following Tuesday

 7     that's enough for me, two or three days in between to prepare, and I can

 8     carry on and utilise Rule 98 bis, because it is my intention to go

 9     through the indictment on the basis of that Rule and to draw your

10     attention to the fact that the Prosecutor has proved absolutely nothing

11     of what he accuses me of.  So we're not even going to lose a single

12     working week.

13             JUDGE ANTONETTI: [Interpretation] Very well.  What you've said is

14     very important.  As soon as we're done with the last witness, we'll

15     probably finish on a Wednesday, so you'll have Thursday, Friday, the

16     weekend, and Monday to prepare, and we will immediately start with

17     Rule 98 bis on the next Tuesday.  Everything is clear.  And that way, we

18     will not waste any time.

19             You told us on two occasions, and this is the third time that

20     you're telling us, that you want to take the floor for Rule 98 bis, and I

21     wanted this to be absolutely clear for each and every one here.

22             Let's drop the blinds now and bring the witness into the

23     courtroom.  There's no one in the gallery, but still we have to abide by

24     the Rules.  And we will first move into closed session.

25             Could you please move into closed session, Registrar.

Page 15280

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Page 15281











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Page 15283

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21                           [Open session]

22             THE REGISTRAR:  Your Honours, we're now in open session.

23                           Questioned by the Court:

24             JUDGE ANTONETTI: [Interpretation] Witness VS-1067, you made two

25     statements to the OTP, the first one on August 18 and 19, 1998, and the

Page 15284

 1     second one almost six years later on March 1st and 2nd, 2004.  We have

 2     these statements.  Could you please tell us, as far as -- could you tell

 3     me the following:  The first time you met the OTP, what exactly happened?

 4     Did they call you, did they contact you?  Could you tell me how you came

 5     into contact with them?

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11             Sir, you were detained in a country.  The OTP then contacted you.

12     You met them in the prison where you were being detained or did you meet

13     them elsewhere?

14        A.   No, I didn't meet them in prison.  I had a meeting with them when

15     I left prison.

16             JUDGE ANTONETTI: [Interpretation] You met them once you had been

17     released.  You spent two days with them, the 18th and 19th of August,

18     1998.  Were there any questions and answers from you or was it just you

19     giving a statement?

20        A.   I only recounted what happened and how it happened.

21             JUDGE ANTONETTI: [Interpretation] You told them what had

22     happened.  When you told them what had happened, did the OTP investigator

23     input all the information in his computer or was he taking down notes in

24     writing?

25        A.   I do not remember exactly.  I don't remember whether he had a

Page 15285

 1     computer.  But he did have a notebook, and he was writing things down in

 2     that notebook.

 3             JUDGE ANTONETTI: [Interpretation] On the 19th of August, to be

 4     precise, you were asked to sign your statement, which is a ten-page

 5     statement.  This statement, which you were asked to sign, was it in

 6     English or was it in your language?

 7        A.   It was in English, but there was an interpreter there who

 8     interpreted it, because, well, I guess there wasn't enough time for that

 9     person to write it down in our language.  I don't know.

10             JUDGE ANTONETTI: [Interpretation] Before you signed, did the

11     interpreter interpret into your language those ten pages?

12        A.   Yes.

13             JUDGE ANTONETTI: [Interpretation] And after that, you signed.  So

14     much for 1998.

15             Then you meet the OTP again on the 2nd of March, 2004.  Did they

16     contact you once more or did you contact them?

17        A.   They got in contact with me.

18             JUDGE ANTONETTI: [Interpretation] When they contacted you, well,

19     this lasted two days.  This was for the 1st and 2nd of March, and you

20     gave a much shorter statement, a five-page statement with 30 paragraphs,

21     and I assume that you were then given the statement in English, you were

22     asked to sign it, and then those five pages were translated back to you;

23     yes or no?

24        A.   I cannot remember exactly, but I know that there was an

25     interpreter there, that she interpreted things to me.  (redacted)

Page 15286

 1     (redacted).  I remember that.

 2             JUDGE ANTONETTI: [Interpretation] Registrar, line 2, page 10, you

 3     need to redact it, because he is saying which country the person putting

 4     questions to him came from.

 5             So last question on this:  At any point in time in 1998 or in

 6     2004, were you told that you were going to be testifying in Mr. Seselj's

 7     trial, or were you told nothing at all?

 8        A.   They didn't say anything to me.

 9             JUDGE ANTONETTI: [Interpretation] You weren't told anything.  So

10     in March 2004, you will go on with your job.

11             This is going to be my last question.  Since March 2004 until

12     today, did Mr. Seselj or his associates phone you up at some point in

13     time; yes or no?

14        A.   Yes.

15             JUDGE ANTONETTI: [Interpretation] Can you tell me on what day,

16     which year, which month, and who?

17        A.   First, he called me on 2007, I believe, in November, this little

18     guy called Samardzic, Dragan Samardzic.  He's from Mostar.  He said that

19     he'd kill my children this way, that way.  He started talking nonsense,

20     and I hung up.  Three or four months later, Drago Tamindzija me and said

21     that I had no business testifying there because I cannot say anything.  I

22     answered, Well, yes, there's nothing I can say that I don't already know.

23             JUDGE ANTONETTI: [Interpretation] Those two people who called

24     you, how do you know that they are close to Mr. Seselj?

25        A.   The first one I mentioned, Dragan Samardzic, I didn't know on

Page 15287

 1     whose behalf he was calling at all.  As for Mr. Drago Tamindzija, when I

 2     was in Nevesinje in 1996, he was a member of the Serb Radical Party.

 3             JUDGE ANTONETTI: [Interpretation] So you are saying as far as the

 4     first one is concerned, you don't know, but as far as the second one is

 5     concerned, you know that he was a member of the Serbian Radical Party.

 6             Now, the second person who is a member of the Serbian Radical

 7     Party, how do you know that he is such a member?

 8        A.   Because I was in Nevesinje at the time when they were there, and

 9     he was recruiting people to join his party.

10             JUDGE ANTONETTI: [Interpretation] So you were in that village,

11     and he was encouraging people to join the Serbian Radical Party.  This

12     happened in 2007?  We are talking about 2007; is that right?

13        A.   Yes.

14             JUDGE ANTONETTI: [Interpretation] Nevesinje, is it located in

15     Serbia or in the Republic of Bosnia-Herzegovina?

16        A.   It is located in Bosnia-Herzegovina.

17             JUDGE ANTONETTI: [Interpretation] If I have understood correctly,

18     in the Republic of Bosnia-Herzegovina in 2007, the Serbian Radical Party

19     had a political branch there where people were recruiting individuals to

20     become members of the Serbian Radical Party, which was exercising

21     political activities in Bosnia-Herzegovina.

22        A.   The recruitment was not in 2007.  They started recruiting people

23     from the end of the war, from 1996 onwards.

24             JUDGE ANTONETTI: [Interpretation] Last question.  Nevesinje, this

25     village in the Republic of Bosnia and Herzegovina, is it located in the

Page 15288

 1     Republika Srpska or in the federation which currently exists?

 2        A.   Republika Srpska.

 3             JUDGE ANTONETTI: [Interpretation] Thank you.  I have no questions

 4     for you.

 5             I shall ask my colleagues whether they have any questions for

 6     you.

 7             JUDGE LATTANZI: [Interpretation] Good morning, Witness.

 8             In your statements, you mention the arrival of JNA units in

 9     Mostar.  You also mention the Green Berets.  You mention a paratrooper

10     regiment from Nis, the Red Berets?

11        A.   Yes.

12             JUDGE LATTANZI: [Interpretation] I wanted to know whether at that

13     time, which seems to be between June and July 1992, whether units of

14     volunteers arrived also, groups of volunteers.

15        A.   Yes.

16             JUDGE LATTANZI: [Interpretation] Could you be a little bit more

17     specific as regards these groups that arrived?

18        A.   That unit arrived.  I cannot remember the exact date.  I think it

19     was the 6th of April, 1992.  They came to Bjelusine.  That is a

20     neighbourhood in Mostar, Bjelusine.

21             JUDGE LATTANZI: [Interpretation] Which group do you mean?

22        A.   It's a group of some 50 or 60 men who came and introduced

23     themselves as being from the Serbian Radical Party.

24             JUDGE LATTANZI: [Interpretation] I apologise.  I'm a little bit

25     ill.

Page 15289

 1             Now, this group comprising approximately 50 to 60 men was made up

 2     entirely of Serbs coming from Serbia or also of local Serbs, Bosnians?

 3        A.   There were local Serbs from Bosnia, too.  I know that one

 4     introduced himself as a Bosnian from Vlasenica, I believe.  However, they

 5     were immediately joined by some of the local Serbs from Mostar.

 6             JUDGE LATTANZI: [Interpretation] Thank you.  Were there any other

 7     groups of volunteers different from the Seseljevci?

 8        A.   Yes.  Yes, I hadn't seen them, but there were these White Eagles.

 9     They said that they were stationed in Gacko.  That's 40 or 50 kilometres

10     away from Nevesinje.  Then later on, in July 1992, a unit came.  They

11     were called Vukovarci, men from Vukovar.  They had come from Croatia.  I

12     didn't have any information about these people.

13             JUDGE LATTANZI: [Interpretation] I wanted to know precisely,

14     Witness, whether you know anything about the co-operation between the

15     White Eagles and the group Seselj's men.

16        A.   I don't know anything about that co-operation because this group

17     that came from Mostar, that introduced themselves as Seseljevci, they

18     were in Mostar, whereas this other group was in Bijelo Polje -- no,

19     sorry, Gacko.  I'm sorry.

20             JUDGE LATTANZI: [Interpretation] What distance is there from

21     Mostar to Gacko?

22        A.   Gacko is about 75 or 80 kilometres away.

23             JUDGE LATTANZI: [Interpretation] Thank you.  Now, let's discuss

24     some of the names you give in your statement.

25             I would like to know who Relebic [as interpreted] was.  According

Page 15290

 1     to you, he brought money back for his unit.  You also add that the

 2     Serbian Radical Party always had money?

 3        A.   As for Radovic, he was commander of a special unit of the Army of

 4     Republika Srpska.  They were called the Bjelica volunteers.  Radovic,

 5     Rade Radovic.  He went to Serbia, and whenever he'd come from Serbia he'd

 6     bring money for the needs of his troops.  Now, where that money actually

 7     came from, I have no idea.

 8             JUDGE LATTANZI: [Interpretation] So this was not a group of

 9     volunteers made up of Seselj's men?

10        A.   Yes, they were Seselj's men, but they were the Bjelica

11     volunteers, and they, indeed, were members of the Serb Radical Party.

12     However, these Bjelica volunteers were under the Army of Republika

13     Srpska, whereas this first group that had come, consisting of 50 or 60

14     men that I'm talking about, they were not under the command of the Army

15     of Republika Srpska.  They had a relationship with the Yugoslav People's

16     Army, and it's from the JNA that they received everything they needed.

17             JUDGE LATTANZI: [Interpretation] Thank you.  Cvele, who was he?

18        A.   He came from Serbia.  He came to Mostar 25 or 30 years ago.  And

19     when they came to Bjelusine, he joined them.  Cvele and Lika, that's what

20     I know, that they joined them.

21             JUDGE LATTANZI: [Interpretation] Could you give us the name of

22     the group?  Specify each time which group it is, whether you include the

23     group of Seseljevci or not.

24        A.   Cvele and Lika, and a few other local Serbs, had joined this

25     group that came to Mostar on the 6th of April, the first one.  They said

Page 15291

 1     that they had been sent by Mr. Vojislav Seselj and that they were from

 2     the Serb Radical Party.

 3             JUDGE LATTANZI: [Interpretation] Witness, this is something you

 4     heard those men tell you directly?

 5        A.   I didn't understand your question.  What were they supposed to

 6     tell me?

 7             JUDGE LATTANZI: [Interpretation] You said, if I had understood

 8     you correctly, that they were saying that they had been sent by Seselj?

 9        A.   Yes.

10             JUDGE LATTANZI: [Interpretation] This is something you heard from

11     them directly?

12        A.   Yes.

13             JUDGE LATTANZI: [Interpretation] Thank you.

14             Let's now move on to the direct testimony you are giving us.

15     Either you can deny or uphold this, i.e., crimes committed by some of the

16     Seselj's men.

17             Could you, first and foremost, tell us whether you were an

18     eye-witness to this when these crimes were being committed?

19        A.   Yes.

20             JUDGE LATTANZI: [Interpretation] Could you expand on this,

21     please?

22        A.   On the 13th of June, 1992, a sabotage group of the BH Army

23     attacked, and we fought with them, and two or three men lost their lives.

24     When we repelled that attack, we returned to Zalik about 6.30 in the

25     evening, because our location was in Zalik.  A woman came up to me and

Page 15292

 1     said that they had taken her son away, Nedzad Benca, that they took him

 2     away, and that he was somewhere in the changing rooms in Vrapcici.

 3     However, more and more people were coming there and saying that their

 4     husbands, children, et cetera, had been taken away.

 5             Then, Borislav Janjic and I went to look for these people.  I

 6     actually went to look for this Nedzad Benca.  When I came to the changing

 7     rooms, he was not there.  However, there were quite a few people locked

 8     up there.  Now, I don't know how many "quite a few" is, but there were

 9     really many of them.  I was looking for Nedzad Benca, but a local person

10     told me that they had already taken a group to Uborak, to a garbage dump

11     there.  Then this Bosanac, the Bosnian, came to me.  He was from the

12     Radical Party and he disarmed me and said, You want to protect the

13     "balijas" here?  Nobody is going to do that.  Then Borislav and I

14     quarreled with them a bit there, but a young man came up to us, and said,

15     You'd better leave here.  There's nothing here.  Then we went to Uborak.

16             When we got to Uborak, there were about 20 men there who had

17     introduced themselves as being Seselj's men previously, and there were

18     about 20 civilians.  Among them were some local persons as well, among

19     the Seseljevci; Diki Janjic, Mile Antelj.  I can't remember who else was

20     there.  Then as we walked up to them, Mile Antelj -- I mean as we walked

21     up to these people to see whether Benza was there, perhaps Mile Antelj

22     said, You have no business here; go.  We walked towards the car -- but

23     Benca wasn't there.  Before we entered the car -- as we were walking

24     towards the car, they took them down into a valley, into a valley.  We

25     started towards the car, and they went in this other direction.  When we

Page 15293

 1     got to the car, we heard shooting.  We got into the car and fled.

 2             Afterwards, we heard that over 100 people had been killed there.

 3             JUDGE LATTANZI: [Interpretation] Witness, there's one thing I

 4     have not understood from your statements.  If at some point in time you

 5     had been arrested, together with the Muslims and the Croats, by this

 6     group --

 7        A.   Yes, I was arrested.

 8             JUDGE LATTANZI: [Interpretation] You were arrested and detained?

 9        A.   No, they disarmed me.  They took away my rifle, and they said

10     that they would take me away and that I would end up like those people

11     too.  That's what Bosanac and Srecko -- that's what Bosanac said to me,

12     and Bosanac was there with Srecko and other people I don't know.

13             JUDGE LATTANZI: [Interpretation] Just a few points of detail

14     concerning Kandic.  Who was he?

15        A.   You mean Zdravko Kandic?

16             JUDGE LATTANZI: [Interpretation] I am talking about your

17     statement of August 1998, where you say that 88 persons were purportedly

18     killed, 30 of them in a forest, and the orders had come from Kandic.

19        A.   No, I didn't say that the order came from Kandic, the order to

20     kill them.  I said that Kandic had ordered to have these people detained,

21     that he issued an order to have all these people brought together and

22     detained.

23             JUDGE LATTANZI: [Interpretation] Thank you.  What about Savic;

24     was he a military policeman?

25        A.   You mean Krsto Savic?

Page 15294

 1             JUDGE LATTANZI: [Interpretation] What about Miljenko?

 2        A.   Miljenko Savic, yes, he was a military policeman at the beginning

 3     of the war.

 4             JUDGE LATTANZI: [Interpretation] You say in that same statement

 5     that you were locked up in a cell and beaten by Miroslav Duka?

 6        A.   That was on the 5th of August, 1992, after all of these things

 7     that had happened.

 8             JUDGE LATTANZI: [Interpretation] Who was Miroslav Duka?

 9        A.   He was the chief of police in Bjelica.

10             JUDGE LATTANZI: [Interpretation] Thank you, Witness.

11             JUDGE ANTONETTI: [Interpretation] Sir, I have a follow-up

12     question for you after the questions put by Judge Lattanzi.

13             As far as Mr. Seselj's men are concerned, in your statement of

14     1998 you mention a number of names which I shall remind you of.  You say

15     that there was Rasko Janjic, nicknamed Diki; Damir Antelj, Borislav

16     Miskin, Ses Pejak, Slavko Milovanovic, Dragan Antelj, Miroslav Antelj,

17     Mile Antelj, Slobodan Umicevic, Novica Antelj, and Boskajlo Kovacevic, so

18     you mention the names of a number of individuals who, in 1992, were

19     Seselj's men.  You say this in 1998; i.e., six years later.

20             I apologise.  My memory doesn't operate the same way as yours

21     does.  I would be totally unable to give you the names of those witnesses

22     I have examined, even though I may have spent a number of days with these

23     witnesses.  Therefore, do you have a remarkable memory to such an extent

24     that you are able to give the names of eight people who, according to

25     you, belong to Seselj?  How are you able to do this?

Page 15295

 1             I apologise.  How are you able to remember eight names like this,

 2     those eight names you gave the investigator; because you have a

 3     remarkable memory, quite unique?

 4        A.   I apologise, sir, but the people that I enumerated, and I never

 5     said they were Seselj's men.  They were the local population.  They were

 6     the local population.  They were there with them, but they weren't

 7     Seselj's men.  That's what I said.

 8             JUDGE ANTONETTI: [Interpretation] Listen carefully.  This is what

 9     is written in your statement, in the English version:  You say that they

10     were a number of Seselj's men:  "The ones I knew were ...," and then you

11     mention them, give their names.  Are you giving names of locals or

12     Seselj's men?  Because when you read this -- when the sentence is read,

13     the impression you get is that the names you mention are Seselj's men.

14     Or are these locals who belonged to different groups?

15        A.   Sir, they were local men.  I knew them.  I knew their full names,

16     and they were from Mostar.  Now, the others, the Seselj men who came,

17     from Serbia, and they just had nicknames.  None of them introduced

18     themselves by giving their first and last name.

19             JUDGE ANTONETTI: [Interpretation] Very well.  The Seselj's men

20     who came from Serbia only had nicknames.  This is clear.

21             One last question.  This is from paragraph 27 of your 2004

22     statement.  This is probably the most important paragraph in the entire

23     statement.  This is what you say:

24             "Seselj and his political party was almost unknown in Mostar

25     because there was no SRS party headquarter in Mostar."

Page 15296

 1             And you add:

 2             "The first such office of the SRS was established in Bjelica at

 3     the beginning of the war."

 4             And you add:

 5             "I also observed that an SRS office had been established in

 6     Nevesinje."

 7             And you go on:

 8             "The first SRS officer in Bjelica was Ljubo Kapor, who was a

 9     vojvoda, but he was killed in August 1992."

10             Then you say that the other local SRS leader was Rade Radovic,

11     who later also became a vojvoda, and that in 1991 this group had

12     participated in the attack of Dubrovnik from Trebinje, and the soldiers

13     were still members of the SRS with proper membership cards.  This is what

14     you are saying on paragraph 27.

15             How did you know that Ljubo Kapor and Rade Radovic were members

16     of the SRS?

17        A.   Well, we know that because Mr. Seselj, in 1994, went to see

18     Rade Radovic in Nevesinje at their positions there, and they openly said

19     that they were -- well, Rade Radovic would always say that he was going

20     to Serbia, to the Serbian Radical Party somewhere, and that they gave him

21     assistance in the form of food, money, clothing, footwear, everything.

22             JUDGE ANTONETTI: [Interpretation] Very well.  You're saying that

23     Mr. Seselj came to Nevesinje in 1994 and he met Rade Radovic there.  So

24     according to you, Rade Radovic was a member of the Serbian Radical Party?

25        A.   Well, obviously, I assume so.

Page 15297

 1             JUDGE ANTONETTI: [Interpretation] Very well.  You assume so.

 2             JUDGE LATTANZI: [Interpretation] Witness, I apologise, but I need

 3     you to give us some additional information.

 4             I had asked you whether, among Seselj's men, there were also

 5     locals, and you answered by saying that there were also locals and not

 6     just Serbs from Serbia; there were also Serbs from Bosnia.  So if I

 7     understood you correctly when answering a question put to you by the

 8     Presiding Judge, you said that Seselj's men were not locals, they came

 9     from Serbia.  So maybe I misunderstood you, but I detect a contradiction

10     here.  So could you shed some light on this?

11        A.   Local people.  When I say "local people," I mean the people who

12     originate from the area, for example, from Mostar.  They were joined by

13     two, three, maybe five - I'm not quite sure of the number - these from

14     Vlasenica.  Vlasenica is in Bosnia-Herzegovina.  We didn't consider them

15     to be locals.  Vlasenica is in Bosnia-Herzegovina, so they weren't

16     considered the local population, because I never actually saw those

17     people.  So Vlasenica is about 300 kilometres away from Mostar, 250 to

18     300 kilometres, so I can't call them locals.

19             JUDGE LATTANZI: [Interpretation] Thank you.  I understand now.

20     Thank you.

21             JUDGE ANTONETTI: [Interpretation] One last question, and then I

22     will give the floor to my fellow Judge.

23             Are you really saying the following:  Among Seselj's men, some

24     came from Serbia?  This is what I'm interested in.

25        A.   Yes, most of them.

Page 15298

 1             JUDGE ANTONETTI: [Interpretation] You say most of them, they were

 2     in the majority.  Now, those who came from Serbia, could you give us a

 3     figure?  Could we know how many there were, a ballpark figure?

 4        A.   About 55 to 60 people in three trucks.

 5             JUDGE ANTONETTI: [Interpretation] Fifty-five to sixty in three

 6     trucks.  When they arrived, did they have weapons, uniforms?

 7        A.   Yes.

 8             JUDGE ANTONETTI: [Interpretation] A leader?

 9        A.   Yes, they had uniforms and everything they needed.  They had

10     weapons, rifles, everything they needed.  They would get them from the

11     JNA.  They would go to the main command, the headquarters of the JNA, and

12     get them there.

13             JUDGE ANTONETTI: [Interpretation] As you see, when we put

14     questions, we obtain very important details.  Seselj's men, who numbered

15     55 to 60, came on board three trucks, but they had obtained weapons and

16     uniforms at the JNA.  How do you know that?

17        A.   Because we saw them when they arrived.  They parked in front of

18     the school in Bjelusine.  They got out.  They were all wearing camouflage

19     uniforms and bearing weapons.

20             JUDGE ANTONETTI: [Interpretation] Last question.  You told us you

21     saw these men.  They arrived in front of the school.  According to you,

22     did they report to the JNA, were they under JNA command; yes or no?

23        A.   I really can't say, because they arrived and told us that they

24     were Serbian Radicals, and some of them even had some booklets of the

25     Serbian Radical Party.  They said that they had every possibility to

Page 15299

 1     procure whatever we needed from the army.

 2             JUDGE ANTONETTI: [Interpretation] Thank you.

 3             JUDGE HARHOFF:  Thank you.

 4             Mr. Witness, just to clarify one small point that came out of the

 5     questions that were put to you by my two colleagues at the Bench.

 6             When the three trucks arrived with Seselj's men to Mostar, you

 7     said that they were equipped by the JNA, yet you also said that when they

 8     got out of the trucks, they already had camouflage uniforms and their

 9     weapons with them before they entered the JNA headquarters in Mostar.

10     I'm not quite sure of what your testimony really is, so let me put a

11     question to you to clarify this.  Were they already dressed in camouflage

12     uniforms and armed with rifles when they came in the trucks, or did they

13     only get their uniforms and their weapons once they had entered the JNA

14     headquarters?

15        A.   They came armed and had camouflage uniforms on them.  That's how

16     they came.  And the JNA barracks was about a kilometre away from

17     Bjelusine, and they would go every day brining back weapons and whatever

18     they needed.  They had everything.  We didn't even have cigarettes.  They

19     had everything.  Where they got it all from, who supplied them, I have no

20     idea.  However, when they arrived in Mostar, they had -- when they got

21     off the trucks, they had rifles and uniforms.

22             JUDGE HARHOFF:  Thank you.  So what exactly did they get from the

23     JNA?  If they brought already their own weapons and had everything they

24     needed, what could they possibly get from the JNA in the barracks?

25        A.   Well, they would get ammunition, food - what do you call

Page 15300

 1     them? - those RPGs, hand-held rocket-launchers, the Zolja type.  They

 2     just came with light weapons.  Everything else they got from the JNA;

 3     anti-tank mines, mines for the destruction of tanks and things like that,

 4     launchers and so on.

 5             JUDGE HARHOFF:  Thank you.  That's very useful information.

 6             Now, during the events that you have described in your statements

 7     to the Prosecution, you mentioned that there were, of course, the JNA,

 8     who had their headquarters in the barracks.  You also mentioned a number

 9     of paramilitary groups, one of which were Seselj's men, and you also

10     mentioned the TO.  My question is if you were able to form an impression

11     about how the activities of these three groups were co-ordinated during

12     the events which you describe in your statements.  My question is,

13     really:  Were these groups acting more or less individually or was it

14     your impression that they were under an overall central command?

15        A.   Well, I think, quite simply, they were under an overall central

16     command, under the JNA, because they would all address the JNA.  Anything

17     they needed, they procured from the JNA, the Yugoslav People's Army.  For

18     example, if you wanted to leave Mostar, you needed a permit to be signed

19     personally by Momcilo Perisic.  I was never able to get a permit like

20     that.  But these volunteers coming in from Serbia, whenever they wanted

21     to and needed to, and they could even sign those permits themselves, come

22     to that.  Where they got the permits from, I don't know.

23             JUDGE HARHOFF:  I understand.  But when it came to the operations

24     that you have described, was it your impression that these operations had

25     been planned and ordered and initiated by the central command of the JNA,

Page 15301

 1     or was it operations that were planned and carried out individually by

 2     those groups?

 3        A.   I think it was planned and carried out individually by those

 4     groups.  I'm not quite sure.  I don't really know, but that's my opinion,

 5     because they didn't have to tell anybody what they were doing.  They

 6     looted and so on.  They weren't held accountable.  There was no law or

 7     order there for a month while the Serbs were there.  There was no police,

 8     nothing.  It was total chaos and anarchy, lawlessness.

 9             JUDGE HARHOFF:  Yes, you have described that very convincingly in

10     your statements.

11             Just to follow up on this point, in the actions that took place

12     that you have described, the looting and the operations, was there anyone

13     present from the JNA who could actually oversee and perhaps control the

14     actions?  Was there anyone present to represent the overall command?

15        A.   Yes, General Momcilo Perisic.  For example, from Mostar to

16     Nevesinje, there were six to seven check-points along the way, and you

17     had to show your permit or authorisation at each of those check-points,

18     and that permit can only be signed by Momcilo Perisic.  So somebody had

19     to oversee it.

20             JUDGE HARHOFF:  Right.  But, of course, Momcilo Perisic could not

21     possibly have been present at all those six to seven check-points, nor

22     could he have been present at the actions and the events which you

23     describe in your statements, so my question is really:  Was there some

24     JNA officer present along with the paramilitary groups during the events

25     which you describe in your statements?

Page 15302

 1        A.   No, I never saw an officer with any paramilitary group.

 2             JUDGE HARHOFF:  So when the paramilitary groups acted in Mostar

 3     and in Nevesinje, they acted on their own, without there being any

 4     officer from the JNA present; is that a correct version of your

 5     testimony.

 6        A.   Yes.

 7             JUDGE HARHOFF:  Thank you, sir.  I have no more questions.

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15             Now, you say that you were part of the TO.  Could you tell us who

16     was the commanding officer?

17        A.   My superior was Rade Markovic, and his superior was Zdravko

18     Kandic in North Camp.

19             JUDGE ANTONETTI: [Interpretation] And who did Zdravko Kandic

20     report to?

21        A.   Well, the superior to everybody was General Momcilo Perisic.

22     Now, who was his immediate superior, I really can't say.

23             JUDGE ANTONETTI: [Interpretation] Very well.  I was very

24     impressed by the answer you gave to my fellow Judge.  You said that it

25     was chaos.  Now, we can imagine that.  But you also said that in order to

Page 15303

 1     move around, there were check-points, that it was impossible -- and you

 2     could only move around if General Perisic had authorised this trip.  So

 3     on the one hand, there's chaos, but on the other hand, there's also

 4     control.  So was it organised chaos or was it that General Perisic was

 5     completely incompetent and only able to place check-points on the roads

 6     and leave all the rest to pretty much anything?

 7        A.   It seems that that's how it was, sir, because if you had to go

 8     from Mostar to Nevesinje, which is 37 kilometres, there were six or seven

 9     check-points, and at each check-point you were asked for your papers,

10     authorisation to exit town.  But when you come into town, nobody asked

11     you anything anymore.  Total chaos prevailed; killings, abuse,

12     mistreatment.

13             JUDGE ANTONETTI: [Interpretation] If I understand you correctly,

14     outside Mostar General Perisic was in control of the situation, but

15     within the city it was chaos.

16        A.   Yes.

17             JUDGE ANTONETTI: [Interpretation] One last question, and then we

18     will have a break, and then the Prosecutor will start his

19     cross-examination.  So one last question before the break.

20             You told us that the people who came from Serbia would arrive in

21     this JNA barracks, where they were provided with heavy equipment, and

22     then in passing you said that they had brought their own light weapons.

23     If I understand you correctly - I'm trying to imagine all this and

24     understand what happened - the Serbian volunteers would leave Serbia with

25     their own weapons, light weapons, of course - they didn't have any tanks

Page 15304

 1     or RPGs or rocket-launchers, but they had their own light weapons - they

 2     would arrive to the barracks, where they were provided with a uniform,

 3     where they were equipped?  Is this what happened?

 4        A.   They came in camouflage uniforms and light weapons, but

 5     everything else they needed they got from the JNA.  They would go to

 6     North Camp or South Camp, and from there they would obtain everything

 7     they needed, from cigarettes, food, rocket-launchers, the lot.

 8             JUDGE ANTONETTI: [Interpretation] I was right to put this

 9     question to you, because you just said that they arrived in uniforms with

10     light weapons.  Does this mean that before they arrived to the JNA

11     barracks, where they were provided with the rest of the equipment, they

12     had already been through a JNA barracks where they were provided with

13     uniforms and weapons?

14        A.   I really can't say, because I only saw them when they arrived,

15     the moment they arrived.  Where they were before that, I really don't

16     know.

17             JUDGE ANTONETTI: [Interpretation] Very well.  This is a very

18     precise answer.  You are telling us exactly what you saw, i.e., that they

19     already had uniforms and light weapons, and in those JNA barracks they

20     obtained heavy weaponry, but you cannot say where they obtained their

21     equipment earlier.  This is very precise.

22             It is now time for our break.  We will break, and then the

23     Prosecutor will have one hour for his cross-examination.

24                           --- Recess taken at 10.24 a.m.

25                           --- On resuming at 10.49 a.m.

Page 15305

 1             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, you have the

 2     floor.

 3             THE ACCUSED: [Interpretation] Mr. President.

 4             JUDGE ANTONETTI: [Interpretation] Yes.

 5             THE ACCUSED: [Interpretation] I have a brief objection before

 6     Mr. Marcussen starts.

 7             During the break, I asked the Registrar to ask the Prosecutor to

 8     make available to me my book, "Podgoricki Atentat," "The Assassination in

 9     Podgorica."  While I was meeting my disclosure obligations in advance, I

10     gave it to the OTP six years ago.  I wanted to use the book.  However,

11     the OTP refused to help me out, and they don't want to make this book

12     available to me.  I am convinced that it is their duty to make it

13     available at any point when it may be needed, because that is the point

14     of disclosure, to have the book used in the proceedings.  Therefore, I

15     ask you now to order the Prosecution to make this book available to me

16     during cross-examination.

17             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, what about this

18     book?  From what I understand, Mr. Seselj has seemingly given this book

19     six years ago to the OTP, and he would like to have his book back.  Why

20     don't you want to give him his book back?

21             MR. MARCUSSEN:  Your Honours --

22             THE ACCUSED: [Interpretation] Just a small correction.  I don't

23     want the book back.  I just want to use it for one minute here, and I'll

24     return it to the OTP.

25             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, he would just

Page 15306

 1     like to have a look at his book for one minute.

 2             MR. MARCUSSEN:  Your Honours, I was apprised of this request

 3     probably three minutes ago.  The accused has just told us now on the fly

 4     that he wants to use the book.  We probably have it somewhere, if we can

 5     find it.  It is the accused's duty to prepare his cross-examination, to

 6     come with the documents that he intends to use.  It is not for the

 7     Prosecution to bring documents to court that he would like to use in

 8     court.

 9             Now, secondly, if he's going to use the book for the purpose of

10     his cross-examination, what copy is the Prosecution going to have so that

11     we can follow what he's using in cross-examination of the witness?  I

12     respectfully submit that the accused needs to prepare his own

13     cross-examination and come with the documents that he needs.

14             Now, if I'm directed to provide the book, we will go and see if

15     we can find it somewhere.  I don't know if it's in our vault or standing

16     on a shelf somewhere, but if the Chamber would like us to, we will

17     undertake to try to find it.

18             JUDGE ANTONETTI: [Interpretation] I'm convinced that you going to

19     do your utmost, since you are a great professional, and this is why I

20     believe there might be a misunderstanding.  You said, If I give the book,

21     how will I be able to use it if I don't have it?  Mr. Seselj told us that

22     he only wants to look at it for a minute, and then he will give it back

23     to you.  So there's no problem there.

24             MR. MARCUSSEN:  The way the accused normally deals with these

25     extensive documents that he reads out from this, that he puts

Page 15307

 1     propositions to the witnesses from various documents.  When he does that

 2     with a document in a language where we don't have a translation, I'm

 3     having the assistance of somebody who understands the language, so I can

 4     see whether or not the propositions that are being put are correct.  I

 5     cannot do that if I don't have a copy of the material that the accused is

 6     using.  That's my point.  I, of course, trust that the accused would give

 7     us back the book.  I have no worry about that.

 8             JUDGE ANTONETTI: [Interpretation] Proceed, then.  You may start.

 9             Mr. Marcussen, try and find this book again, give it to him over

10     the break.  He will have 20 minutes to look at it, and he will give you

11     the book back once he starts his questions.

12             So you may begin with your questions.

13             THE ACCUSED: [Interpretation] Just one point, Mr. President.

14             On the basis of the questions put by you, the Judges, I realised

15     that I might find the book useful.  Otherwise, I did not think that I'd

16     need the book.  That can happen in any trial.  What is handed over to the

17     Prosecution has to be available all the time.  It cannot simply be lost.

18     I didn't give it to them for fun.  I gave it to them by way of

19     disclosure, material for them to familiarise themselves with.  They've

20     had six years to do that.

21             JUDGE ANTONETTI: [Interpretation] Please proceed.

22             JUDGE LATTANZI: [Interpretation] Mr. Seselj, I have a problem

23     with this procedure.  According to our procedure, you are the one who

24     selects the documents you wish to use during your cross-examination.  You

25     have the documents translated into English or into French so that the

Page 15308

 1     Trial Chamber may use these documents also; in English so that the

 2     Prosecutor may follow.  This is what poses a problem.  I understand now

 3     you would like him to give this to you so that you can use it, and it is

 4     in Serbian, so we would not be able to understand it.  It will only be

 5     for you to refresh your memory relating to what this document contains,

 6     but it is not for the Prosecutor or for the Trial Chamber to be able to

 7     follow.

 8             THE ACCUSED: [Interpretation] Judge Lattanzi, according to

 9     Rule 65 ter it is my duty to disclose on time -- disclosure related to my

10     case, just like the OTP has the duty to disclose their material to me.

11     It is all of six years ago that I disclosed to them all of my books, 80

12     books, and the first editions, at that, so that they would be as

13     authentic as possible and as contemporaneous as possible, in view of the

14     charges in the indictment.  If I disclosed it to the Prosecution, they

15     cannot simply say, Well, we'll see if we find it, because the Prosecutor

16     has to find this at any point in time.  They are an officer of

17     international justice here.  They should be interested in international

18     justice and the truth.  It's not a question of succeeding at all costs.

19     Here, there is a difference between the Prosecution and the accused

20     person in the proceedings.

21             JUDGE LATTANZI: [Interpretation] I stress the point.  You are the

22     one who needs to ask for the translation of portions of this book.  It's

23     not a matter of a thousand pages.  These are just the portions which are

24     relevant to you, to defend your case, and you select these passages and

25     you have them translated, and you then disclose them to the Prosecution.

Page 15309

 1             THE ACCUSED: [Interpretation] But I did not refer to the problem

 2     of translation here at all, just the problem of making the book available

 3     for one minute; nothing more than that.  The book does not have to be

 4     translated.  It is the Prosecutor who is complicating things now.  They

 5     refuse to co-operate.  The Prosecutor always has to co-operate with the

 6     Defence.  They have to do that.

 7             JUDGE HARHOFF:  Maybe the Prosecution is unable, at three

 8     minutes' notice, to find the book, because as you are probably aware, the

 9     stock of evidence that is contained by the Prosecution is enormous and it

10     may not be possible, in three minutes, to produce your book.  But as I

11     understand, the Prosecution will find the book and you will have it for

12     the next break.

13             May I suggest we simply stop this and move on.

14             Mr. Prosecutor.

15             THE ACCUSED: [Interpretation] I did not insist to have it done

16     within three minutes' time.  I did not insist on three minutes.  I was

17     thinking of at least one hour or so.

18             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, you are going to

19     make sure you find this book and give it to the accused during the break.

20     We have wasted ten minutes for a one-minute issue.

21                           Cross-examination by Mr. Marcussen:

22        Q.   VS-1067, I'd like to go back over some of the issues that have

23     already been covered, in part, but to try to cover in a chronological

24     fashion some of the things that have already been talked about today.

25             Let me just ask you, first of all, if you could describe to the

Page 15310

 1     Judges the ethnic composition of the population living on the east and

 2     the west side of the Neretva River, in Mostar?  Who lived on the west

 3     side and the east side, in majority?

 4        A.   Do you mean before the war or during the war?

 5        Q.   Before the war.

 6        A.   Well, I think 42 per cent were Muslims, 30 per cent Serbs, and

 7     about 30 per cent Croats.  I don't know exactly.  Before the war, the

 8     town was not divided into the left and right bank.  It was a single city.

 9        Q.   Were there a majority of one ethnic group on one side and of

10     another group on the other side, or were everyone mixed up?

11        A.   Well, they were all mixed.  In the villages around Mostar, it was

12     different.  Say Rastani, 70 per cent Serb; Bijelo Polje, 60 or

13     70 per cent Serb; Vrapcici, something like that, too; Orlic, Serbs.  Then

14     up there in the mountains, there were Muslims.  Here on the other side,

15     on the right-hand side there were Croats.  And in town, they were all

16     mixed.

17        Q.   In Mostar, were there any military camps?

18        A.   There was the northern and the southern camp.  Two barracks,

19     rather.

20        Q.   Was there a military airport?

21        A.   A military airport was to the south of Mostar, about seven or

22     eight kilometres south.  I didn't count that as a military camp.  I don't

23     know how to put it.

24        Q.   When did -- was that airport always a military airport?

25        A.   Well, it was a military airport, but I think -- I think, I say,

Page 15311

 1     I think that even civilian aircraft landed there.  But it was used for

 2     military purposes the most.

 3        Q.   You say in your 1998 statement that it was a civilian airport,

 4     but that the army took it over in 1992.  Does that reflect your

 5     recollection or do you think -- are you unsure about that?

 6        A.   To tell you the truth, it's been 18 years.  I can't remember

 7     whether it was a civilian or a military airport.  I know that civilian

 8     aeroplanes landed there.  For example, when the football club went to

 9     play matches elsewhere, their planes would take off from there, so it

10     means that it was used for civilian purposes too.

11        Q.   Did there come a time when roadblocks started to be set up in the

12     Mostar area, the Mostar-Nevesinje area?

13        A.   Yes, Mostar-Nevesinje, Mostar-Sarajevo.  There were barricades in

14     Salakovac, held by the Serbs, and up by Grebak, also roadblocks.

15        Q.   Did you, yourself, pass through those roadblocks?

16        A.   When I was going from Sarajevo to Mostar, there was the roadblock

17     in Salakovac.  They -- the Serbs won't let me go by, and I had to go up

18     Prozor and Kupres in order to get to Mostar.  I was about 12 kilometres

19     away from Mostar, but I had to take a 250-kilometre road in order to get

20     home.

21        Q.   Was there a roadblock put up in Nevesinje?

22        A.   There was a roadblock -- I mean from Mostar to Nevesinje, if

23     that's what you mean, when the war started, there were five or six

24     roadblocks held by the Serbs there.

25        Q.   Do you know who was the leader or the commander of those who were

Page 15312

 1     manning those roadblocks?

 2        A.   Well, the JNA all the way up to Podvelezje.  And at Grebak, the

 3     Chetniks of Arsen Grahovac, they said they held check-points there.  They

 4     were the local Serbs from Nevesinje.

 5        Q.   Were they a member of any particular organisation?

 6        A.   Arsen Grahovac's men were the Serb Chetnik Movement.

 7        Q.   Was the Serb Chetnik Movement established in Nevesinje?  Did they

 8     have a branch there?

 9        A.   Yes.

10        Q.   Do you know when it was established?

11        A.   I don't know exactly when it was established.  But even before

12     the war, in 1991, I heard that the Chetnik Movement of Karadjordje or

13     something like that was founded, and this Arsen Grahovac was their

14     commander.

15        Q.   Sorry, I should just explain to you I'm sort of moving back and

16     forth and turning on and off my microphone.  It's not to be impolite, but

17     it's to make the security measures work properly.

18             Now, do you know how many men were under Grahovac?

19        A.   About 150 men.  That's what they said.  However, I don't know.

20     They said that there were about 150 of them.

21        Q.   At some point, were there JNA reservists coming to Mostar?

22        A.   Yes.  They came in September 1991, and between 20.000 and 30.000

23     of them came.

24        Q.   Do you know where they came from?

25        A.   They came from Montenegro.

Page 15313

 1        Q.   At some point, was there a call for mobilisation or mobilisation

 2     orders issued in your area?

 3        A.   Yes.

 4        Q.   When was that?

 5        A.   Mid-September, then perhaps started in mid-October.  I can't

 6     remember exactly, but I know that people received call-up papers for

 7     mobilisation.  There was only Serbs who were mobilised.  As for Muslims,

 8     if they came for mobilisation, they said, Well, if necessary, we are

 9     going to call you.

10        Q.   How do you know that?

11        A.   Well, there were others who reported for mobilisation, but they

12     didn't want to give them rifles and things.

13        Q.   Did there come a point when the Croats declared Mostar the

14     capital of the Croatian Community in Herceg-Bosna?

15        A.   Yes.

16        Q.   Do you remember approximately when?

17        A.   Towards the end of 1991, they declared Mostar the Croatian

18     capital, that it would be the capital of Herceg-Bosna.  That's what that

19     man used to say.  Now, what was his name?  Jadranko Prlic, whatever.  I

20     can't remember what his name was, the name of this gentleman who was

21     making these statements.

22             JUDGE ANTONETTI: [Interpretation] I would like it to be recorded

23     that I cannot put any questions because I am sitting on a trial in the

24     case of Jadranko Prlic, so I will not put any questions.

25             MR. MARCUSSEN:

Page 15314

 1        Q.   In November/December, did the atmosphere start to change in

 2     Mostar?

 3        A.   Yes.  These reservists who came from Montenegro, they were

 4     drinking, shooting.  They started mistreating everyone, regardless of

 5     whether they were Serbs, Croats, Muslims.  They disturbed everyone,

 6     regardless of what faith people belonged to.

 7        Q.   And just in the interest of time, do I understand correctly that

 8     there came a point in time when you and your family were expelled from

 9     your houses by Croat forces?

10        A.   Yes.  They came to the door of my house, and they asked for my

11     rifle.  I fled.  My mother and my two brothers were expelled.  And I fled

12     through the window, (redacted)

13     (redacted)

14        Q.   And was that -- am I correct that was on the 6th of April, 1992?

15        A.   Yes, yes, yes, when the barracks -- well, when the barracks went

16     down.  It was three days or so later, the 6th of April.  You have to

17     understand that they expelled 25.000 to 30.000 Serbs from the

18     Neretva River Valley, and it wasn't that they were only maltreating me,

19     but others as well.

20        Q.   And after this, was there any action by the JNA towards Mostar?

21        A.   Well, they shelled Mostar every day, every day, from the

22     Northern Camp, the Southern Camp, the airport, from Fortica, Hum, the

23     hills around Mostar.  There was shooting non-stop.  However, at first, at

24     the beginning of April, when they started targeting the city, Perisic

25     said over the radio -- he announced that he would target such and such a

Page 15315

 1     locality and that the civilians should seek shelter.

 2        Q.   And am I correct that this is the same time that you testified

 3     earlier today, that the volunteer group of Seselj's men came on two or

 4     three trucks?

 5        A.   Yes.

 6        Q.   Were you told who the leader of that group was?

 7        A.   You mean the Seselj group?

 8        Q.   Yes.

 9        A.   One of them said he was Mico Drazic or that he was the leader.

10        Q.   Are you familiar with a person called Slobodan Zubak?

11        A.   Slobodan Zubac, not Zubak with a K; with a C.  Slobodan Zubac was

12     the leader of the local Serbs in Bjelusine.  Yes, I am familiar with him.

13        Q.   Do you remember if there were any contacts between the group of

14     SRS volunteers that arrived in Mostar and him, that is, Zubac?

15        A.   Yes.

16        Q.   Can you explain what contacts there were?

17        A.   What contacts there were, I don't know.  But I know that they

18     were in his house, and they -- and in Slobodan Zubac's house weapons were

19     being distributed to Serbs coming from Mostar on one occasion.  And they

20     went to his house, they would discuss matters, so they had contacts.

21        Q.   Did you see this yourself, the weapons and the discussions?

22        A.   Yes, yes.

23        Q.   And was this around this time, the 6th or 7th of April, or at

24     another time?

25        A.   Well, it was sometime in April, because I was in Bjelusine in

Page 15316

 1     April.  I don't know until when.  (redacted)

 2   (redacted).  I also saw at his place there was just light weapons,

 3     rifles and bombs or hand-grenades.  He didn't have any heavy weapons.

 4        Q.   Just to clarify, when you say weapons were being distributed,

 5     were they also distributed to the members of Seselj's men, to some of the

 6     people who had come on those trucks, or were they distributed to someone

 7     else, the weapons?

 8        A.   No, it was weapons distributed to people -- Serbs coming from

 9     Mostar, who came in and joined up with the Territorial Defence.  It

10     wasn't still the army at the time, the Army of Republika Srpska.  It was

11     the Territorial Defence.

12        Q.   Thank you.  In your -- are you familiar with a location called

13     Copla [sic]?

14        A.   Topla, Topla.  It's a place about one to one and a half

15     kilometres away from Bjelusine towards Fortica and towards Podvelezje,

16     inhabited by purely Muslims.

17        Q.   And how big is that location?  How many houses, for example,

18     or --

19        A.   Perhaps 30 to 40 houses.

20        Q.   Did you see any members of the SRS there ?

21        A.   Yes, I saw members of the SRS when they brought out television

22     sets, washing machines, white goods generally, cars that had been

23     abandoned.  They drove the cars and loaded up the white goods onto

24     trucks.

25        Q.   Do you know the names of any of the people involved in this

Page 15317

 1     looting?

 2        A.   There was this man Mico Drazic, then some man called Vranjanac

 3     and Srecko.  There was some 10 or 15.  I can't remember them all.  I know

 4     there was Vranjanac, Srecko, Mico Drazic.  Mico Drazic once drove off a

 5     full truck-load from this village of Topla with white goods.  He drove

 6     off towards Nevesinje.  What happened later on, I don't know.

 7        Q.   Generally, what was the attitude of the local population -- the

 8     local Serb population towards the SRS volunteers and the group you

 9     described?

10        A.   Well, to be quite frank, people were afraid of them.  They were

11     afraid of them because they even killed each other.  There was certain

12     cases where they killed their own members.  They were quite wild, so

13     people were afraid of them.

14        Q.   I'd like to talk a bit about some of the groups that already have

15     been discussed today, but other groups than the SRS group that we just

16     talked about.

17             First, could I ask you, are you familiar with something called

18     the 63rd Parachute Unit?

19        A.   Yes.

20        Q.   Do you know where that came from?

21        A.   They were from Nis, and the unit was called the Mungos, and they

22     were stationed in Rastani.  Mungos.

23        Q.   And just so we know, Nis, what republic is that and where is

24     that?

25        A.   Serbia, and I think it said "63rd Parachute Division."  They had

Page 15318

 1     some insignia to that effect.

 2        Q.   What did they look like, the insignia?

 3        A.   I can't really remember.  I know that there was a parachute and a

 4     mouse or something, and then it said "Mungos" underneath.

 5        Q.   Did you see them involved in any sniping activity?

 6        A.   They had snipers.  Now, whether they -- well, they shot from

 7     Razvitak, but you couldn't see them when they went into a building.  But

 8     they had snipers, they had noise dampers, silencers.

 9        Q.   Who were they shooting at?

10        A.   They were shooting on the right-hand side.  Whether they were

11     shooting at civilians or the army, I really can't say.  I didn't see

12     exactly.

13        Q.   Are you familiar with a union called the Red Berets?

14        A.   Yes.

15        Q.   What kind of a unit was that; police, military, volunteers?  What

16     were they?

17        A.   It was a military unit, and the commander was Dragan Zirojevic,

18     nicknamed Zira, and Baca Milosevic, and what was the other man's name?  I

19     can't remember.  There was another man name, but I can't remember his

20     name now.

21             MR. MARCUSSEN:  And, Your Honours, I think we've managed to

22     produce a nice hot, warm copy of the book that the accused has requested,

23     so I'd like to hand it over so he can look for what he wants to look for.

24     And since it's a copy, I'm informed that the accused can keep his copy.

25             JUDGE ANTONETTI: [Interpretation] Thank you, Mr. Marcussen.

Page 15319

 1             MR. MARCUSSEN:

 2        Q.   Are you familiar with the Nevesinje Brigade?

 3        A.   Yes.

 4        Q.   Who was the commander of that brigade, if you know?

 5        A.   The commander was -- I think in February 1994, it was

 6     Novica Gusic, and after him Zoran Purkovic took over.  I can't remember

 7     the exact date, but I know that Novica Gusic was the first commander.

 8     He's from Nevesinje otherwise, but he personally boasted and said that he

 9     was in Vukovar and that for his merits he was given the command of that

10     unit.

11        Q.   If we can now talk about May 1992, and more specifically the 12th

12     of May.  Were you in an operation that day?

13        A.   Yes.

14        Q.   Where?

15        A.   I was coming from the direction of Brankovci, and then we went

16     down to the National Theatre, and there we came across Muslims and

17     Croats.

18        Q.   Let me just stop you.  Were you in Capljina that day?

19        A.   No, not that day, we weren't in Capljina -- I wasn't in Capljina,

20     no.  Capljina is 55 kilometres away from Mostar, and that's where the

21     hotbed of the Croatian Army was.  There was just a barracks there.  And

22     from Mostar, they would target Capljina from the airport to pull out the

23     soldiers from the barracks.  They used helicopters and I don't know what

24     else, and they managed to pull the soldiers up from -- out from the

25     barracks.

Page 15320

 1        Q.   Let's get back, then, to the incident I think you started to

 2     describe.

 3             JUDGE HARHOFF:  Mr. Marcussen, the witness told us that he was

 4     coming from the direction of Brankovci, and then he goes on to say that,

 5     We went down to the National Theatre, and there we came across Muslims

 6     and Croats.  My question is:  Who is "we"?

 7             MR. MARCUSSEN:

 8        Q.   Who are "we"?

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13             JUDGE HARHOFF:  Thank you.

14             THE WITNESS: [Interpretation] We were going from -- well, it's an

15     inhabited area, so we moved forward going from house to house.

16             JUDGE HARHOFF:  And what were your orders?

17             THE WITNESS: [Interpretation] To liberate the left bank of the

18     Neretva River.

19             JUDGE HARHOFF:  And who had given you those orders?

20             THE WITNESS: [Interpretation] I was personally given the order

21     from -- well, to our unit, Major Ugresic, who was in North Camp.  It was

22     an order from the JNA, and he was a JNA colonel.

23             JUDGE HARHOFF:  Thank you.

24             MR. MARCUSSEN:

25        Q.   Could you describe to us what you saw when you came to the

Page 15321

 1     National Theatre?

 2        A.   Well, nothing.  When we reached the National Theatre, there was a

 3     bit of resistance there, but we managed to break through them, and we

 4     pushed them back to the left bank.  And the soldiers passed by first, and

 5     then after us came Seselj's men.  We didn't touch the civilians or

 6     anything.  But they looted and so on.  As far as they were concerned,

 7     what their eyes saw, their hands took.  They took everything.  They just

 8     stole and looted.

 9        Q.   Why do you say these people were Seselj's men?

10        A.   Because that's how they introduced themselves, and they had some

11     membership booklets of the Serbian Radical Party.  And I was up at the

12     check-points by Nevesinje when they were stopped.  They were stopped by

13     Krsto Savic, and Krsto Savic was the commander -- police commander for

14     Herzegovina, for the whole area of Herzegovina, and people asked him, Who

15     are these?  And he said, Seselj's men.  And they also showed some

16     documents to him.  He would examine them.  I have no idea what they were.

17     But, anyway, that's what happened.

18        Q.   Was that on the 12th of May or was it another day that they were

19     stopped?

20        A.   It was in May, up in Nevesinje.  It was another day, not that

21     day, while I was waiting for a truck from Mostar or to Mostar.  They

22     would be stopped at a check-point.

23        Q.   So would it be correct to summarise what you said, that you

24     recognised these men as being the same ones that you then saw again on

25     the 12th, behind the lines that you were in when you were in Mostar on

Page 15322

 1     the 12th of May?

 2        A.   Yes.

 3        Q.   Did Seselj's men take anyone into the National Theatre?

 4        A.   Yes, they did, the Croat.  And when I saw this Croat, he was

 5     all -- well, his face was completely distorted from the beatings.  And

 6     then later on they took him away and mistreated him in the National

 7     Theatre and took him down to Bunur, an area as you're going to the old

 8     town.  And then they threw him into a shaft and threw two hand-grenades

 9     in the shaft and killed him.

10        Q.   How do you know that they threw him into the shaft and threw

11     grenades in?

12        A.   Later on, when the people cleared the area, there was a stench.

13     You can imagine what stench there is coming from a corpse when the

14     temperature is 35 degrees.  You couldn't get within several hundred

15     metres of the area from the stench.

16        Q.   How do you know that it was Seselj's men and not someone else who

17     threw him into the shaft?

18        A.   Because they took him away.  They took him there.  And that shaft

19     was at a distance from the National Theatre of some 50 to 70 metres.

20     It's just one street between them.

21        Q.   In May of 1992, did you see any human bodies in Mostar, in

22     Eastern Mostar, lying in the streets perhaps?

23        A.   Well, yes, there were some.  If you went down Tito Street, there

24     were corpses on all sides, and that was mid-May.  There were people

25     killed.  They were lying 'round about on the road.  I don't know who

Page 15323

 1     collected up the bodies later.

 2        Q.   And you described this in your statement, but it's not clear.

 3     And what I wanted to clarify is:  Were these bodies civilians or

 4     military?

 5        A.   Civilians.

 6        Q.   Were you able to identify the ethnicity of any of these people or

 7     can you not tell us?

 8        A.   No.

 9        Q.   Who were in control of that part of Mostar at this particular

10     point in time in May 1992?

11        A.   Well, that part in Mostar was controlled by the Serbs.  However,

12     that part wasn't actually controlled by anybody, because there was

13     general lawlessness, chaos, and anarchy.  You could lose your head in a

14     second.  If you weren't with them or if you just happened to say

15     something that somebody didn't like, you could be killed.  Nobody was

16     answered -- was held accountable for anything.

17        Q.   Now, moving to the events on June 13th, 1992, that you already

18     described or testified about, I'd like to ask you about the beginning of

19     those events.  You were given an order to participate in an operation.

20     What was your order?

21        A.   I don't know what operation you mean.  Do you mean when we were

22     fighting against the Muslims and Croats in battle or when Mr. Kandic

23     ordered something?

24        Q.   Sorry.  Kandic's order.

25        A.   Kandic ordered us -- well, he -- that was around 3.00 or 4.00 in

Page 15324

 1     the afternoon.  We were fighting the Croats and Muslims.  A sabotage

 2     group was infiltrated, and when we dealt with them -- when we finished

 3     our business with them, then Kandic said -- or somebody came and said

 4     that Kandic had ordered all the civilians to be collected up for

 5     interrogation because those civilians were possibly hiding the saboteurs

 6     in their houses or whatever.

 7        Q.   And the collected civilians, where were they to be taken?

 8        A.   They were to be taken to North Camp, that's where they were

 9     supposed to be taken, but we didn't take them anywhere.  My group didn't

10     take them anywhere because we knew all those local people.  They were all

11     locals.

12        Q.   But I understood from your evidence today that other units must

13     have taken people to these places.  Is that correct?

14        A.   Yes, yes, other units did take people off.  They took them to the

15     football stadium at Vrapci and the dressing rooms there or changing

16     rooms.

17             May I have five minutes to go to the toilet, please?

18             JUDGE ANTONETTI: [Interpretation] You can go ahead.  We'll wait.

19     Go ahead.

20             Usher, could you please escort the witness, and then we'll wait

21     for his return.

22             Just a minute.  We need to drop the blinds first.

23             In order to save time, we'll break right now, and then we will

24     resume at 12.00, and we'll continue non-stop until 1.45.

25                           --- Recess taken at 11.38 a.m.

Page 15325

 1                           --- On resuming at 12.04 p.m.

 2             JUDGE ANTONETTI: [Interpretation] The court is back in session.

 3             Mr. Marcussen.

 4             MR. MARCUSSEN:  Your Honours, before I continue my examination of

 5     the witness, I wondered whether the accused, now that he has had the

 6     break to look at his book, could indicate to us what pages from this

 7     rather voluminous book that he intends to refer the witness to when we

 8     get to the cross-examination.

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj.

10             THE ACCUSED: [Interpretation] Mr. President, I haven't found the

11     page, but it is easy to find.

12             Oh, my microphone wasn't on.  It's on now.

13             Mr. Marcussen's associate can help him.  Benis [as interpreted]

14     was in Podgorica on the 25th of May with me and that he was wounded

15     there, and I referred to this several times during the examination of

16     some other witnesses.  And I'd like to raise that; nothing more.

17             And as far as Miroslav Vukovic, Cele, is concerned, he was also

18     wounded in Podgorica.  Forty-two pieces of shrapnel from the bomb were

19     found in his body, and this case was tried in Podgorica, the assassin

20     case.

21             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, from what I have

22     understood, the date of the 25th of May, 1992, is mentioned in the book,

23     the arrival of Mr. Seselj, together with Olivia Barret [as interpreted],

24     B-a-r-r-e-t, as well as Miroslav Vukovic, who seemingly was wounded.

25     That's it.  Well, we will see things a bit better later on.

Page 15326

 1             MR. MARCUSSEN:  We have been given no assistance by the accused.

 2     I am not able to understand in Cyrillic how to find this.

 3             Now, the other thing is during the break the accused has provided

 4     some documents that he's going to use for cross-examination.  From my

 5     very limited understanding of this, or, rather, the briefing that I have

 6     been given, my impression is that some of the documents concern an issue

 7     that might have been unexpected and that came up today in response to one

 8     of the Judges' question, but one of the documents is a document regarding

 9     a Radovic who has been discussed here a number of times.  Now, Radovic is

10     also referred to in the statements of the witness's, and therefore

11     there's no reason that the accused could not have provided this document

12     earlier.  It has been clear all the time that the witness would be giving

13     this evidence, and we should have been provided this and the Court should

14     have been provided this at the beginning of the witness testimony.

15             So I object to the accused's use of this particular document

16     which has been provided to us during the break.

17             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, in the witness's

18     statement made under oath, Radovic is a member, according to him, of the

19     Serbian Radical Party.  This is what I have understood.  The documents in

20     Cyrillic, which I don't know anything about, may indicate that he belongs

21     to another party.  Let's wait and see what questions are put during the

22     cross-examination, and then you may put further questions after that.

23     For the moment, I have no information, but in light of the case file I

24     have some idea of what might happen afterwards.

25             MR. MARCUSSEN:  Your Honours, but this illustrates the problem.

Page 15327

 1     The document is not translated, is provided last minute.  Now, I'm able

 2     to assist the Court by providing you the information that this is

 3     apparently some sort of membership registration for this particular

 4     person, and that's what I'm saying.  This could have been brought to

 5     everyone's attention much earlier than during the break.  We only got it

 6     at noon.  I guess Your Honours also just received it now.  So I'm

 7     objecting to the use of that document.

 8             The other documents which have to do with elections, I'm not

 9     objecting to.

10             THE ACCUSED: [Interpretation] Judges, I really thought that I'd

11     refrain from any further objections so that we would finish with this

12     witness today.  However, that will not be possible, obviously.  This is

13     the first time I hear today that Dragan Samardzic and Drago Tamindzija

14     are my associates.  Today is the first time I hear of this.  No one ever

15     said that to me before.

16             MR. MARCUSSEN:  I'm not objecting to the election documents.  I'm

17     objecting to use of the registration of Radovic.

18             JUDGE ANTONETTI: [Interpretation] Proceed.  We'll see this later.

19             THE ACCUSED: [Interpretation] As for the sixth document, I don't

20     have to use it at all.  This is just Radovan Radovic's application form

21     dated the 15th of October, 1994, when joining the Serb Radical Party.

22     Radovan Radovic was mentioned several times, including last week by

23     Dabic.  However, no war crimes are linked to Radovan Radovic.  There is

24     no reason for me to prove when he became a member of the party.  They

25     sent me this just like that, along with other documents.  I don't need to

Page 15328

 1     use that document at all.  The first five documents are important to me.

 2     And this is the first time I hear of these names today.  They are not in

 3     any of the previous documents.

 4             JUDGE ANTONETTI: [Interpretation] Proceed, Mr. Marcussen.

 5             MR. MARCUSSEN:

 6        Q.   VS-1067, you testified that you were -- your unit was given an

 7     order to round up remaining Muslim and Croat civilians.  From what area

 8     were they to be rounded up?

 9        A.   The area of Zalik.  That's in Mostar, opposite the Northern Camp.

10        Q.   Would that be on the eastern or the western side of the river?

11        A.   The eastern side.

12        Q.   And in your testimony earlier on today, a couple of times you

13     made reference to events taking place on the right-hand side or the

14     left-hand side of the river.  Now, the right-hand side of the river, is

15     that east or west?

16        A.   If I say the right-hand side, then if we're going towards

17     Sarajevo, it's the right side.  But if we're going from Metkovic, it's

18     the left side.  However, we all say that the area where the Croats were

19     is the right side, west bank.

20        Q.   So when you testified about the right side, you testified about

21     an area that was predominantly Croat; is that correct?

22        A.   Well, it's not correct that it was predominantly Croat, because

23     the population was mixed there, all of us were a mixed population.

24     However, above Mostar over there, the population was, I think, almost

25     100 per cent Croat.  The town, itself, was not populated by Croats only.

Page 15329

 1             MR. MARCUSSEN:  I'd like the usher if we can call up an exhibit

 2     that has already been admitted as P851.

 3        Q.   VS-1067, I'm going to ask you about the list which hopefully

 4     comes up in a bit.

 5             Can we zoom in on the top part?  That will be fine.

 6             Can you see this list?

 7        A.   Yes.

 8        Q.   Now, I want to ask you, because at -- you have talked about a

 9     friend of yours that you went to try to fetch.  And at page 16, line 9,

10     his spelling might not have been entirely correct.  I wanted to ask you

11     is:  Your friend that you have testified about today, is he on this list,

12     is his name there?

13        A.   Number 2.

14             MR. MARCUSSEN:  Thank you.  We're done with the exhibit.

15        Q.   You talked about the junkyard, and could you describe the role

16     that Rajko Janjic had in events there?

17        A.   Rajko Janjic, well, he stood by a machine, a bulldozer.  Later

18     on, I heard that he used that bulldozer to cover the bodies of the dead.

19     He was a bulldozer driver, otherwise-wise.

20        Q.   And where did you hear that from?

21        A.   Well, later on people were talking about it, and he, himself,

22     boasted about that, that he covered the bodies that way and was involved

23     in that killing.  He was involved in all sorts of things, at least

24     according to the way he had talked about it.

25        Q.   Did he tell you how many people were killed at the junkyard?

Page 15330

 1        A.   He didn't tell me exactly, but later on we heard on the news and

 2     people were saying that they had killed around 100 persons.

 3        Q.   And we talked about the junkyard.  What's the name of that or the

 4     name of the location where it is?

 5        A.   Uborak, Uborak.

 6        Q.   Could you -- is it correctly spelled U-b-o-r-a-k?

 7        A.   Yes.

 8        Q.   Did Janjic also tell you about other killings that took place on

 9     the 13th of June?

10        A.   He didn't tell me exactly.  Well, he talked about all sorts of

11     things when he would get drunk.  To tell you the truth, I didn't even

12     listen all the time.  He said that he and Pejak would give two sheep for

13     a Muslim, well, all sorts of rubbish.  To tell you the truth, I didn't

14     even listen to him, and I don't even know what he did say and what he did

15     not say.

16        Q.   Are you familiar with a killing of some people at a location

17     referred to as VTI?

18        A.   Well, they brought them there.  There was a group there from

19     Bjelusine, Seselj's men, and they took them for interrogations.  And what

20     they did to them, I don't know.

21        Q.   How do you know it was Seselj's men who took them there?

22        A.   What do you mean?  Those who were there, the VTI.  I mean, are

23     you asking me how come I know who the people at the VTI were?

24        Q.   Yes.

25        A.   Well, these people came to Bjelusine, and there was a group

Page 15331

 1     there.  It was sort of -- well, this was a military institute, and they

 2     had re-done it and it was sort of a pharmacy by then, and there were some

 3     wounded persons there.  However, there were also members of the Serb

 4     Radical Party there who had come from Serbia.

 5        Q.   And how do you know that the members of the Serb Radical Party

 6     from Serbia were involved in the killing of the 30 people?

 7        A.   You mean at Uborak?  I mean, you got me a bit confused now.

 8        Q.   According to what you remember, what happened, and the VTI?

 9     Let's start from the beginning.

10        A.   I know that they brought some people there.  But that they killed

11     him, I don't know, I can't remember.  I mean, I'm so confused now.  It's

12     been 18 years, after all, Mr. Prosecutor.  However, some members of the

13     Serb Radical Party were there who had come from Serbia, and they were

14     stationed there.

15        Q.   I understand, and thanks for being so open to the Court about

16     what you remember and what you don't remember.  That's, of course, very

17     important.

18             Are you familiar with or do you today remember --

19             THE ACCUSED: [Interpretation] Now it's the Prosecutor testifying.

20     How can he say whether it's sincere or not?

21             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, please proceed.

22             MR. MARCUSSEN:

23        Q.   VS-1067, are you familiar with an incident in which some people

24     got killed in the woods in June 1992?  Or, rather, maybe I should put

25     that differently.  Let me rephrase that.  That some people were detained

Page 15332

 1     or rounded up in the woods and killed at someplace, 79 people?

 2        A.   Halfway between Mostar and Zijemlje.

 3        Q.   Please explain to the Judges what you know about this incident?

 4        A.   Well, they were Muslims from Nevesinje.  The police captured

 5     them, and also some volunteers from Serbia participated in that too.  And

 6     I know that they said that they had killed all of them.  The commander of

 7     the military police then was this Zdravko Kandic.  Zdravko Kandic was

 8     commander of the military police in the Nevesinje Brigade then.  This

 9     is -- well, on the 16th of June, the Army of Republika Srpska was

10     established, and it happened around then.

11             MR. MARCUSSEN:  I'd like to ask the usher to call up

12     Exhibit 65 ter number 1771, please.  And I'd like us to go to the last

13     page of that.  And if we can zoom in under the signature block or sort of

14     the lower part of the page.

15        Q.   I believe that this document is signed by a person called Krsto

16     Savic, and it says "Chief of the Centre."  Would this be the person that

17     you have already mentioned with this name as chief of the police?

18        A.   Yes.

19             MR. MARCUSSEN:  And I just indicate to the Court that the

20     document is signed for Mr. Savic.  It's not his signature on the

21     document, and that's reflected in the translation as well.

22             Could we now call up 65 ter 1551, please.

23             THE ACCUSED: [Interpretation] Objection.  What does this mean,

24     Judges?  The witness mentioned Krsto Savic as the chief of police for

25     that part of Herzegovina, and now the Prosecutor is showing a document to

Page 15333

 1     the witness, and on the last page of this document it says "Krsto Savic,"

 2     but it also says that someone else signed this.  Now, what is the

 3     Prosecutor doing to us in this courtroom?  Krsto Savic is alive and

 4     healthy, is in prison in Bosnia, and at every point in time is accessible

 5     to the OTP and to the Court.  You can summon him to testify here.  But

 6     the Prosecutor is turning this trial into a mockery.  What is the witness

 7     supposed to recognise here; that Krsto Savic's name is typewritten here

 8     and that somebody else signed on his behalf?  Why is the Prosecutor doing

 9     this to us?

10             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, do you wish to

11     reply or do we move on?

12             MR. MARCUSSEN:  I believe that I pointed out the very fact that

13     the document wasn't signed by Mr. Savic.  No attempt at misleading anyone

14     here.  The document is stamped, and it's quite normal that military and

15     police documents and reports are signed by a lower-ranking officer on

16     behalf of a superior officer.  So there's nothing abnormal about this.  I

17     haven't even tendered the document yet.  I might do that later, but let's

18     see.

19             Now, I asked if we could see 65 ter number 1551.  So once we get

20     that up, I believe, Your Honours, that this time we have a document which

21     is signed by Mr. Savic, himself.  No, that's incorrect.  It's signed by

22     Milorad Cuk this time for Mr. Savic.

23             I'd like to go to page 5 of the English version and to page 5 of

24     the B/C/S version.

25             THE ACCUSED: [Interpretation] Judges, I insist that you first ask

Page 15334

 1     whether the witness ever had this document in his hands at the relevant

 2     time.  This witness here is not a military or police expert, so he cannot

 3     testify about official documents.  Krsto Savic can be asked about his

 4     document, or this assistant of his, Milorad Cuk, who signed on his

 5     behalf, not this witness.

 6             MR. MARCUSSEN:  I'm going to have a question about the contents

 7     of the document, really.

 8             JUDGE ANTONETTI: [Interpretation] Yes.

 9             THE ACCUSED: [Interpretation] Well, this witness cannot give his

10     opinion about the content of the document.  The witness is testifying

11     about what he had seen or heard.  He's not supposed to give his opinion

12     about the content of the document.

13             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the witness has

14     never seen this document, that's for sure, but the document mentions a

15     number of items, which you will see, which cross-reference what he said

16     before.  Let the Prosecutor put his question, and during your

17     cross-examination you'll be able to provide counter evidence.  On looking

18     at the document, I see that there are some paragraphs which coincide with

19     what he has said already.

20             Please proceed, Mr. Marcussen.

21             MR. MARCUSSEN:  Thank you, Your Honour.

22        Q.   Towards the top of the document, there's a description of a group

23     of people as Seselj's men, and then there's talk about leader called

24     Vranjanac.  Do you know this person?

25        A.   Yes.

Page 15335

 1        Q.   Who is he?

 2        A.   Well, when this Mico Drazic left, he represented himself as their

 3     leader, and he did not disarm in August 1992.

 4        Q.   And he presented himself as the leader of who, of what group, of

 5     who?

 6        A.   He was the leader of this group of Seselj's men, and they all

 7     obeyed him.  As I've already said, they mistreated people.  It didn't

 8     matter whether you were Serb, Croat, or a Muslim.  They maltreated

 9     everyone.

10             MR. MARCUSSEN:  Your Honour, I would at this point tender Exhibit

11     65 ter 1551.  The witness has clearly corroborated the contents of the

12     document, and we also have learned from the witness --

13             THE ACCUSED: [Interpretation] Objection.

14             MR. MARCUSSEN:  Let me finish my submission on why the document

15     should be admitted, then you can answer afterwards.

16             And the witness has --

17             THE ACCUSED: [Interpretation] You interrupt me, too.  When I

18     speak, you interrupt me, you intervene, and then I stop.

19                           [Overlapping speakers]

20             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the Prosecutor is

21     explaining why he wishes to tender it into evidence.  Let him finish, and

22     then you can object.  He hasn't finished.

23             What did you want to say, Mr. Marcussen?  You wanted to tender --

24             MR. MARCUSSEN:  I was going to seek the admission of 65 ter 1551.

25     The witness has confirmed that the person who at least is put on as being

Page 15336

 1     the authority who issued the document that is stamped is, in fact, a

 2     person who had the position that the document says, and the witness has

 3     confirmed the correctness or corroborated the correctness of the

 4     information in the document.  And I submit that on that basis, the

 5     document is admissible, and I tender it before the Court.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, what did you have

 7     to say?

 8             THE ACCUSED: [Interpretation] That is absolutely impossible.

 9     This witness is testifying about what happened in Mostar.  Milorad Cuk

10     describes what happened in Nevesinje.  The witness, himself, says that

11     Vranjanac was expelled with his group in October 1992 in Nevesinje.  Then

12     someone should explain to us how come this group came to Nevesinje and

13     they appeared in Mostar.  What does that mean, that it was in Mostar?

14     How come?  It is Krsto Savic or Milorad Cuk that can explain that.  And

15     you keep saying that various gangs were affiliated with me.  Even if they

16     did introduce themselves as Seseljevci, call someone who is competent and

17     then admit it into evidence.  I cannot question this witness about a

18     document that Cuk signed.

19             JUDGE ANTONETTI: [Interpretation] Let's give this document an MFI

20     number, and the Chamber will deliberate after the examination.

21             Can we have a number, please.

22             THE REGISTRAR:  It will be Exhibit P891, marked for

23     identification.

24             JUDGE ANTONETTI: [Interpretation] Witness, I have a follow-up

25     question.

Page 15337

 1             This document seems to be an official document.  It is a report

 2     on the activities of paramilitary formations, and in this document there

 3     is mention of a group called Seselj's men, led by Vranjanac.  You said

 4     that this leader was in command until August 1992, and you said that they

 5     were expelled after that.  Very well.  But you added something in

 6     passing, but which I believe was of utmost importance.

 7             Just look at the transcript.  You said that these people, as the

 8     document says, were carrying out abuse, they were abusing Muslims,

 9     Croats, and Serbs, which could mean that this group was also attacking

10     the Serbs?

11             THE WITNESS: [Interpretation] In fact, they didn't attack them

12     with weapons, but they mistreated them and abused them.  There is this

13     one thing that happened before their expulsion from Nevesinje.  They

14     mined the Croatian church in Nevesinje.  Look at this paradox.  The

15     Croatian church is practically in the center of town.  Twenty metres

16     away, there are residential houses, and also nearby is a hospital where

17     there were 150 to 200 wounded were put up there.  And imagine, when they

18     blew up that church, how damaged the houses and the hospital were.  And

19     that led to the elimination of these people from there, because they blew

20     up this Croatian church in the middle of an inhabited settlement.

21             JUDGE ANTONETTI: [Interpretation] Well, Mr. Marcussen, proceed.

22     I believe you have less than 15 minutes left, maybe only 10 minutes or 5

23     minutes.

24             MR. MARCUSSEN:  Thank you, Your Honours.

25             Could we call up -- sorry.  Maybe we could call up 65 ter number

Page 15338

 1     1771 again.  And if we can go to page 2 in both versions.

 2             JUDGE HARHOFF:  Mr. Marcussen, what exactly is this document?

 3             MR. MARCUSSEN:  This is a report signed for Krsto Savic from the

 4     Security Centre of the Republika Srpska, Ministry of Interior, and it is

 5     a report on the work of the Trebinje CSB, so that will be the Security

 6     Centre, on the period from April to December 1992, so the time-frame

 7     that's relevant to the allegations in the indictment.  And they talk

 8     about the establishment of the RS MUP in the area, and it's relevant for

 9     that reason to the case, as such.

10        Q.   What I wanted to ask, VS-1067, is:  There is mention of some

11     special units of the police in some -- it will be in the third paragraph

12     in the B/C/S version of what you are seeing.  Are you familiar with

13     Special Police units being in any of these locations?

14        A.   No.

15             MR. MARCUSSEN:  Your Honours, I have no further questions for the

16     witness.

17             JUDGE ANTONETTI: [Interpretation] Thank you.

18             Mr. Seselj, you have one hour.

19                           Cross-examination by Mr. Seselj:

20        Q.   [Interpretation] In these statements of yours and during today's

21     testimony, I was surprised by many things, but I was most surprised when

22     you said that my associates contacted you and disturbed you and

23     threatened you.  So when the Presiding Judge asked you which of my

24     associates, you mentioned Dragan Samardzic and Drago Tamindzija; right?

25        A.   Yes.

Page 15339

 1        Q.   How do you know that those two men are my associates?

 2        A.   I don't know about Samardzic.  But Drago Tamindzija, when the war

 3     ended, he was one of the main people in the Serbian Radical Party.

 4        Q.   Well, during the break my people contacted Nevesinje and learned

 5     that Dragan Samardzic has been living abroad for quite some time and that

 6     it isn't known whether he's a member of any party.  Is that correct?

 7        A.   Well, it could be.  I don't know.

 8        Q.   But you didn't say he was a member, did you?

 9        A.   No.

10        Q.   You said that he was an associate of mine?

11        A.   I didn't say -- well, he called me up and threatened me.

12        Q.   That's not what I'm asking you.

13             THE INTERPRETER:  Could the speakers kindly speak one at a time.

14     Thank you.

15             MR. SESELJ: [Interpretation]

16        Q.   The Judge asked you which of my associates called you up, and you

17     mentioned him first.  Now, I don't want to enter into whether he actually

18     threatened you or not.  I have no interest in challenging that.  All I

19     want to know is:  Did you say he was my associate or not?

20        A.   I don't know.

21        Q.   A moment ago, you expressly stated that he was my associate?

22        A.   I know about Drago Tamindzija for sure.

23        Q.   You mean that he was my associate?

24        A.   That he was in your party in 1996.

25        Q.   In 1996, he was, but he called you in 2007 and threatened you.

Page 15340

 1     That's what you said; right?

 2        A.   From your party.

 3             JUDGE HARHOFF:  You speak the same language, so you fall into the

 4     trap of overlapping, which makes it impossible for the interpreters to

 5     interpret and thus communicate to us what you're saying.  So please

 6     observe a pause between answer and question.

 7             MR. SESELJ: [Interpretation]

 8        Q.   Do you know that since 2002, in Republika Srpska there is a party

 9     which is called the Serbian Radical Alliance of Dr. Vojislav Seselj?

10        A.   I don't know that.

11        Q.   And that there exists a political party who is falsely

12     representing itself as the Serbian Radical Party of Republika Srpska?

13        A.   Well, I've heard of the existence of that party.

14             THE ACCUSED: [Interpretation] Now, would you be so kind -- well,

15     yes, I am switching off my microphone as soon as I finish, I am taking

16     that on board.

17             Now, could we provide the witness with this copy, and I hope that

18     you have distributed it to the Trial Chamber and to the Prosecutor.

19        Q.   Now, with your help, let's establish who this Drago Tamindzija

20     is.  The first document is an official copy of the Official Gazette of

21     Republika Srpska, and it speaks about certified lists -- nomination lists

22     for 2004, the 20th of October, 2004.  Now, turn over -- the 2nd of

23     October, rather.  And then you'll see the parties in Nevesinje that are

24     up for election, and it says that there's this Serbian Radical Alliance

25     of Dr. Vojislav Seselj, and it says that's in the middle of the page,

Page 15341

 1     second column in the middle of the page.

 2        A.   Yes.

 3        Q.   And then a little lower down it says "The Serbian Radical Party

 4     of Republika Srpska"; right?

 5        A.   Yes.

 6        Q.   Now turn the page -- or, rather, don't go on to the next page

 7     right away.  On the page we were dealing with, it says "The Serbian

 8     Radical Party of Republika Srpska."  That is the party which falsely

 9     represented itself as being the Radical Party; is that right?

10        A.   Well, I really can't say.  If it says "The Serbian Radical Party"

11     here, and I can't comment.

12        Q.   It says the "Serbian Radical Party of Republika Srpska"; is that

13     right?

14        A.   Yes.

15        Q.   Before that, it said "The Serbian Radical Alliance of

16     Dr. Vojislav Seselj" in column 3, can you see that?  And can you see the

17     list of nominees in Nevesinje beginning with Dragan Vistic [phoen],

18     Natasa Mustic [phoen], Luka Radojcic [phoen], et cetera?

19        A.   Okay.

20        Q.   Now here we have "The Serbian Radical Party of Republika Srpska,"

21     as it says.  Now, if a party bears my name in its title, then it did so

22     to be clearly differentiated from some false party with a similar name;

23     is that logical?

24        A.   Yes.

25        Q.   Now, this Serbian Radical Party of Republika Srpska which I say

Page 15342

 1     is falsely representing itself has as its candidate -- as its nominee

 2     Drago Tamindzija; is that right?  Turn the page, and you will see name

 3     underlined, and it is "Drago Tamindzija"?

 4        A.   Correct.

 5        Q.   So Drago Tamindzija is a candidate in the elections of this party

 6     that falsely represents itself as a radical party which I don't recognise

 7     as being our party, right?

 8        A.   Yes.

 9        Q.   Now turn to the next page.  It's another document, and here we

10     have the electoral results for Nevesinje Municipality, the local

11     elections held in 2008?

12        A.   Yes.

13        Q.   It says "The Serbian Radical Party, Dr. Vojislav Seselj"; right?

14        A.   Yes.

15        Q.   And we won 826 votes or 12.15 per cent; right?

16        A.   Yes.

17        Q.   Right below that is the "Serbian Radical Party of Republika

18     Srpska," and it secured 7.46 per cent of the votes; right?

19        A.   Right.

20        Q.   Are those two different parties?

21        A.   From this document, we can see that they are, indeed, two

22     different parties.

23        Q.   Now, examining a witness last week, I said that this other party

24     falsely representing itself was led by Mihajlo Mihajlica.  Do you know

25     this man, Mihajlo Mihajlica?

Page 15343

 1        A.   No, I don't think so.

 2        Q.   All right.  Now, turn to the next page, and it's document

 3     number 3 that I'd like to look at now.  It is the Nevesinje Municipal

 4     Assembly, and we have the electoral results there.  The Serbian Radical

 5     Party of Republika Srpska, that's the one that I don't recognise and

 6     doesn't have my name in its heading; right?

 7        A.   Yes.

 8        Q.   So everything is clear now?

 9        A.   Yes --

10        Q.   And number 5 is Drago Tamindzija; right?

11        A.   Yes.

12        Q.   Now turn to the next page, which is document number 4, and these

13     are elections in 2004.  It says, "The Serbian Radical Party of Republika

14     Srpska," and in fourth place "Drago Tamindzija," right?

15        A.   Yes.

16        Q.   Now turn to the next page, and this is document 5.  Once again,

17     we have the elections for the Municipal Assembly of Nevesinje

18     Municipality, and this is the Serbian Radical Alliance of

19     Vojislav Seselj; right?

20        A.   Yes.

21        Q.   There we have a list of candidates and who was elected and Drago

22     Tamindzija is no where on the list, right?

23        A.   Right.

24        Q.   And document number 6, I'm not going to ask you anything about

25     that.  It's an application form for Radovan Radovic becoming a member of

Page 15344

 1     the Serbian Radical Party.  Have I convinced you here now that

 2     Drago Tamindzija cannot be an associate of mine in any way and that he's

 3     not a member of the party that I lead?

 4        A.   That's right, but when you say "Serbian Radical Party," nobody

 5     abroad, we all think that it's -- they're your men.  I had no idea that

 6     this Serbian Radical Alliance of Vojislav Seselj existed and the BH

 7     Serbian Radical Party.

 8        Q.   Well, now it's clear to you that a party does exist which is

 9     registered as being the Serbian Radical Party, but that it is erroneously

10     presenting itself.  And is it possible that in the war, you might have

11     come across people who falsely represented themselves as being Seselj's

12     men; is that possible?

13        A.   Yes.

14        Q.   And is it possible that this man, Vranjanac, is one of those

15     people who was expelled from Nevesinje for crime and false

16     representation?

17        A.   Yes, that is possible, sir.  But if you would like me to give you

18     some elements, to have the man arrested and then an investigation can be

19     launched.

20        Q.   Well, the Prosecutor can give orders for that.  I haven't started

21     arresting anybody yet, and if I do, well, all hell will break lose one

22     day, if one day I start arresting people, unless they keep me here in

23     prison for the rest of my life.

24             Now, you mentioned the arrival of Seselj's men in Mostar?

25        A.   Yes.

Page 15345

 1        Q.   And that's true.  A group of volunteers, at the beginning of

 2     April, 7th or 8th of April, 1992, did indeed arrive in Mostar, and it was

 3     put up next to the command of General Perisic, is that right, next to his

 4     headquarters?

 5        A.   I saw them in Bjelusine the first time.

 6        Q.   Was Perisic's command there somewhere?

 7        A.   I think that Perisic's command and headquarters was somewhere in

 8     North Camp, or I'm not sure exactly, or at the airport.

 9        Q.   You were in North Camp, and Perisic wasn't there.  Just let me

10     finish.  I haven't got much time.  I'd like to get through all this.  I

11     will have some blitz questions to ask you.

12             You said that they arrived in three trucks?

13        A.   Yes.

14        Q.   Which direction did they arrive from?

15        A.   From the south, from Buna.

16        Q.   Is that from the airport direction?

17        A.   Yes.

18        Q.   Did you ever hear that they came to Mostar by plane?

19        A.   No.

20        Q.   Did they have absolutely brand-new camouflage uniforms, the likes

21     of which nobody had seen in Mostar until then?

22        A.   Yes.

23             THE INTERPRETER:  Could the speakers kindly slow down.  It's

24     impossible to translate at this speed.

25             JUDGE HARHOFF:  Slow down, please.  You speak too fast, and it's

Page 15346

 1     impossible for the interpreters to --

 2             MR. SESELJ: [Interpretation]

 3        Q.   So during April, these volunteers of the Serbian Radical Party,

 4     so-called Seselj's men, it was easy to recognise them because they were

 5     wearing new camouflage uniforms; is that right?

 6        A.   Yes.

 7        Q.   However, since the beginning of May the camouflage uniforms were

 8     given to other members of the JNA, the Territorial Defence and other

 9     units; is that true too?

10        A.   Well, it's like this, let me tell you:  People did have them, but

11     95 per cent were wearing the olive-green-type uniforms.

12        Q.   But in May, supplies of camouflage uniforms started.  That's all

13     the information I need you to confirm.

14        A.   Yes.

15        Q.   Did the military police begin to wear these camouflage uniforms,

16     too, at that time?

17        A.   The military police and the reconnaissance men, they had

18     camouflage uniforms.

19        Q.   They began wearing them first, when we're talking about the Serb

20     forces, because it was still the JNA; right?

21        A.   Yes.

22        Q.   So when they began wearing camouflage uniforms, you were no

23     longer able to distinguish Seselj's men from the rest; right?

24        A.   Well, Seselj's men all had long beards.  They didn't shave.  So

25     those who represented themselves as being your men, they had long hair

Page 15347

 1     and beards and never shaved.  We, of course, did shave.

 2        Q.   You know that I am the oldest Chetnik vojvoda to this day?

 3        A.   Yes, and I respect that.

 4        Q.   Do you know that I've never had long hair or a long beard?

 5        A.   Yes.

 6        Q.   So why would this wearing of long beards be a mark of Seselj's

 7     men?  Do you know that there were other men, too, who kept the Chetnik

 8     tradition of wearing long beards from different parties and so on;

 9     Vuk Draskovic and et cetera?  Do you know about that?

10        A.   Yes.

11        Q.   And do you know that Vuk Draskovic, at Ravno Gora, erected the

12     first monument to Draza Mihajlovic?

13        A.   Yes.

14        Q.   So I don't have the monopoly over the Serbian Chetnik Movement;

15     is that true?

16        A.   Yes, that's true.  There are other groups, too.

17        Q.   Is it true that the Serb adversaries called all Serb forces,

18     referred to them as Chetniks?

19        A.   Yes.

20        Q.   Did they call you Chetniks, the Muslims, Croats and so on, did

21     they call you Chetniks too?

22        A.   Yes.

23        Q.   Very well.  Now, you mentioned the Serbian Chetnik Movement here

24     in Nevesinje of Arsen Grahovac.  Now, do you know that Arsen Grahovac was

25     a member of the Serbian Radical Party and the Serbian Chetnik Movement

Page 15348

 1     within our composition, so our constitutive part, in actual fact,

 2     constituent part?

 3        A.   No, I think he used to say he was a Vukovac man, a Vuk man.

 4        Q.   So you have no proof that he has anything to do with the Serbian

 5     Radical Party and me personally and the Chetnik Movement within our

 6     composition, under us?

 7        A.   No, they had their own Karadjordje Chetnik Movement, and to whom

 8     they belonged, I really couldn't say.

 9        Q.   All right.  Now, the authorities of the Muslim-Croatian

10     federation arrested you sometime in 1996; is that right?

11        A.   Yes.

12        Q.   And you were accused of some war crime, but you were released

13     from prison quickly and you were given a symbolic sentence; is that

14     right?

15        A.   Yes, I spent three and a half months in prison.

16        Q.   However, in the -- during the investigation, you gave a

17     statement, and in that statement you described this crime at Zalik,

18     Vrapcici, and so on, where, on two occasions, more than 100 Muslims were

19     killed; is that right?

20        A.   Yes.

21        Q.   The statement you gave to the Muslim authorities served the

22     Cantonal Prosecutor's Office in Mostar to expand the indictment against

23     people who personally took part in that crime; is that right?

24        A.   No.

25        Q.   What happened, then?

Page 15349

 1        A.   I was accused, as well as Sasa Zurovac.  Sasa Vaskovic [phoen]

 2     and Matkovic were accused of having killed some Muslim civilians.

 3        Q.   Let's leave that to one side, why you were accused.  You were

 4     accused for a limited number of killings; is that right?

 5        A.   Yes.

 6        Q.   Two or three or four?

 7        A.   Two.

 8        Q.   But when you made your statement to the Muslim-Croatian

 9     federation authorities and then an investigating judge, you described

10     this crime in detail at Uborak and Zijemlje and what happened at the

11     football statement at Vrapcici?  You told them the story in great detail;

12     is that right?

13        A.   Yes.

14        Q.   And that was recorded, your testimony was recorded?

15        A.   Well, that's what was -- what should have been the case.

16        Q.   And you name the names of people whom you knew had taken part in

17     the crime; is that right?

18        A.   Yes.

19        Q.   There were some 14 or 15 people that you mentioned, that you

20     named; is that right?

21        A.   Yes.

22        Q.   Now, do you know that the Cantonal Prosecution Office from Mostar

23     raised an indictment against some 30 Serbs for these crimes in Zijemlje,

24     at Uborak, and in Vrapcici?

25        A.   No.

Page 15350

 1        Q.   I showed this document here in the courtroom.  I was provided it

 2     by the Prosecutor.  And all those people on the list were accused of

 3     something, whether in Mostar or in the surrounding municipalities, but

 4     you have no knowledge of that document?

 5        A.   No.

 6        Q.   When you made your statement to the Muslim authorities or,

 7     rather, the authorities of the federation, nowhere did you mention

 8     Seselj's men, did you?

 9        A.   I mentioned those people, but I didn't know their names, their

10     first and last names.  There was a Vranjanac, there was a Srecko, a

11     Bosanac, and so on.  Now why they didn't take them I don't know, but I

12     did mention them.

13             THE ACCUSED: [Interpretation] Now, Judges, the OTP was duty-bound

14     to disclose that statement by this witness in the Mostar investigation

15     and then they failed to do so.  All I have is a copy of the judgement,

16     where we can see that this witness was given a very mild sentence and

17     released from prison or, rather, exchanged.

18             THE WITNESS: [Interpretation] I was exchanged after three and a

19     half months.

20             THE ACCUSED: [Interpretation] You were exchanged for some Muslims

21     that were supposed to be tried in Republika Srpska.  So, Judges, that was

22     tendentious on the part of the OTP for failing to provide me with that

23     document.

24        Q.   Now, the next statement that you gave, you gave in a foreign

25     country where you were arrested for theft, as you, yourself, told us?

Page 15351

 1             JUDGE ANTONETTI: [Interpretation] Witness, I am just discovering

 2     that you were in jail for three and a half months.  You hadn't mentioned

 3     this in your statements -- in your 2004 statement, and that you had been

 4     indicted for murder.

 5             THE ACCUSED: [Interpretation] 2006, Mr. President.

 6             THE WITNESS: [Interpretation] 1996.

 7             JUDGE ANTONETTI: [Interpretation] And that you were indicted for

 8     the murder of two to three people?

 9             THE WITNESS: [Interpretation] Two persons.

10             JUDGE ANTONETTI: [Interpretation] Two people.  In the Republic of

11     Bosnia-Herzegovina, there are investigating judges and investigators, and

12     these are professional people, generally speaking.  Were you heard by the

13     investigative judge?

14             THE WITNESS: [Interpretation] Yes, an investigating judge

15     interrogated me.  However, these two civilians who were referred to, they

16     were members of the Army of Bosnia-Herzegovina, and they had the insignia

17     of the golden lily, the highest in their army.  However, the other people

18     were civilians.

19             JUDGE ANTONETTI: [Interpretation] Very well.  All the better for

20     you, it's what's most important for you.  But when the investigative

21     judge put questions to you about these crimes and those who had committed

22     the crimes or committed -- or participated in the crimes, why didn't you

23     mention paramilitary groups at the moment, including Seselj's men?  Why

24     didn't you mention that at the time?

25             THE WITNESS: [Interpretation] What do you mean, when I was in

Page 15352

 1     Mostar?

 2             THE ACCUSED: [Interpretation] He did not mention Seselj's men at

 3     that point, Judge.  He mentioned the perpetrators of the crime by their

 4     names, but he did not mention Seseljevci at all.

 5             JUDGE ANTONETTI: [Interpretation] I'm asking you for the

 6     following reason:  An investigative judge is a professional, a senior

 7     professional, and normally when this man investigates a crime, he wants

 8     to know the ins and outs of the crime.  So when speaking with you, he

 9     puts a question, and he probably wanted to know who committed these

10     crimes and whether these formations reported to or belonged to political

11     parties.  I assume he asked these questions, but I don't have the

12     transcripts here, but it seems that you never mentioned Seselj's men

13     except in 1998, when you were asked questions by the investigator of the

14     OTP.  I'm trying to understand why, in a very serious investigation, in

15     front of a professional judge, you said nothing, but later on you provide

16     details, but only later on.

17             THE WITNESS: [Interpretation] I beg your pardon, sir.  I repeated

18     the same thing in Mostar, what I'm saying here and now.  Now, it wasn't

19     the judge who was putting questions to me; it was policemen.  I just go

20     to the judge, who'd read something out to me, and then I'd go away.

21     Perhaps I'd spend 15 minutes with the judge, 15 or 20 minutes.  Is that

22     enough to clarify a war crime?

23             JUDGE ANTONETTI: [Interpretation] Whatever the case may be, you

24     said that you mentioned Seselj's men in front of the policeman who

25     conducted the investigation?

Page 15353

 1             THE WITNESS: [Interpretation] Yes.

 2             THE ACCUSED: [Interpretation] Mr. President, now this is a new

 3     thing for me as well.  As for this statement before a Muslim Croatian

 4     policeman, I never received it, and I was supposed to receive all of

 5     that, all the previous statements made by this witness that the

 6     Prosecutor has, and the Prosecution did not submit that to me on purpose.

 7     Now, only 23 days ago --

 8             MR. MARCUSSEN:  It's now the third time that the accused is

 9     alleging that we have been holding back documents from him.  We have

10     disclosed the documents we have.  It is well known to the Court and it's

11     well known to the accused that there might be occasion when witnesses

12     have given statements to other authorities which the Prosecution don't

13     have.  The accused should refrain from this.  We have disclosed, to the

14     best of my knowledge, everything we have regarding the witness.  The

15     accused has his own large team who can go and get the documents that

16     needs -- wants for his examination, so I object to these kind of

17     allegations against the Office of the Prosecutor.

18             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, this is what I had

19     understood.  Seemingly, the Prosecutor did not receive these documents.

20     He is telling you that he has given you everything he has.  The interview

21     before the investigating judge and the policeman is something which he

22     did not receive.  He might not even have known about it.

23             THE ACCUSED: [Interpretation] Mr. President, I have to deny that.

24     What I received here is a copy of the judgement against this witness in

25     1996.  Where there is the copy of the judgement, there is also a witness

Page 15354

 1     statement made by him, at the beginning, then from the investigation

 2     itself, and also the statement given before the police.  The Prosecution

 3     provided me with only a copy of the judgement, because there is nothing

 4     in the judgement.  And now where there is some content and what is

 5     important for me is what the Prosecution is not giving me.  Now it seems

 6     they are trying to present it as if I had a stronger team than the OTP.

 7     That is ridiculous, Judges, that I have more resources than the OTP.  How

 8     can I have contacts with the police or the judiciary of the federation?

 9     I have no contacts with them whatsoever.  I can have contacts with people

10     from Nevesinje, people who lived in Mostar up until the war, and so on

11     and so forth.

12             As for the official authorities of the federation, I have no

13     contact whatsoever with them.  The OTP does have contacts with them and

14     has good co-operation with them, and they didn't want to provide me with

15     these documents.  And they knew that these documents had to exist, even

16     though they claim that they do not have them in their hands, which I do

17     not believe.

18             May I continue now?

19             On the 29th of January, the OTP informed me of the following, and

20     they submitted to me the police report of a foreign country from 1998.

21     Oh, please don't tell me that the OTP received it only on the 29th of

22     January 2010, that they received that police report, that -- they got it

23     a lot earlier.  This police report was a pretext for The Hague

24     investigators to interview this witness at all in late 1998.  Otherwise,

25     they wouldn't have known of this witness, had the police of that foreign

Page 15355

 1     country arrested -- not arrested them -- him, rather.  I'm not going to

 2     mention the name of the country, otherwise, you'll redact the transcript.

 3             Should I go on or are we going to wait for Mr. Marcussen to go on

 4     whispering?  All right, then let me move on.

 5             JUDGE ANTONETTI: [Interpretation] Continue.

 6             MR. SESELJ: [Interpretation]

 7        Q.   In 1998, you were arrested in a foreign country, and that is

 8     where you were interviewed on account of different kinds of theft; right?

 9        A.   Yes.

10        Q.   Also the crime of driving without a license, possession of

11     weapons, and so on, all sorts of things?

12        A.   Yes.

13        Q.   When the police completed those interviews, then they started

14     interrogating you about the war, and you described very precisely

15     everything that happened on the 13th of June, 1992, in the area of

16     Vrapcici, Uborak, Zijemlje; is that right?

17        A.   Yes.

18        Q.   And there you mentioned the names of the perpetrators of those

19     crimes; that is, 2, 4, 6, 8, 10 -- at least 12 names; right?

20        A.   I can't remember, but yes.

21        Q.   Roughly?

22        A.   Roughly.

23        Q.   You described all of that in detail, and you did not mention at

24     all that there was a single man of Seselj's there; is that right?

25        A.   That's not correct, sir.

Page 15356

 1             THE INTERPRETER:  Microphone, please.

 2             JUDGE ANTONETTI: [Interpretation] One moment, Mr. Seselj.

 3             Mr. Marcussen, I have a question for you.  I'm discovering that

 4     you disclosed at the beginning of January to Mr. Seselj this report that

 5     has to do with the events that he is charged with in this foreign

 6     country.  This witness is a witness of the Court.  Why didn't you give

 7     this to the Judges, for what reason?

 8             MR. MARCUSSEN:  The order that we were given was to provide the

 9     Chamber with all statements of the witnesses.  That is what we were -- we

10     were given some additional directions, for example, not to provide

11     transcripts of witnesses who have testified, only their statements.

12     There was some material that had already been provided to the Chamber.

13     And so that is what we have done.

14             This witness has criminal record.  They have been disclosed to

15     the accused.  And, actually, the information that the accused just made

16     reference to --

17             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, let me stop you

18     here.  I acknowledge that you have not disclosed documents which, in my

19     view, should have been disclosed because these documents have to do with

20     the character of the witness.  Don't forget that he has protective

21     measures, that in this document he has made statements about the events

22     that took place in June of 1992, and these documents are documents which

23     I do not have.  That's all I have to say.

24             MR. MARCUSSEN:  The statements that the accused is making

25     reference to, I have already explained, we have disclosed everything we

Page 15357

 1     had, the statements that we would have had from the witness from other

 2     authorities would also have been given to Your Honours, pursuant to your

 3     order, for your remaining witnesses.  The criminal records have not been

 4     provided to you because we did not realise the Chamber wanted this.  All

 5     this kind of material has been disclosed to the accused under Rule 68,

 6     and actually the information that I think the accused is referring to

 7     that he got on the 29th of January was provided to him back when the

 8     witness was originally scheduled to testify in the form of a proofing

 9     note, that we disclosed to the accused as soon as the information came

10     out, and the witness had told us about this information in proofing.

11             We had then obtained the official records, we have had them

12     translated from a foreign language and into the accused's language, and

13     we have only been able to disclose on the 29th to the accused.  So I

14     strongly object to these allegations of any impropriety and deliberate

15     delays in the Prosecution's disclosure of any material to the accused.

16     It's simply unfounded.  It's repeated allegations by the accused, and

17     it's inappropriate.

18             Now, if Your Honours would like to receive this kind of

19     information with respect to the remaining witnesses, I am happy to

20     undertake to go back and look at what other criminal records we may have

21     for some of these witnesses.  I am aware that we have disclosed documents

22     in that regard to the accused, and I'm happy to provide them to the

23     Chamber.  We're certainly not trying to hold anything back from Your

24     Honours.

25             JUDGE ANTONETTI: [Interpretation] Please proceed.

Page 15358

 1             THE ACCUSED: [Interpretation] What Mr. Marcussen said is an

 2     absolute lie.  The first time the police record of an interrogation of

 3     this witness before the police of a foreign country from July 1998, I

 4     received it for the first time on the 29th of January, 2010.  It wasn't

 5     the beginning of January.  That may have been misinterpreted to you.  It

 6     was towards the end of January, the 29th of January.  And today is the

 7     3rd of February, so it was only this Friday that I first got this ever in

 8     my life, this Friday.  And it's not true that it was given to me after

 9     the proofing.  During the proofing, they did mention that the witness had

10     been arrested, but as for the statement made before the police of this

11     foreign country, I got it only now, and you never received it.  However,

12     I never received the statement made before the police in Mostar and

13     before the investigating judge of the Muslim-Croat federation.  I never

14     received that.  I simply do not have that.  However, I do have

15     information, that I received through a certain lawyer, that I was never

16     mentioned in those two statements.  In those two Mostar statements, there

17     is no mention of Seseljevci.  There is only mention of the persons who,

18     to the best of the knowledge of this witness, who took part in the crimes

19     that I am being charged with now.  That is the core of the matter.

20             May I proceed now?

21             JUDGE ANTONETTI: [Interpretation] Proceed.

22             MR. SESELJ: [Interpretation]

23        Q.   Are you denying that this is what you had said to the police of

24     that foreign country?

25        A.   I didn't understand the question.

Page 15359

 1             THE INTERPRETER:  Microphone, please.

 2             MR. SESELJ: [Interpretation]

 3        Q.   You enumerated the names of all the perpetrators that you

 4     allegedly knew of, the perpetrators of that crime in the area of

 5     Vrapcici, Zijemlje, and Uborak; you said that to the police of this

 6     foreign country?

 7        A.   Yes.

 8        Q.   All of these are names of locals either from Mostar or from

 9     Nevesinje, and even now, if they live in a foreign country, you mentioned

10     which foreign country they live in, right?  You even put that there?

11        A.   I can't remember that.  I can't remember that, but I know and I'm

12     sure that I said that Bosanac, Srecko, were there, and that they said

13     that they were Serb Radicals.

14        Q.   They are not in this document.

15             Please, Judges, have a look at this document of the police of

16     this foreign country and see for yourselves that these people are not

17     there, that this witness is trying to present as Seseljevci only

18     subsequently at a later point.

19             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you are talking

20     about a document which the Prosecutor did not disclose to the Judges

21     because he felt it was not necessary.

22             MR. MARCUSSEN:  I suggest that we admit that -- that we put that

23     document onto the record so everyone can see what it is that's being

24     talked about.  So why don't we admit it as a Defence exhibit or as a

25     trial exhibit and then everyone can see it, and then no secrets.  We're

Page 15360

 1     certainly not trying to hold back anything from the Judges.  I strongly

 2     object to this.  And as I've indicated, if there's anything the Judges

 3     would like to have from us, we are happy to share it with the Court.

 4             THE ACCUSED: [Interpretation] Judges, not a single document that

 5     the OTP disclosed to me is going to be admitted into evidence as a

 6     Defence document.  However, you ordered the OTP to provide you with all

 7     the statements of this witness, and they did not do that.  Now, this

 8     statement before the police of a foreign country, they had it -- the OTP

 9     had it, and they didn't submit it to me -- to you, and they didn't submit

10     to you or to me the statements made before the police in Mostar and the

11     investigating judge in Mostar, which I think would be very, very

12     important.  I believe that's not in dispute.  And now the Prosecutor is

13     teaching me what I'm going to tender as Defence exhibits?  I am not going

14     to tender anything.  I -- what matters to me is the public and that I

15     show the public that I have cut into pieces this false indictment, and I

16     did that from one witness to another.

17             You have falsified the evidence, you forged the evidence, you

18     have false witnesses, and all of that serves your purposes.  Perhaps the

19     Judges could save more time by not questioning this witness, and then I

20     wouldn't have to do all of this for the sake of the transcript.

21             JUDGE LATTANZI: [Interpretation] You cannot say that the

22     Prosecutor has forged an indictment which has been approved by the

23     Judges, as you know.

24             THE ACCUSED: [Interpretation] All right, then.  All right, then.

25     Then I forged everything.  I forged the transcript, the police record

Page 15361

 1     from a police of a foreign country, and I stole it from the OTP, and then

 2     the OTP took for granted my forgery.  I accept that.  And I also forged

 3     the police record of this witness before the police in Mostar and before

 4     the investigating judge in Mostar.  Right.

 5             Now, if you'll allow me to proceed.  Let us try to get this done

 6     and over with today.  Further questions are actually pointless, after

 7     what has happened.

 8        Q.   Now, I received here from the Prosecutor quite a record of yours.

 9        A.   Okay.

10        Q.   Since the OTP provided me with that, I would not have dealt with

11     it, I really wouldn't have looked into your record or your CV, because I

12     know what my volunteers did in that area.  And if somebody had introduced

13     themselves falsely, then there has to be material evidence to support

14     that.  I have proof.  Have you heard of Oliver Denis Baret?

15        A.   Yes.

16        Q.   Do you know that he was the commander of the volunteers of the

17     Serb Radical Party, the so-called Seseljevci, but the real original

18     Seseljevci in Mostar?

19        A.   Yes.

20        Q.   If Oliver Denis Baret was commander, no doubt about that, of the

21     original Seseljevci in Mostar, then it couldn't have been Mico Drazic; is

22     that right?

23        A.   Sort of.

24             THE INTERPRETER:  Microphone.

25             THE WITNESS: [Interpretation] Vranjanac came to the fore only in

Page 15362

 1     June, when Mico Drazic and Oliver whatever his name is disappeared.

 2             MR. SESELJ: [Interpretation]

 3        Q.   Did Mico Drazic have anything to do with Oliver?

 4        A.   I never saw them together.

 5        Q.   So you heard that Oliver Denis Baret was commander of the

 6     Seseljevci?

 7        A.   Yes.

 8        Q.   Did the OTP forbid you to put that into your statement when you

 9     talked to them?

10        A.   I can't remember.

11        Q.   Oliver Denis Baret is a very well known name?

12        A.   Yes.

13        Q.   Very well known?

14        A.   Yes.

15        Q.   How come he's not mentioned in any one of your statements here?

16        A.   I don't know.  I didn't mention him because I don't know of him

17     creating any kind of problems.

18        Q.   You never heard of Oliver Denis Baret and people under his

19     command taking part in any kind of crime; theft, looting, killing, any

20     kind of crime?

21        A.   Any kind of crime.

22        Q.   Thank you.  This is very important to me, because I'm very proud

23     of the role that Oliver Denis Baret and his people played in the war.

24             Now, I have evidence here that Oliver Denis Baret withdrew from

25     Mostar before the 25th.  Actually, he withdrew together with the JNA.  Do

Page 15363

 1     you know when the JNA left Mostar?

 2        A.   On the 28th of May.

 3        Q.   Oliver Denis Baret withdrew before the 25th of May, and here he

 4     is at a rally that I held on the 25th of May in Podgorica.  Podgorica is

 5     the capital of Montenegro; right?

 6        A.   Yes.

 7        Q.   Did you hear that a shell had been thrown at me then in -- a

 8     hand-grenade had been thrown at me in Podgorica then?

 9        A.   Yes.

10        Q.   And here is the entire court record of the proceedings against

11     the assassins.  Sixty-two persons were wounded on that occasion.  Did you

12     hear that a large number of people were wounded there?

13        A.   Yes.

14        Q.   Did you hear that I was injured then as well, that I was hit in

15     the leg?

16        A.   Yes.

17        Q.   Here we have, on page 50 -- I hope that the Prosecutor has found

18     this.  This is the interrogation of -- or, rather, the interview of

19     Oliver Denis Baret as one of the wounded persons there.  He was hit by 42

20     shrapnel.  Do you know how many a hand-grenade has?

21        A.   Many.

22        Q.   Perhaps 3.000?

23        A.   Many.  I don't know exactly how many.

24        Q.   But it's an enormous number?

25        A.   Yes, I know.  I was wounded myself.

Page 15364

 1        Q.   Do you know that one of my escorts was composed and that he

 2     kicked one of them under a car, that this saved several lives?

 3        A.   I heard of that.

 4        Q.   And all of us who were wounded were wounded in the lower part of

 5     the abdomen or on our legs and feet; is that right?

 6        A.   I heard about that.  I don't know.

 7        Q.   Do you believe now that Oliver Denis Baret, on the 25th of May,

 8     was seriously wounded in Podgorica?

 9        A.   Well, if you have proof that he was in hospital, then I believe

10     that.

11             THE INTERPRETER:  Microphone, please.  Microphone, please.

12             MR. SESELJ: [Interpretation]

13        Q.   Forty-two balls were found in his body, and the Prosecution has

14     that evidence and has had it for quite some time.  Now, what the OTP

15     provided me, as far as you're concerned, some other West European

16     countries are mentioned where you were arrested.  There were several

17     others.  We're not going to mention them.  Is it correct?

18        A.   Yes.

19        Q.   Was it four or five countries?

20        A.   Two.

21        Q.   Which others?  No, all right.  We're not going to mention

22     countries.  Right.  So two more?

23        A.   A total of two.

24        Q.   I see, a total of two.  And now they go on to list the reasons

25     for which you were arrested.  You were accused of having taken part in

Page 15365

 1     some crime organisation?

 2        A.   Yes, for killings.

 3        Q.   Very well.  Then something else listed here is what you stole.

 4     You stole in department stores mostly; right?

 5        A.   Yes.

 6        Q.   Clothing; right?

 7        A.   Yes.

 8        Q.   And all the items of clothing are listed.  And then it says

 9     "Illegal possession of weapons," and then you were a suspect in a

10     killing?

11        A.   Yes.

12        Q.   And is all that correct?

13        A.   I was just a suspect, but you don't spend just one month in

14     prison if you have killed someone.

15        Q.   Now, I have information saying that during the war you were

16     arrested in Nevesinje too; is that correct?

17        A.   Yes.

18        Q.   And they were crimes of aggravated theft.  And in addition to

19     you, five more individuals were arrested, five others.  We're not going

20     to mention their names, not to disclose your identity.

21        A.   Right.

22        Q.   It says that in the Nevesinje Municipality in 1993/1994, you

23     looted several facilities, catering establishments, that you stole

24     cameras, video-recorders, white goods, alcohol, coffee, cigarettes, and

25     the like.  Is it true that you were arrested for those reasons?

Page 15366

 1        A.   Just for the theft of various apparatuses and cameras.

 2             THE ACCUSED: [Interpretation] Now, I have this document from 1994

 3     provided to me by the Prosecutor, but they failed to provide me with the

 4     police files and court files, and they were duty-bound to do so, Judges,

 5     to disclose to me everything that would help me challenge the credibility

 6     of this witness.  You know that better than I do.  You're far more better

 7     acquainted with the law than I am.  I have just become acquainted with

 8     Defence counselling of late.

 9             JUDGE ANTONETTI: [Interpretation] I don't want to spend much time

10     on this, but you were arrested for a series of thefts.  Were you

11     convicted or were you proved not guilty?

12             THE WITNESS: [Interpretation] I was a suspect, but never

13     convicted.

14             JUDGE ANTONETTI: [Interpretation] Very well.

15             MR. SESELJ: [Interpretation]

16        Q.   According to the information I have, belong to the Cicciolina

17     unit; right?

18        A.   Yes.

19        Q.   And it takes its name from Cicciolina, the famous Italian lady

20     politician?

21        A.   Yes, she was a respected member of the Italian Parliament.  Yes.

22        Q.   Well, I need that for a bit of an exotic approach to these

23     proceedings.  Now, when you say that Seselj's men looted in Mostar and

24     Nevesinje, you have in mind this man Vranjanac, I assume.

25        A.   Yes.

Page 15367

 1        Q.   Do you have information according to which Oliver Denis Baret and

 2     his group ever stole anything?

 3        A.   Oliver and his group, I didn't see them, but I did see this man,

 4     Vranjanac, and the other one.  They took everything they could lay their

 5     hands on.

 6             THE ACCUSED: [Interpretation] What I'd like, the Prosecutor to

 7     identify this man, Vranjanac; if nothing else, then to accuse him of

 8     false representation here, because I can't seem to gather information

 9     about him.

10        Q.   And then you say at one place that the stolen goods from Mostar

11     were driven to Nis?

12        A.   Somewhere in Serbia.  I don't know whether Nis in particular.

13        Q.   In your statement, it says "Nis."

14        A.   I can't remember.

15        Q.   Well, I can find it.  I'll take a moment, and maybe I can find

16     it.

17             Now, if you set out from Mostar to Nis in a truck, where would

18     you go?

19        A.   You'd go to Bjelica -- you'd pass through Bjelica, Niksic,

20     Podgorica.

21        Q.   Through Montenegro?

22        A.   Yes.

23        Q.   So you'd have to drive the stolen goods through Montenegro?

24        A.   Yes.

25        Q.   And do you know that throughout Serbia there were police

Page 15368

 1     check-points, and throughout Montenegro you couldn't move from one town

 2     to another with clandestine goods or stolen goods without passing through

 3     check-points?

 4        A.   I apologise to you, Mr. Seselj, but from the Mostar Aluminium

 5     Company they took 300 trucks -- truckloads of aluminium.  So how could

 6     they cross the borders?  They had some papers.

 7        Q.   You mean Seselj's men?

 8        A.   No, no, no, I mean the JNA.  Perhaps they had some JNA documents

 9     or whatever.  They had to have had some documents to be able to exit

10     Mostar.

11        Q.   But for something to be transported from Mostar and Nevesinje to

12     Serbian Montenegro, a large-scale mafia-type organisation must have

13     existed?

14        A.   Yes.

15        Q.   You couldn't just have a group of people loading goods up onto a

16     truck and drive it away to Serbia and Montenegro without having a broader

17     organisation; is that right?

18        A.   Yes.

19        Q.   So do you agree that it was only the mafia that could smuggle

20     goods on this scale?

21        A.   Well, I don't know, sir.  I don't know what documents they had,

22     but they had to have some kind of permit from Mr. Perisic to be able to

23     leave Herzegovina at all.

24        Q.   War booty is one thing.  If aluminium was an important strategic

25     natural resource, the JNA took it from the aluminium combine or it took

Page 15369

 1     weapons from underground storehouses and depots?  If it was tragically

 2     important, they could do that?

 3        A.   Right.

 4        Q.   But what about people looting white goods and television sets and

 5     drive them to Serbia?

 6        A.   Well, I don't know, but they drove them off somewhere.

 7        Q.   Yes, they drove them off and then resold them to refugees in

 8     Nevesinje.  And you said that 30.000 people had -- that there were 30.000

 9     refugees from the Neretva River Valley, and they needed household goods

10     in a hurry?

11        A.   Yes.

12        Q.   So for somebody to drive white goods, used television sets, to

13     Serbia, at that time it would be more costly to pay for the fuel needed

14     for the trucks to drive these goods off than they would get by selling

15     the goods, themselves; am I right in thinking along those lines?

16        A.   Yes.

17        Q.   So is there any logic, then, that the volunteers of the Serbian

18     Radical Party who had come from Serbia, and only two groups arrived in

19     that area, Oliver Denis Baret, one group, to the withdrawal of the JNA,

20     and later on a small group of some 20 men under the command of Branislav

21     Vakic in Nevesinje?  Have you heard of Branislav Vakic?

22        A.   No.

23        Q.   So as to this group that was the regular volunteer group of the

24     Serbian Radical Party, you've never heard of that group?

25        A.   No.

Page 15370

 1        Q.   Now, we've logically established that the goods, used goods,

 2     white goods, it just didn't pay to have them transported that far away?

 3        A.   Well, yes.

 4        Q.   And it's true that you could sell them in Nevesinje for very

 5     little money?

 6        A.   A television set costs 50 or 100 German marks.

 7        Q.   So going very cheap.  And unfortunately that's what happened

 8     during this war, theft and the resale of stolen goods, but it wasn't cost

 9     effective to take it all the way to Serbia and sell it there?

10             Anyway, I have some more information that I'd like to deal with

11     here.

12             You said that some people killed a Croat, threw him into a shaft,

13     and threw a hand-grenade after him and killed him; is that right?

14        A.   Yes.

15        Q.   Now, do you link those people to this man Vranjanac or what?

16        A.   To Vranjanac.

17        Q.   And what about Oliver Denis Baret; you definitely don't tie them

18     up with him, do you?

19        A.   No.

20        Q.   We had a witness in here before you who said that some Albanian

21     had killed this Croat, throwing a hand-grenade into the shaft after him?

22        A.   Well, that could be true, too, because there were several

23     Albanians in the JNA.

24        Q.   So you couldn't say for sure -- identify for sure the person who

25     killed that civilian.

Page 15371

 1        A.   I knew who took him off.

 2        Q.   You mentioned the Muslim village of Topla.  The looting and

 3     setting fire to houses in that village, has it got anything to do with

 4     Oliver Denis Baret and the unit he was in command of?  Just tell me yes

 5     or no so we can move on.

 6        A.   No.

 7        Q.   Are you absolutely certain?

 8        A.   Yes.

 9        Q.   Thank you.  Let's move on.  Do you know that some locals would

10     get together, forming a band or gang of some kind, and say that they are

11     members of some military formation?

12        A.   Yes, there were examples of that.

13        Q.   Do you know about Ratko Mladic's order from the summer of 1992,

14     saying that all those units should be disarmed, arrested, or, if they had

15     not committed any crimes, be incorporated into the regular Army of

16     Republika Srpska?

17        A.   You mean the paramilitaries?

18        Q.   Yes, the paramilitaries.  Now, do you know that the policy of the

19     Serbian Radical Party, of which I was the head, was always against the

20     formation of paramilitary formations and including all the fighters into

21     the regular Army of Republika Srpska or, rather, Srpska Krajina, or,

22     rather, the JNA, that I was opposed to that?

23        A.   Yes, but those -- Vranjanac and the others who introduced

24     themselves that way, I can't describe them to you.  They were real

25     idiots, madmen.

Page 15372

 1        Q.   All right.  But do you have any evidence that this man,

 2     Vranjanac, and the people that he controlled I sent from Belgrade?

 3        A.   That's what they said, that's what they said, that you had sent

 4     them.

 5        Q.   They referred to that?

 6        A.   Yes.

 7        Q.   But they had no documents or papers or anything of that kind?

 8        A.   They had the little booklets.

 9        Q.   What did they look like?

10        A.   They were small blue booklets like an ID card, like the former

11     Yugoslav ID cards used to be, a small booklet, navy blue.

12        Q.   Did you see whose signature was on the book?  What did it say in

13     those little booklets?

14        A.   I didn't see anything like that.

15             THE ACCUSED: [Interpretation] You didn't; right.

16             How much more time have I got, Judges?

17             JUDGE ANTONETTI: [Interpretation] I believe you have about 20

18     minutes left.  We can continue until 10 to.

19             THE ACCUSED: [Interpretation] Then we can finish everything

20     today, and I'll speed up a little.

21        Q.   Did you have any problems with the law before the war?  For

22     hooliganism, there was something of that nature; right?

23        A.   Yes, hooliganism, brawls among supporters, sports fans.

24        Q.   Some people told me that it was your custom to demolish vehicles

25     with license plates from other towns.

Page 15373

 1        A.   For the Hajduk football team supporters.

 2        Q.   When they come into Mostar to play against Velez; right?

 3        A.   Yes.

 4        Q.   Do you know Boris Kozul, Toza, at all?

 5        A.   Yes.

 6        Q.   Edin Music, nicknamed Edin Muce, yes.

 7        A.   Yes.  He's not Edin Music, he's Edin Ramadanovic.

 8             THE INTERPRETER:  Microphone, please.  The interpreter didn't

 9     catch the next name.

10             MR. SESELJ: [Interpretation]

11        Q.   Sasa Zurovac?  I think my microphone was off, but Sasa Zurovac,

12     and the witness said, Yes.

13             Did you know these people well?

14        A.   Yes.

15        Q.   Did you socialise with them?

16        A.   Yes.

17        Q.   But as I have heard, they were well known in Mostar as drug

18     addicts.

19        A.   Zurovac and Edo or Edin Ramadanovic, they never took drugs, and I

20     can confirm that.

21        Q.   What about this Boris Kozul?

22        A.   He was the leader of the Velez supporters.

23        Q.   And did you socialise in some cafe called Garden?

24        A.   Garden, let me see.  Well, we did go 'round the cafes.  I can't

25     say for sure.  Probably, yes.

Page 15374

 1        Q.   Then there was some Black Label Cafe?

 2        A.   Yes.  I never went in there.  My foot never set foot in that

 3     place.

 4        Q.   But Sasa Zurovac was accused of looting that cafe.

 5        A.   Well, that could very well be.

 6        Q.   He didn't want to uncover his associates in front of the --

 7     before the court, so he took the whole blame upon himself?

 8        A.   I don't know.

 9        Q.   How don't you know?  He was your friend.

10        A.   Well, you know that person had committed various crimes.

11        Q.   Well, I would be proud of a friend of mine who took all the blame

12     upon himself and didn't want to implicate others, but very well.

13   (redacted)

14   (redacted)

15        A.   Could that be redacted, please?  Could we have that name

16     redacted?

17        Q.   Very well.  We're not going to mention it, then.  I don't want to

18     say anything -- it's not in my interest to say anything in private

19     session, so we'll skip that.

20             There were a number of incidents with the reservists in Mostar;

21     right?

22        A.   Yes.

23        Q.   And what about Croats; did they plant bombs and throw

24     hand-grenades?

25        A.   Cafe Azaro, Cafe Gringo.

Page 15375

 1        Q.   So there was a lot of that?

 2        A.   Yes, on the eve of celebrations and holidays.  I can't remember

 3     all of them.

 4        Q.   All right.  And some people, and we saw that from the article,

 5     accuse you of using marijuana?

 6        A.   In Mostar?

 7        Q.   Yes.

 8        A.   No.  Can I interrupt you there?  I smoked hashish for the first

 9     time in 1997 here in Holland.

10        Q.   Well, it's legal here.  It's been legalised; right?

11        A.   Yes.

12        Q.   Some people accused you of having a whole marijuana plantation in

13     Zijemlje in front of Cira's weekend cottage?

14        A.   Yes, I do, but that's not true.  Marijuana won't grow at a high

15     altitude in the mountains.

16        Q.   Well, what's the altitude?

17        A.   About 800 metres.

18        Q.   I see.  Very well.  That's what some people say about you.  And

19     when I collected this information, I didn't tell them what I needed the

20     information for.  Do you believe me?

21        A.   I believe you.

22        Q.   All right, fine.  Let's see what's next.

23             You mentioned here the crime in Zalik, linked to Vrapcici and

24     Zijemlje, and it is a unique crime -- or it's one crime, although the

25     killings took part in two parts, and everything happened when the JNA

Page 15376

 1     left Mostar; right?

 2        A.   Yes.

 3        Q.   And it was a spontaneous retaliation for -- revenge for crimes

 4     committed on the opposite side to the Serbs; right?

 5        A.   Well, I don't know what kind of revenge, who issued the orders.

 6     I really can't say.  I don't know.  Why those people were killed, I

 7     really can't tell you.  I don't know.

 8        Q.   And you didn't see any of the killings personally; right?

 9        A.   Right.

10        Q.   Tell me, please, the people manning the check-point, they were

11     all military policemen, except at the entrance to Nevesinje; right?

12        A.   Mostly, yes.

13        Q.   And those who held the check-point in Nevesinje, you tied them to

14     Arsen Grahovac, linked them to Arsen Grahovac?

15        A.   Yes.

16        Q.   So they have nothing to do with the volunteers that I could have

17     sent in?

18        A.   No.

19             THE ACCUSED: [Interpretation] Judges, I'm going to complete my

20     examination within the prescribed time, you can rest assured.  I haven't

21     got much longer to go.

22        Q.   Now, you mentioned this Radovan Radovic's unit, and you first of

23     all mentioned this man Kapor who was killed in 1992?

24        A.   Yes, Kapor.

25        Q.   How do you know that Ljubo Kapor was a member of the Serbian

Page 15377

 1     Radical Party at all?  Where do you get that from?

 2        A.   Well, the volunteers from Bjelica told me that, and that he was a

 3     vojvoda.  Now, who could have given him that title, I don't know.

 4        Q.   I don't know what kind of vojvoda he could have been.  Now, do

 5     you know that I proclaimed the first Serbian Chetnik vojvodas only in May

 6     1993?  You don't know about that?

 7        A.   No.

 8        Q.   On the basis of my information, in Bjelica there was no branch of

 9     the Serbian Radical Party in 1992, and Radovan Radovic joined up with the

10     Serbian Radical Party in 1994.

11        A.   It says here the 15th of October, 1994.

12        Q.   Well, I promised the Prosecutor that I wasn't going to refer to

13     the document, but I have my own information.  I know when he became a

14     member.  But you, sir, were a member -- were there to see him in August

15     1994?

16        A.   Yes, I did go to see him.

17        Q.   But he didn't become a member straight away?

18        A.   Well, I don't know that.  Well, I visited various front-lines.

19     Why wouldn't I have visited him?

20        Q.   What about Cicciolina?  Why didn't you visit Cicciolina?

21        A.   Well, I didn't want to go to Cicciolina, establish inter-party

22     relations with some Italian politicians at the time.  Perhaps later on, I

23     might have done so, but not linked to Rade Radovic and the others.  They

24     did not commit any crime.

25        Q.   I know that the summer I visited them, I prevailed upon Radovan

Page 15378

 1     Radovic -- I tried to persuade him to become a member of the Serbian

 2     Radical Party.  And I managed to convince him and he did become a member,

 3     and you saw when he became a member.  And I proclaimed him a Serbian

 4     Chetnik vojvoda on the occasion, because I did not want to have any

 5     Serbian Chetnik vojvodas proclaimed, anybody who is not a member of the

 6     Serbian Radical Party, in view of the fact that we had the Serbian

 7     Chetnik Movement as a component part of the Serbian Radical Party, which

 8     does not include the existence of various other Chetnik organisations

 9     that had nothing to do with us.  I suppose that's clear to you.

10        A.   Yes.

11        Q.   Do you know that to this day in Republika Srpska, there are some

12     Chetnik organisations that have nothing to do with the Serb Radical

13     Party?

14        A.   Yes, around Brcko.  I know that.

15        Q.   In various places?

16        A.   In Herzegovina too.

17        Q.   Do you know that in Serbia there are Chetnik organisations that

18     have nothing to do with the Serb Radical Party?

19        A.   Yes.

20        Q.   Can the Serb Radical Party, that is proud of its Chetnik

21     traditions, can it have a monopoly on these traditions?

22        A.   No.

23        Q.   You stated one more thing here, that the Serb Radical Party from

24     Belgrade assisted Radovan Radovic and his unit both financially and in

25     equipment?

Page 15379

 1        A.   That's what he said to us.  Before we went into action, because

 2     the Bjelica volunteers in Cicciolina went into action together, two or

 3     three days before every action he went to Belgrade and he brought

 4     uniforms, food, cigarettes, everything from Belgrade.  And he, himself,

 5     Rade Radovic, said that he got money from the Serb Radical Party.

 6        Q.   I'm interested in how come that money was there and they didn't

 7     really have that much money.  We primarily provided them with cigarettes

 8     and canned food.

 9        A.   That's what they brought.

10        Q.   I visited them twice in 1994 and 1995.  Do you know that?

11        A.   I know about 1994.

12        Q.   In 1994, he hadn't joined the party yet, and by 1995 he was

13     already a member of the Serb Radical Party and a Chetnik vojvoda.  What I

14     could do then was to give them a gift of 1.000 Deutchemark so that they

15     can treat themselves to a crate of beer and things like that.  Can you

16     believe that?

17        A.   Possibly.

18        Q.   Did they have any kind of big money?

19        A.   Well, no, I could not say that they really had any kind of big

20     money.  They did have a bit more than us.

21        Q.   Could these have been voluntary contributions for a unit that

22     became famous, and then somebody would give 50 and somebody would give

23     100 or 200 Deutchemark?

24        A.   Yes.

25        Q.   Can your statement be reduced to that?

Page 15380

 1        A.   Yes.

 2        Q.   Do you know what kind of cigarettes we could have and send to our

 3     volunteers at the front-line?  Did you ever see those cigarettes when we

 4     would send them?

 5        A.   I saw them.  We smoked those cigarettes.  I can't remember what

 6     brand they were.

 7        Q.   Were they originally packed or were they there on a wholesale

 8     basis?

 9        A.   Wholesale, in large quantities.

10        Q.   So then you can confirm that we got, as a gift from the tobacco

11     factory in Bjelusine, all the cigarettes that the machine would throw out

12     during manufacturing?  They're proper cigarettes, but then some of them

13     simply get thrown out during the manufacturing process, and then they

14     collected them for us and put them in these big carton boxes for us.  Did

15     you see such box?

16        A.   I think that there were 200 or 300 cigarettes per box.

17        Q.   There were even more.

18        A.   Well, that's what they brought to us.

19        Q.   And then we handed out these boxes to our volunteers so that

20     smokers could have cigarettes?

21        A.   Yes.

22        Q.   So it wasn't any kind of luxury cigarettes, not in the original

23     packing?

24        A.   No.

25        Q.   It is what we barely managed to get our hands on.  What about

Page 15381

 1     food?

 2        A.   Cans, for the most part.

 3        Q.   And sometimes a sack of flour, beans?

 4        A.   For the most part, yes.

 5        Q.   What could we send by way of clothing?

 6        A.   Uniforms.

 7        Q.   How did we get uniforms in 1994 and 1995?

 8        A.   I don't know.  They always had new uniforms.

 9        Q.   They had new uniforms because they were an elite unit consisting

10     of very brave fighters?

11        A.   Sorry, sir, but I was there too, and I went with that unit to all

12     the front-lines in Bosnia-Herzegovina.

13        Q.   Do you know that in 1994 and 1995, we had severely clashed with

14     Milosevic's regime and we simply could not get anything from state

15     warehouses?

16        A.   That's right.

17        Q.   So where could we get any uniforms?

18        A.   Nowhere, but they did have them.

19        Q.   But they did not get them from the Army of Republika Srpska?  Did

20     they have some kind of priority or a factory manufactured had

21     manufactured more and gave it to them as a gift?

22        A.   That is possible, but they didn't have more priority than we did

23     from the Army Republika Srpska.

24        Q.   Can you think of a factory of this kind?

25        A.   There was a factory in Bjelica.

Page 15382

 1        Q.   Did the factory from Bjelica manufacture that for them?

 2        A.   I don't know.

 3        Q.   You could have known?

 4        A.   Well, I don't know.

 5        Q.   If the factory in Bjelica manufactured uniforms, and if they have

 6     that detachment from Bjelica that became famous at many front-lines --

 7        A.   Yes.

 8        Q.   -- what would be more natural than that?  Now, why am I insisting

 9     on this?  Because the Prosecution claims in the indictment as well that

10     the Serb Radical Party financed volunteers.  The Serb Radical Party could

11     not have financed anyone, and I assert that.  Am I right when I say that?

12        A.   Yes.

13        Q.   If I'm not right, the question arises straight away as to where

14     we got our money.

15        A.   As for financing, they did get cigarettes and tinned food for

16     you.

17             JUDGE HARHOFF:  Sorry.  Mr. Seselj, I do not think that this

18     witness is in a position to testify as to where the SRS got its money

19     from and what it spent its money on.

20             THE ACCUSED: [Interpretation] But this witness was brought into a

21     situation of providing expert testimony about documents that were signed

22     by the deputy of Krsto Savic, and you didn't intervene then, Mr. Harhoff.

23     And he had never seen those documents in his life, and --

24             JUDGE HARHOFF:  Stop this, please.  This witness was not brought

25     in as an expert on anything.

Page 15383

 1             THE ACCUSED: [Interpretation] Judges, I have totally completed my

 2     cross-examination.

 3             JUDGE ANTONETTI: [Interpretation] Very well.

 4             There is no additional questions for the Court witness.  We have

 5     to finish off because Judge Harhoff has to sit on another trial.  Very

 6     often, the Judges on this Bench have two trials to attend, and it's

 7     exhausting, but that's just the way it is.

 8             Mr. Marcussen.

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15             MR. MARCUSSEN:  Thank you, Your Honour.  My apologies.

16             We have forwarded the report to the Chamber through the legal

17     officer, and my suggestion is that maybe Your Honours don't want to

18     release the witness until you've had a chance to look at the document and

19     determine whether or not you think you would want to put further

20     questions to the witness based on this particular document.

21             JUDGE ANTONETTI: [Interpretation] No, no additional questions, no

22     additional questions.  You told us that you gave the document to the

23     legal officer.  We will look at it.  Maybe the Trial Chamber made a

24     mistake.  Maybe we did obtain this document and couldn't -- didn't see it

25     or neglected it.  We'll look into this.

Page 15384

 1             MR. MARCUSSEN:  I do not think Your Honours have received the

 2     document.  That's why I forwarded it.

 3             Also, if Your Honours have any wishes for other documents, such

 4     as criminal records, for any of the witnesses, I hope Your Honours will

 5     communicate that to the Prosecution so we can assist Your Honours with

 6     any kind of records you might require.

 7             JUDGE ANTONETTI: [Interpretation] Very well.  Let me put the

 8     question to my fellow Judge, Judge Lattanzi.  I believe she had a

 9     question for the witness, an additional question.

10                           Further Questioned by the Court:

11             JUDGE LATTANZI: [Interpretation] Quickly, as far as you know,

12     because maybe you know nothing about all this, but as far as you know,

13     could you tell us whether the volunteers of the Serbian Radical Party,

14     the Seseljevci, whether they were all officially members of the Serbian

15     Radical Party or whether there were also volunteers who were not members

16     of the SRS; maybe they joined later on, maybe they never joined?  So as

17     far as you know, do you know anything about this?

18        A.   I don't know about that.  I cannot say.

19             JUDGE LATTANZI: [Interpretation] Thank you.

20        A.   I cannot say.

21             JUDGE ANTONETTI: [Interpretation] Witness, on behalf of my fellow

22     Judges, I thank you for coming and testifying here for the Court.  Don't

23     leave right now, because we have to drop the blinds.  I wish you a safe

24     return home.

25             Mr. Seselj, we will resume on Tuesday, February 16, at 9.00 a.m.,

Page 15385

 1     since there will be no hearing next week.  So Tuesday, February 16,

 2     9.00 a.m.  Thank you.

 3                           [The witness withdrew]

 4                           --- Whereupon the hearing adjourned at 1.50 p.m.,

 5                           to be reconvened on Tuesday, the 16th day of

 6                           February, 2010, at 9.00 a.m.