Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15880

 1                           Tuesday, 11 May 2010

 2                           [Open session]

 3                           --- Upon commencing at 2.19 p.m.

 4                           [The accused entered court]

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

 6     case, please.

 7             THE REGISTRAR:  Thank you and good afternoon, 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             Before we bring the witness in, the Trial Chamber will hand out

12     several oral decisions, in the following order:

13             First order.  The Trial Chamber is asking the Prosecution to

14     file, at the latest on the 1st of June, 2010, all motions which it feels

15     it needs to file before the 98 bis decision is rendered, which means,

16     Mr. Marcussen and Ms. Biersay, that you have until the 1st of June to

17     file all your requests.  After that, it will be too late.  When once

18     these motions have been filed, Mr. Seselj will have enough time to reply

19     to these motions when they have been translated in his language.  That is

20     the first oral decision.

21             The second oral decision concerns the motion filed by the OTP on

22     29th of March, 2010.  I shall read it out slowly.

23             Considering the motion recorded by the Registrar on the 29th of

24     March, 2010, with a view to obtaining, in its second motion, i.e., Bar

25     table, the possibility to exceed 3.000 words and to extend this to 4.353

Page 15881

 1     words.  Considering the Practice Direction in the length of motions and

 2     applications, given that the Bar table motion aims at admitting 180

 3     documents which most relate to the speeches of the accused and the

 4     interviews he gave in the period covered by the indictment.  Considering

 5     that the Trial Chamber holds that the important number -- in light of a

 6     great number of documents and the need for the Prosecution to

 7     justify each document in detail, the reasons for filing a motion,

 8     substantiate exceeding the word limit in the Practice Direction of the

 9     16th of September, 2010.  Considering that it is in the interests of

10     justice for the accused to benefit from the same time delay if he wishes

11     to reply to the Bar table motion.  For the foregoing, we will grant the

12     motion and order that the second Bar table motion of the Prosecution not

13     exceed 4.400 words and, second, that the reply filed by the accused to

14     the second Bar table motion, in the event that he would like to reply,

15     not exceed 4.400 words.

16             Mr. Seselj, I would like to indicate today that the Prosecutor

17     has sent us a voluminous motion which contains seven volumes.  I

18     personally spent five hours looking into all the documents to realise

19     that we have here three series of documents, one first series which has

20     to do with all the interviews you had, the second series which relate to

21     all your speeches before the National Assembly of your country, and the

22     third series of documents are miscellaneous documents, including press

23     articles.

24             The first two series, i.e., your interviews and your speeches

25     before the National Assembly, are documents which lie at the heart of the

Page 15882

 1     joint criminal enterprise and documents which may include incriminating

 2     evidence, i.e., to incite to commit crimes.  It would be most advisable

 3     for me and my colleagues if you were to respond to these submissions to

 4     give us your opinion on each of the documents that relate to your

 5     interviews.  I was about to say this is at the core of the Prosecution's

 6     case.

 7             The Prosecution's motion needs to be translated for you, of

 8     course, and we have set the word limit at 4.400 words for your reply.

 9     You have 15 days to reply, but in light of the fact that this motion is

10     exceedingly important, you could perhaps ask for additional time to

11     respond.  You may decide also not to respond.  That is for you to judge.

12             In addition, I would like to indicate that the Prosecution has

13     filed a judicial notice on the basis of the Krajisnik judgement.  There

14     are 10 facts or so for which the Prosecution has requested a judicial

15     notice.  We also need to know your position on this.  Let me, from

16     memory, remind you that this has to do with item 24 of the Prosecution's

17     motion.  You have been mentioned specifically in the Krajisnik judgement.

18             That said, contrary to what I had told you a few weeks ago, since

19     I knew nothing about the motions filed by the Prosecution which have been

20     coming in of late at an increasing pace, we will undoubtedly not be able,

21     before the end of August or the beginning of September, start on the

22     98 bis procedure.  In light of all the work that needs to be undertaken

23     by the Trial Chamber for it to be able to hand down its decision relating

24     to the two motions, and given your submissions and motions, we have every

25     reason to believe that we will only be able to start after having

Page 15883

 1     completed all of this beforehand, start on the 98 bis procedure at the

 2     end of September and not, as I stipulated previously, in June, because at

 3     the time I knew nothing about the fact that the Prosecution was going to

 4     file such motions.

 5             I also have a decision that I would like to hand down in closed

 6     session.

 7             You have raised your hand.  If what you have to say is very

 8     short, I will give you the floor straight away.  We must not forget that

 9     a witness is waiting and our time is very valuable, because the Trial

10     Chamber will have two hours to question the witness, the Prosecution will

11     have two hours, and you will also have two hours, Mr. Seselj.  Please

12     make it short.

13             You have the floor.

14             THE ACCUSED: [Interpretation] Mr. President, first of all, I

15     would like to state my position about what you just said briefly, and

16     then I have four administrative issues to raise, but that will also be

17     brief.

18             You can relax.  I will not do what would suit you most, because I

19     don't want to give you coverage for prejudicing my right to due process.

20             What the Prosecution is asking for is not based in either

21     continental or common law.  I am strictly opposed to a document being

22     admitted without a witness, but that has been done.  But to allow the

23     Prosecution to send documents by mail, that is not grounded in any kind

24     of law.

25             In many cases here, the accused did not have proper Defence.  We

Page 15884

 1     had a decision concerning video-recordings.  You ordered the Prosecution

 2     to bring all the video-clips, to see them in the courtroom, and the

 3     Prosecution had, according to your order, to state their arguments, and I

 4     would be given the right to respond.  In the same way, the Prosecution

 5     can present their documents through witnesses one by one, explain why

 6     they're relevant, and I should have a chance to respond concerning

 7     relevance.  That would be clear-cut, like with video-recordings.

 8             Now, for the Prosecution to give you a batch of documents and

 9     that I should be asked to respond, that is out of the question.  The

10     Prosecution should also make available video-recordings of my Assembly

11     speeches, my newspaper and radio interviews, et cetera.  But newspaper

12     articles which reflect a journalist's subjective interpretation of

13     events, for them to be admitted into evidence without any witness to

14     corroborate it, without any chance to discuss it in the courtroom, that

15     is absolutely out of the question.  That is a dirty trick that the

16     Prosecution is trying to make you approve, and I won't participate in it.

17     You would be contributing to further irregularity of this process, and

18     this process has long been completely irregular for many, many reasons.

19     Rest assured that you can -- that you are going to save time, because I'm

20     not going to waste it.

21             As for judicial notice of facts determined in the Krajisnik case,

22     gentlemen Judges, Krajisnik himself complained that he did not have

23     adequate Defence.  Do you know what happened to Krajisnik once in the

24     courtroom?  He had a witness that was cross-examined, and Mr. Krajisnik

25     asked to ask a few questions himself.  And his lead counsel got to his

Page 15885

 1     feet immediately and told the Trial Chamber that he is opposed to his

 2     client asking questions.  That counsel kept his own client in the status

 3     of idiot in the courtroom.  Mr. Krajisnik withdrew his power of attorney

 4     from that counsel, decided to defend himself in the appeals proceedings,

 5     and then engaged a new lawyer as assistant.  His trial was irregular.  He

 6     had inadequate Defence.  What the Trial Chamber found in his case, I

 7     don't care.  I do not recognise a single sentence from that judgement.

 8             A very new book will soon appear by me, "The Hague Anti-Serbian

 9     Guillotine," in which I expose the many irregularities and prejudices to

10     the accuseds' right to due process in many cases in this Tribunal,

11     including those in my own trial.

12             Now, I have to raise a few administrative issues.

13             JUDGE ANTONETTI: [Interpretation] One moment, Mr. Seselj.  The

14     Trial Chamber has noted your comments.  The four items you have mentioned

15     will take up how much of your time?  I'm concerned about the witness.

16     This will be one of the last witnesses before the presentation of your

17     case, so I would like to finish this witness.  How much time do you need?

18             THE ACCUSED: [Interpretation] Mr. President, I did not revise my

19     own evidence in this trial, but I'll try to be concise.  I can't tell you

20     straight away whether it's going to be five or ten minutes, but in the

21     meantime, if you hadn't asked me this question, I would have dealt with

22     one problem by now.  I'll be brief.

23             I got a letter from Soraya Laucci to Mr. Ram Doraiswamy, the

24     Registrar of our Trial Chamber, where she says that the Trial Chamber

25     believes that only official transcripts can be admitted into evidence and

Page 15886

 1     that the Prosecution should review all the transcripts admitted into

 2     evidence in the Seselj trial and up-loaded into e-court, and replace all

 3     the versions of transcripts marked "Unofficial" with the official revised

 4     version.  This was a surprise to me, that revised transcripts from

 5     earlier trials were not admitted and up-loaded.

 6             And as for 98 bis evidence, I need all the submissions of the

 7     Prosecution and all decisions of the Trial Chamber which form part of the

 8     evidence.  Of course, it was disclosed to me as 65 ter, but it's a huge

 9     amount of material mixed up with a lot of useless material that I have

10     never used.  Now I need it all organised in binders in the Serbian

11     language, because I have no assistants here who can do that for me.  And

12     I believe that someone must do it for me, be it the Registry or some

13     service of the Office of the Prosecutor.  But, in any case, I need it to

14     prepare a proper 98 bis motion.

15             Second.  In the month of April, I was visited by my legal

16     assistants and the case manager.  In fact, only the legal adviser,

17     Boris Alexic, and case manager, Marina Ragus.  The Registrar again

18     prevented Zoran Krasic, my legal adviser, to visit me, and wrote to me

19     that his visit could not be privileged but would instead be supervised,

20     and that's why Mr. Krasic did not arrive.  They also failed to pay the

21     arrival -- the visit of my legal advisers, and I had to pay for all that

22     alone.  The last time they visited was in April, and God knows when

23     they're going to come back, because I can't afford their travel.

24             Third.  On the 19th of April, I received a Prosecution motion to

25     recall one witness.  Since this is confidential material, I will not

Page 15887

 1     quote anything from that material.  But the point is that after the

 2     witness completed his testimony, the Prosecution interviewed him again,

 3     and the witness gave them a new statement through which the Prosecution

 4     tried to rehabilitate themselves, having made a mess of it in the

 5     courtroom, because I demolished their witness in cross-examination and

 6     proved that the Prosecution is using inappropriate methods in

 7     interviewing witnesses and preparing 92 ter statements.

 8             Now they want to recall this witness.  I assert that it's

 9     impossible, because if you set such a precedent, then that means that the

10     Prosecution would be able to recall all their witnesses with all their

11     new statements, because so far I have demolished all their witnesses.

12     Not a single witness of theirs remains standing here in the courtroom as

13     relevant.  I have demolished all their theories and all their case.  Now,

14     if you allow them, it would mean that the Prosecution could recall all

15     the witnesses, prepare new statements using the results of my

16     cross-examination, and rehabilitate these witnesses in the courtroom.

17     No, that can't be done, and that's why I oppose this motion.

18             The fourth issue.  Several months ago, you gave me your verbal

19     decision that I have to preventively submit to you for censure --

20     censorship all the material that I want to have published.  I haven't

21     done that yet, but my books are appearing in publication, and most

22     recently my book -- my police dossier has appeared.  This is my police

23     file from the beginning of 1982 through the end of 2002, 20 years of

24     police work to collect the information about me, through informers,

25     through wire-tapping, through placing bugs in my apartment, et cetera.

Page 15888

 1     This contains a large amount of documents that the Prosecution obtained

 2     from the Government of Serbia.  I asked the Government of Serbia to give

 3     me those documents as well, but the Government of Serbia told me that I

 4     must not show it to anyone, that I can't publish it, that I must ask for

 5     their consent to use it in the courtroom, et cetera, et cetera; but how

 6     can the Government of Serbia bind me to such an undertaking?  I'm

 7     prepared to be arrested one day by the Government of Serbia.  It's their

 8     business.  I don't care.

 9             Now, after they gave all this to the Prosecution, I asked them to

10     give me the rest of my police file from the years which are not relevant

11     to the indictment.  So in a moment of weakness, they provided me with

12     that as well, possibly to sooth their conscience after delivering so many

13     Serbs to The Hague Tribunal, and I decided to publish it in its entirety.

14     What can they do about it?  I'm sitting in prison in The Hague, so I

15     can't be sitting in the prison in Belgrade at the same time.

16             But the Prosecution can relax from now on.  Whenever they give me

17     any new documents, they don't have to bother to mark it "Contact the

18     Serbian government before use in court."  That's now irrelevant.  I've

19     published it all in the Serbian language in the original.

20             Gentlemen Judges, as far as I know, it has never happened yet

21     anywhere in the world that a political opponent of the regime has

22     published his entire police file.  I am the first, and I'm proud of it.

23             Now, when you look at these four books, when you see all the

24     things that the secret police, led by Jovica Stanisic, did against me,

25     you will understand how pointless it is for the Prosecution to place me

Page 15889

 1     in a joint criminal enterprise with Jovica Simatovic and -- Jovica

 2     Stanisic and Frenki Simatovic when I was an opponent of the regime.  And

 3     even when I was a member of the government of Serbia, the secret police

 4     wire-tapped me as a terrorist who is just looking for his first chance to

 5     overthrow the government by force.  That's why this is important.  And

 6     it's important for another reason.

 7             I had understood your inclination to accept police files and

 8     police material as evidence.  In Serbia, that's impossible.  It's still

 9     impossible.  Only when the witness -- or, rather, the accused or a

10     suspect is interviewed in the presence of his lawyer, then such material

11     is admissible.  However, reports from informants cannot be admitted into

12     evidence.  You have been inclined to accept such material.  Now, if you

13     look how many horrible lies have been planted against me in the past 20

14     years, and when you grasp all the methods that the secret police had been

15     using in Yugoslavia, when you see that for the past 20 years I have been

16     on the edge between life and death, you will understand then that you

17     cannot trust a single police report.  Therefore, be kind and order the

18     Legal Officer to take these books and give them to the Trial Chamber.

19             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I shall give the

20     floor to Mr. Marcussen, who was on his feet.  What would you want to do

21     with your books?  Would you like them to be admitted?  Would you like to

22     give them to the Trial Chamber?  What status should these books have,

23     according to you?

24             THE ACCUSED: [Interpretation] Well, before Mr. Marcussen takes

25     the floor, I did not want the books to be admitted.  I'm just respecting

Page 15890

 1     your decision, and that decision has not been delivered to me in writing.

 2     I'm just informing you that the books are out of print and I am giving

 3     them to you for your inspection, and you do whatever you want to do with

 4     them.  You can keep them as a souvenir, you can sell them.  They will

 5     sell well.  They're expensive.  You can give them to somebody as a gift.

 6     I hope that you will not throw them away.  I'm not giving a set to the

 7     Prosecution because they can buy themselves a set in Belgrade.  Maybe

 8     they will charge me with the contempt of court for this, but they can go

 9     to Belgrade and buy themselves a set of my books.

10             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Marcussen.

11             MR. MARCUSSEN:  Your Honours, I was on my feet because the

12     accused was not raising an administrative matter, but promoting one of

13     his books and making substantive submissions.

14             The other thing is obviously there is no reason for the accused

15     to give the book to the Trial Chamber for inspection, because your order

16     was that it should be given before publication.  This book has been

17     published, so whatever is in the book is out there already.

18             JUDGE ANTONETTI: [Interpretation] Indeed, the Chamber has handed

19     down a decision.  I do not have the reference, but this can be found.  We

20     said that in future, when the accused would publish a new book, this book

21     would have to be submitted to the Registry in order to check whether

22     there are not anything in the book that could cause prejudice to the

23     peaceful unfolding of the hearing, the reputation of the Tribunal, or

24     that of the Judges.  It seems that those books do not meet those

25     criteria.  But I find a potential interest for yourself, but this is your

Page 15891

 1     problem, really.

 2             If, in this book, you state that you were under surveillance from

 3     policemen from Mr. Stanisic and Mr. Simatovic, and this happened over a

 4     number of years, this could be interesting when dealing with the joint

 5     criminal enterprise, because you are in a joint criminal enterprise with

 6     those other two persons, as well as others.  And perhaps in those police

 7     reports could perhaps state that you had a talk with Mr. Karadzic or with

 8     Mr. Milosevic or that you were put under wire-tapping.  I don't know.

 9     Unfortunately, I do not read your language, and therefore it would be

10     very difficult for me to look into what is being said and to understand

11     what's in the book.  But I will ask my colleagues what we are going to

12     decide regarding those four books.

13             MR. MARCUSSEN:  Well, Your Honour --

14                           [Trial Chamber confers]

15             JUDGE ANTONETTI: [Interpretation] The Chamber deliberated on

16     those issues, and they are asking the usher to go and fetch those books,

17     to give them to the Registrar, and according to our decision, the

18     Registry, with their translators, will look at the content of those books

19     and will draft a report, if necessary; namely, if the book is of any

20     interest to us.  So this is our decision.

21             Mr. Usher, could you go and fetch those four books and give them

22     to the Registrar, who is in this room.

23             Mr. Marcussen, you have the floor.

24             MR. MARCUSSEN:  Just to be sure that we understand the order,

25     what is being checked is whether or not there is any material that

Page 15892

 1     shouldn't have been disclosed; the Chamber is not minded to look at the

 2     books as evidence, since it has been tendered?  It's just a formulation

 3     of what Your Honours said.  It's to check whether or not there is

 4     disclosure of confidential information?

 5             JUDGE ANTONETTI: [Interpretation] Indeed.

 6             Two very brief comments, and then we will bring the witness into

 7     the courtroom.  But I have to also read another oral decision, which is

 8     rather long.  So first my remarks.

 9             A witness had been then heard by the Prosecutor.  I was rather

10     surprised when I saw that.  I could not, in the least, imagine that a

11     Prosecutor would have a talk with a witness, so I was rather surprised,

12     and I hope that this will not happen again.

13             Secondly, regarding the talk with Mr. Krasic, we heard that there

14     was no interview with Mr. Krasic because you had learned that he was

15     going to be wire-tapped during this interview.  And being aware of this,

16     you say that under those conditions, there is no point for him to come

17     over here.  We were aware of this, because we had been informed by the

18     Registry.

19             As for the other questions that you raised, they are of a

20     technical nature and we will handle those issues between each other.

21             I would like to ask the Registrar to move to closed session.  I

22     have a rather long oral decision to read, and then we will bring the

23     witness into the courtroom.  Please, let's move to closed session,

24     because we are dealing with a protected witness in this oral decision.

25                           [Closed session]

Page 15893











11  Pages 15893-15897 redacted. Closed session.















Page 15898

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

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

11                           [The witness entered court]

12             JUDGE ANTONETTI: [Interpretation] Witness, could you please

13     confirm that you are not asking for any protection measures and that you

14     are prepared to testify in open session?

15             THE WITNESS: [Interpretation] I can confirm that.

16             JUDGE ANTONETTI: [Interpretation] Very well.

17             Could you give us your name, surname, and date of birth.

18             THE WITNESS: [Interpretation] My name is Zoran Rankic.  I was

19     born on the 1st of August, 1955, in Bogatic, in the Republic of Serbia.

20             JUDGE ANTONETTI: [Interpretation] Very well.  What is your

21     current profession?

22             THE WITNESS: [Interpretation] Currently, I work as a foreman in a

23     construction company.  I'm a construction technician.

24             JUDGE ANTONETTI: [Interpretation] Thank you.  Witness, have you

25     already testified before a court of law on events which unfolded in the

Page 15899

 1     former Yugoslavia or is that the first time that you testify in a court?

 2             THE WITNESS: [Interpretation] I've never testified before.

 3             JUDGE ANTONETTI: [Interpretation] Could you please read the

 4     affirmation.

 5             THE WITNESS: [Interpretation] I solemnly declare that I will

 6     speak the truth, the whole truth, and nothing but the truth.

 7                           WITNESS:  ZORAN RANKIC

 8                           [The witness answered through interpreter]

 9             JUDGE ANTONETTI: [Interpretation] Thank you, Witness.  You may

10     sit down.

11             Witness, some information regarding the way this hearing will

12     unfold.

13             In the first stage, you will answer to questions put by the three

14     Judges before you.  We have decided to split those two hours into three,

15     so each and every Judge will have about 40 minutes.  Personally, I'm not

16     going to use the full 40 minutes, given the delay that we've encountered

17     this afternoon.  After that, the Prosecutor will have two hours.  The

18     Prosecutor made a motion to change the rounds; namely, that they wanted

19     for Mr. Seselj to first ask questions and then the Prosecution, but the

20     Chamber has not accepted this request, given that we have always

21     proceeded the same way; Judges questions, judges [as interpreted] from

22     the Prosecution, and questions from the accused.  But given the

23     Prosecutor has two hours, they can use 90 minutes for the questions

24     first, and then they can give the floor to Mr. Seselj, who can use two

25     hours, and then they can take the floor again for another 30 minutes.

Page 15900

 1     This being said, the Prosecution will have, all in all, two hours, not

 2     one more minute and not one minute less.  If they do not use their two

 3     hours, it's all the better, but they have two hours.

 4             THE ACCUSED: [Interpretation] Mr. President, objection.

 5             I don't accept your method.  This is something new, you've just

 6     introduced something totally new.  In that case, I'm not going to examine

 7     the witness.  If you give half an hour to the Prosecutor after my

 8     examination, I won't examine the witness.  You can give the Prosecution

 9     four hours if you want.

10             JUDGE ANTONETTI: [Interpretation] Very well.

11             Well, in that case, if you give this up, it is your choice.  But,

12     Mr. Seselj, the Chamber gives you the opportunity to take the floor again

13     after additional questions from the Prosecutor.  So the Prosecutor may

14     have 90 minutes, then you use 90 minutes, and then the Prosecutor uses 30

15     minutes for additional questions, and then you take the floor last and

16     then you have another 30 minutes.  So perhaps you did not understand what

17     we had decided upon.  You can always take the floor last.

18             Did you understand?

19             THE ACCUSED: [Interpretation] Mr. President, I understood you

20     well the first time 'round.  Maybe the interpretation was not good.  Now

21     that you've corrected yourself, or maybe the interpreter did not

22     interpret correctly the first time 'round, now I understand that I have

23     the last word and I always have the last word after the Prosecutor.

24     Maybe it was not interpreted properly the first time 'round.

25             JUDGE ANTONETTI: [Interpretation] Very well, we all agree.

Page 15901

 1             Witness, I'm going to start putting questions to you.  I devoted

 2     several hours in looking at documents, such as statements made to the

 3     Prosecutor.  The Prosecution, as well, has questions to put, Mr. Seselj,

 4     and then this allows me to look at the entirety of the picture.

 5                           Questioned by the Court:

 6             JUDGE ANTONETTI: [Interpretation] Could you perhaps tell us under

 7     which circumstances you first made statements with the Prosecution, and

 8     then in August 2008 you went to see the Defence team of Mr. Seselj to

 9     give them a statement?  Could you perhaps tell us why you were, in the

10     first stage, a Prosecution witness and then you were a Defence witness

11     for Mr. Seselj?  Could you please give us some explanation regarding

12     this?

13        A.   Your Honours, first of all, I have to start with the year 2003.

14     That's when my first statement was given to the investigators of

15     The Hague Tribunal.  And I have to finish with the year 2006, and that

16     was the time when I provided my last statement to the OTP of The Hague

17     Tribunal, and that was here in The Hague.

18             From 2003, the OTP started putting pressure on my family.  They

19     wanted me to report to the Office of The Hague Tribunal in Belgrade

20     because they wanted to take my statement.

21             I hope that I'm not talking too fast.  Am I?

22             And since they were putting a lot of pressure on my family for me

23     to report to them, and they threatened me that if I did not report to the

24     OTP, I would be brought in by the organs of the interior of the Republic

25     of Serbia, in order to protect my family from ill treatment I responded

Page 15902

 1     to their invitation.

 2             The first time, they questioned me for three days.  It was

 3     Mr. Paolo Pastore Stocchi who was the investigator in charge, and there

 4     was also Ms. Sabine Scholz who was there.  I started providing my

 5     statement according to the best of my recollection.  You know the events

 6     had happened a long time ago, and it was only logical that I couldn't

 7     remember some of the events.

 8             Mr. Paolo Pastore Stocchi was not satisfied with the statement

 9     that I provided.  He tore up the first statement that I provided, and he

10     said, Mr. Rankic, either you're going to give us a proper statement, and

11     you have to know that we have statements by other witnesses which do not

12     tally with what you're telling us.  I suppose that he thought that my

13     statement was false, that I was not telling the truth, that I was lying,

14     and the course of the interview evolved in the following way:

15     Mr. Rankic, I know that you are not a sweet-smelling flower.  We have

16     something for you.  We have statements by other witnesses to the effect

17     that you were present during some events in Bosnia and Herzegovina.  And

18     my conclusion from all of that was that if I did not co-operate with him,

19     I could suffer consequences, all of that could have repercussions on my

20     life from then on.

21             At that time, I was not sure whether the OTP of The Hague

22     Tribunal could bring charges against me for something that I really was

23     not a part of.  I personally did not feel guilty.  I don't feel guilty.

24     I personally know that I did not participate in any war crimes.  I know

25     that I never tried to cover up a war crime either.  I was perplexed, I

Page 15903

 1     was afraid.  At that time, my family situation was very bad.

 2             As a result of all that, I divorced my wife.  I did not live with

 3     my family.  I was unemployed at the time.  I started drinking as well.

 4     My health was not good at the time, and it's still not good.  I have a

 5     lot of health problems.

 6             I started giving statements.  The first one was given -- as far

 7     as I remember, the interview lasted for three days, and the interpreter

 8     read my statement back to from her laptop.  And on the end of day 3, I

 9     was given a bunch of papers to sign.  Can you imagine what my state was

10     after the three days of interrogation?  I could hardly wait to sign all

11     that, to sign the statement, and to leave the Office of The Hague

12     Tribunal.  I just wanted to go in and have some rest.  I wanted to give

13     my brain some rest from all of that.  It is very difficult to try and

14     remember things that happened 15 or 20 years ago and still be as

15     concentrated as you possibly can be.

16             My second encounter with the investigators of The Hague Tribunal

17     was at the beginning of 2004.  The investigators were a woman, whose name

18     was Rita, and I believe she was from Nepal - I can't remember her family

19     name - and there was a gentleman from Sweden whose name I believe was

20     Thomas Athans [phoen].  Ms. Rita from Nepal threatened me and told me

21     that if I did not -- if I did not co-operate with the investigators, I

22     could be delivered to Bosnia, because allegedly in Bosnia they had

23     something against me, they could put me on trial for something, although

24     I know that I knew then that that wasn't true.  At such a moment, nobody

25     would be indifferent.

Page 15904

 1             I know that heaps of Serbs have been sentenced here to long-term

 2     imprisonment, so I was forced to start giving untruthful statements in

 3     order to save my hide.

 4             And it then ended, and then in 2006 I was again invited to the

 5     Office of The Hague Tribunal in Belgrade.  I had a conversation there

 6     with Mr. Daniel Sax [as interpreted], who was a Prosecutor at the time,

 7     and he told me on that occasion that all of my cases had gone missing at

 8     the airport in Belgrade and that there is an imminent danger that I would

 9     be assassinated; that it would be good if I came to The Hague to give all

10     my statements again and to supplement some of the things that I had said

11     before.  I wasn't very clear on the origin of that imminent danger

12     because of that -- because of that -- before that I was not endangered by

13     anybody, and especially not by the Serbian Radical Party, where I still

14     have friends today.  I had them at that time, I still have them, although

15     I'm not a member of the Serb Radical Party.  I haven't been a member

16     since 1993.  I just want to say that nobody ever threatened me or nobody

17     ever intimidated me.

18             I arrived here in the Hague with an explanation that I would

19     spend a few days here.  However, that dragged on and lasted nearly two

20     months.  In the meantime, Mr. Seselj's trial was about to start.  He was

21     dissatisfied with some of our decisions, he went on a hunger strike, and

22     that's why the beginning of trial was postponed.  They probably planned

23     for me to be the first Prosecution witness, since I was already in

24     The Hague.

25             Since all that did not materialise, and I realised that nothing

Page 15905

 1     would come out of that, later on they tried to promise me that I would be

 2     relocated to a third country, that I would be financially provided for,

 3     to be safe.  I don't know who should I have been safe from, because

 4     nobody ever threatened me.  I am not easily scared, I am not easily

 5     intimidated by anybody.  I was deceived, and I left The Hague.  Actually,

 6     I was the one who tricked them, and I left The Hague.  I could no longer

 7     sit here.  They didn't send me to any third country, as they had promised

 8     they would.  I returned to Belgrade.  And a few days later, although I

 9     was not in my house, the Serb police was looking for me at my -- at the

10     address where my residence is, but I don't reside there.

11             After that, I didn't know what to do.  I called the Serbian

12     Radical Party, and a gentleman by the name of --

13             JUDGE ANTONETTI: [Interpretation] I'm going to interrupt you

14     here.  You have described to us everything that happened with the OTP.  I

15     shall get back to a point of detail a little later.

16             Now, please explain to me how things happened with Mr. Seselj's

17     Defence.  Did members of Seselj's Defence team contact you or did you

18     contact them?  Can you give us some details, please?

19        A.   I understood your question, and I have just started to explain

20     all that.

21             I called the Serbian Radical Party, and the gentleman replied.

22             JUDGE ANTONETTI: [Interpretation] What are you saying is

23     important.  You are testifying under oath.  Each and every word is

24     important.

25             When you say, I am the person who phoned up the Serbian Radical

Page 15906

 1     Party, you know that, through technical means, we are able to know

 2     whether you did, in effect, call or not the Serbian Radical Party.  We

 3     can check whether you phoned that number, and we professional Judges can

 4     check all that out.  I hope you have understood me.

 5        A.   Yes, and I say, with full responsibility, and I know that I'm

 6     here to testify under oath, I respect this Tribunal, I consider this

 7     Chamber a professional Chamber.  That's why I'm here to tell the truth

 8     and the whole truth.

 9             I was the one who called the Serbian Radical Party, and a

10     gentleman replied.  His name was Dragan Tasic.  I told them that I could

11     no longer be in touch with the OTP, that I didn't want to be in touch

12     with them.  And I said that if the Trial Chamber summoned me, I would

13     respond to those summons, but I would never respond to the summons of the

14     OTP.  And then he told me to draft a statement and to send it to them.

15             I drafted a statement.  I personally drafted a statement.

16     Nobody --

17             JUDGE ANTONETTI: [Interpretation] Could you tell me on what date

18     this was, if you remember?

19        A.   I believe that that was in 1997.

20             JUDGE ANTONETTI: [Interpretation] I'm putting the question to you

21     because I have a statement that is dated the 12th of August, 2008.  Did

22     you make a statement prior to that?

23        A.   I got mixed up on the year.  My first statement, as far as I can

24     remember, was provided in 2007, in the month of August 2007.

25             JUDGE ANTONETTI: [Interpretation] Did you draft the statement,

Page 15907

 1     did you type it up, or was it Mr. Dragan Tasic who typed it up on his

 2     computer?

 3        A.   No, I drafted the statement, and my son typed it up on a

 4     computer.

 5             JUDGE ANTONETTI: [Interpretation] So it's your son who typed it

 6     up on the computer.  What happened after that?

 7        A.   Yes.  I certified that statement at court, and I handed it over

 8     to Mr. Seselj's Defence team.

 9             JUDGE ANTONETTI: [Interpretation] I have two questions of a

10     technical nature to put to you.

11             You have explained to us how things took place with the OTP and

12     with Mr. Seselj's Defence team.  Now, this is my first question of a

13     technical nature, which is a fairly straightforward question which I'm

14     sure you'll be able to answer.

15             I read, in the judgement concerning Colonel Mrkic and

16     Captain Sljivancanin, that the volunteers from the Serbian Radical Party

17     were part of a unit called the White Eagles.  I was a little bit

18     surprised on reading this, and I checked to see whether there was a

19     footnote.  There is no footnote.  I therefore wonder where this comes

20     from, i.e., the fact that the volunteers were called White Eagles.  Since

21     you met volunteers, since you were, yourself, as it appears, a volunteer,

22     can you explain to us whether the White Eagles were volunteers of the

23     Serbian Radical Party?

24        A.   This is absolutely incorrect.  The volunteers of the Serbian

25     Radical Party in Vukovar belonged to a unit called Leva Supoderica, which

Page 15908

 1     belonged to the Territorial Defence of Vukovar.  And, as such, it was

 2     under the operative command of the Guards Brigade under the command of

 3     Mr. Sljivancanin.

 4             JUDGE ANTONETTI: [Interpretation] This is now my second question

 5     of a technical nature.  I have very few questions for you.  My colleagues

 6     will put the bulk of the question to you.

 7             I have noted, in the statement you challenge, which you gave to

 8     the OTP on the 19th of September, 2006, in paragraph 54 - you don't have

 9     the statement before you, but you don't need to look at it - at some

10     point you talk about the Milosevic regime, and you say that the Milosevic

11     regime was against the Chetniks.  You say that Milosevic's regime was in

12     favour of Communism, that it was competing with nationalist parties like

13     the Serbian Radical Party, and you say that the co-operation between the

14     Milosevic regime and Mr. Seselj deteriorated because of the JNA.  Did you

15     tell this to the OTP?  Is this right, is this not right?  What can you

16     say about that today?

17        A.   I said something to that effect.  It is true that Milosevic's

18     regime, in principle, was against the Chetnik movement.  Mr. Milosevic's

19     party was the Socialist Party of Serbia, which originated directly from

20     the League of Communists of Serbia.  As everybody knows, Communists and

21     Serbian Chetniks were never in an amicable relation.

22             I apologise.  Do you have any other questions?  Actually, your

23     question was long and I don't remember all of it.

24             JUDGE ANTONETTI: [Interpretation] What I'm interested in is this:

25     I'm putting the question to you for the following reason.  According to

Page 15909

 1     the Prosecutor, Mr. Seselj is a member of a joint criminal enterprise,

 2     together with Mr. Milosevic, together with Mr. Karadzic, who is being

 3     tried by this Tribunal, together with Simatovic and a number of others.

 4     As it seems you were familiar with the way the Serbian Radical Party

 5     operated, you were partly aware of this, I would like you to give us your

 6     opinion on the relations between Mr. Seselj and Mr. Milosevic and his

 7     regime, if there was such a thing as Milosevic's regime.  What were the

 8     relations between Mr. Milosevic and Mr. Seselj?

 9        A.   Mr. Milosevic and Mr. Seselj were political opponents at first.

10     On the most important points, such as why we sent off volunteers, I

11     believe that's the most important thing to explain.  We, as a nationalist

12     party, felt it was our obligation to protect the Serbian population

13     outside the territories of the then Republic of Serbia.  There was no

14     open co-operation with the regime of Slobodan Milosevic, but it would

15     have been illogical to expect that in the middle of a war there would be

16     an armed conflict between the Serb Radical Party and the then Socialist

17     Party of Serbia, led by the president, Slobodan Milosevic.

18             The Serbian Radical Party had its own priorities; first and

19     foremost among them, to protect the Serbian population outside Serbia.

20     Later on, in peacetime, of course, we would have fought for power, and in

21     that struggle we would be against Slobodan Milosevic.

22             JUDGE ANTONETTI: [Interpretation] My last question.  I read about

23     your political career, which you described to the OTP, with great

24     interest.  You were pressured; maybe you were, maybe you weren't.  From

25     what I understood, and if I make a mistake, please let me know, but you,

Page 15910

 1     yourself, were an anti-Communist, and in Germany in 1987 in Offenbach,

 2     you joined the Ravna Gora organisation, and after that, when you were in

 3     Serbia, the joined the SAVA association, and it is only after that time

 4     that you joined the Serbian Radical Party.  What I would like you to

 5     confirm is this:  Before belonging to the Serbian Radical Party, was your

 6     political path totally different from that of Mr. Seselj's?

 7        A.   I would like to make one correction.  I was not a member of the

 8     Serb Radical Party.  I was a member of the Serbian Chetnik Movement, and

 9     I was involved in the creation of the Serbian Chetnik Movement together

10     with Mr. Seselj.  In fact, I was one of the first founders of that

11     movement.  The Serbian Chetnik Movement was later merged with another

12     party to create the Serb Radical Party, but that was towards the end of

13     February 1991.  All the rest that you said is correct.  I was part of the

14     Chetnik emigration movement.  I was a member of Ravna Gora in Offenbach.

15     Then after returning to Serbia, I was in prison for a while in a prison

16     in Belgrade.

17             JUDGE ANTONETTI: [Interpretation] There is a mistake, perhaps, in

18     your statement of the 19th of January, 2004.  In paragraph 11, you listed

19     the Serbian Radical Party:  President Mr. Seselj, Deputy President

20     Djordjevic, Petkovic, Stefanovic, Goskovic [phoen], Viletic [phoen].  And

21     then list of members:  Zoran Drizilovic [phoen], aka Zika, and after that

22     there is your name, Zoran Rankic, and after that there is Jovan --

23             THE ACCUSED: [Interpretation] Correction.  Mr. President, it is

24     clearly stated in paragraph 11 that it was the Serbian Chetnik Movement,

25     not the Serbian Radical Party.

Page 15911

 1             JUDGE ANTONETTI: [Interpretation] This is, therefore, a list that

 2     concerns the Serbian Chetnik Movement, which means that you have never

 3     been a member of the Serbian Radical Party; in other words, you have

 4     never had your membership card of the Serbian Radical Party?

 5        A.   [Previous translation continues]... officially a member of the

 6     Serbian Radical Party, that's correct.

 7             JUDGE ANTONETTI: [Interpretation] Since you have never been a

 8     member of the Serbian Radical Party, how is it, then, that according to

 9     the statements you gave to the OTP, that you were present in the offices

10     of the War Staff, headed by Petkovic?  How was it that you were there?

11        A.   I would have to explain that.

12             Towards the end of February 1991, the Serbian Chetnik Movement

13     merged with a spin-off wing of the Serbian Radical Party, and there was a

14     conference in Kragujevac, if I remember correctly, where the Serbian

15     Radical Party was established.  A central homeland administration was

16     created, and members of this popular radical party that merged with the

17     Serbian Chetnik Movement were in that central homeland administration.

18     They were represented proportionally, and I was part of that.

19             JUDGE ANTONETTI: [Interpretation] I understand things better now.

20             THE ACCUSED: [Interpretation] I can be of assistance with my

21     remarks.

22             When the creation --

23             MS. BIERSAY:  Objection, Your Honour.

24             THE ACCUSED: [Interpretation] When the creation --

25             MS. BIERSAY:  Mr. Seselj should use his time for

Page 15912

 1     cross-examination.

 2             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, yes, of course.

 3     But Mr. Seselj is trying to help the Judges, and when someone is trying

 4     to help me, I never turn down any help.  But maybe you can also help me,

 5     Ms. Biersay.

 6             MS. BIERSAY:  I appreciate that, Your Honour, and I'd be happy to

 7     help the Court.  But what Mr. Seselj is doing is testifying, in terms of

 8     what he thinks the reality is, and he's giving you his representation

 9     about the issue that the Court has asked.

10             JUDGE ANTONETTI: [Interpretation] Now, if we do not consider what

11     Mr. Seselj has said, if at no point in time you were a member of the

12     Serbian Radical Party, nonetheless, you are telling us that you were

13     affiliated to the Serbian Chetnik Movement, and this is why, at some

14     point in time, you were part of a much broader movement at the same time

15     as Mr. Seselj?

16        A.   That's what I was trying to explain.  I did not need to get a new

17     membership card, because two parties merged, the Serbian Chetnik Movement

18     and the Popular Radical Party, and the Serb Radical Party was formed with

19     that name.  However, the membership cards remained bearing the name of

20     the Serbian Chetnik Movement.  I did not need to have my membership card

21     replaced.

22             JUDGE ANTONETTI: [Interpretation] I have already spent enough

23     time on my questions, and I shall give the floor to my colleagues, who

24     have a lot of questions for you.  I don't know who will start.  Courtesy

25     would have it that it is Ms. Lattanzi.

Page 15913

 1             JUDGE LATTANZI: [Interpretation] But it will be Judge Harhoff.

 2             JUDGE HARHOFF:  Mr. Rankic, in extension of what the Presiding

 3     Judge has already told you, I think it would be pertinent to just add a

 4     few extra details.

 5             First of all, Mr. Rankic, you have been called here to testify

 6     today and tomorrow by the Chamber.  This means that you are not a witness

 7     of the Prosecution, nor are you a witness for the accused.  We have

 8     called you as our witness because we wanted to avoid any possible

 9     misunderstanding as to whose interests you may have thought that you were

10     here to defend.

11             You are here, sir, to tell the truth, and you have made the

12     solemn declaration.  And I wish to remind you that there is a severe

13     penalty for providing false or incomplete evidence to this Tribunal.  Is

14     that clear?

15        A.   Perfectly clear.

16             JUDGE HARHOFF:  Secondly, I would like to just inform you that

17     for technical reasons, we have to have a break every 90 minutes because

18     the tapes from the recordings of these proceedings have to be changed.

19     And if you look at the clock, you'll see that this is in four and a half

20     minutes.  So this means that we will take a 20-minute break in four and a

21     half minutes, and then we will resume and go on for another 90 minutes,

22     and then have another break, and then we will adjourn at 7.00.  That will

23     be it for today, and then we will proceed tomorrow, as the Presiding

24     Judge has instructed you.

25             Mr. President, I don't know if it would make sense, actually, to

Page 15914

 1     take the break now and then I will proceed with my questions.

 2             JUDGE ANTONETTI: [Interpretation] Let's have the break now.

 3             Witness, I was told that you sometimes suffered from backache.

 4     If it is too trying for you, please let us know so that you can have a

 5     rest and relax, if you need to.  Make the most of the 20-minute break.

 6             We shall resume in 20 minutes' time.

 7                           --- Recess taken at 3.44 p.m.

 8                           --- On resuming at 4.06 p.m.

 9             JUDGE ANTONETTI: [Interpretation] The court is back in session.

10             JUDGE HARHOFF:  Thank you.

11             Mr. Rankic, before we begin my examination, I would like to

12     clarify one further thing with you, and that is the fact that you are

13     not under suspicion.  You are not being accused.  There are no

14     allegations to be made towards you.  You are here only as a witness, and

15     nothing that you are saying today in your testimony here in this court

16     can be used by this Court against you, unless, of course, you testify

17     falsely or incompletely.  So I just want to make sure that you are not

18     the accused here, you are a witness, and you're supposed to tell the

19     truth.

20             Now, Mr. Rankic, what I want to elicit from you is your account

21     of the process of recruiting volunteers through the SRS in 1991 and 1992.

22     You were a member of the leadership of the party of the SCP, of the

23     Chetnik Movement, and you were close to the proceedings and the

24     procedures that applied to the process of recruiting volunteers, so I'd

25     like you to account to us, as briefly as you can, the process of how a

Page 15915

 1     young man in, say, Bosnia, or even in Serbia, could become an SRS

 2     volunteer.  What -- how does the career as an SRS volunteer begin?  Can

 3     you tell us that?

 4        A.   Your Honours, first of all, I have to clear up one thing.  I'm

 5     qualified to speak about events until the end of 1991, the moment when I

 6     resigned to the post of deputy chief of the working headquarters of the

 7     SRS -- or, rather, the Serbian Chetnik Movement.  From that time on, I

 8     had no obligations towards the War Staff of the Serbian Radical Party,

 9     but I can explain what happened in the course of 1991.

10             The establishment of the Crisis Staff in the spring of 1991 --

11             JUDGE HARHOFF:  Thanks, Mr. Rankic.  I'm perfectly aware of the

12     time in which you were a member of the party, but I believe that you are

13     still able to provide us with your evidence even in 1992.  So my

14     questions to you are not limited to what you experienced as a member of

15     the leadership of the SRS or SCP party.  It's your personal account that

16     I am interested in.

17             Please proceed.

18        A.   I agree, but this version for 1991 is an official version.  After

19     that time, it's my individual version.

20             Beginning with the establishment of the Crisis Staff in the

21     spring of 1991 and the arrival of large numbers of refugees from the

22     territory of Croatia, the first tasks of the Crisis Staff were to find

23     accommodation for the refugees and to assist -- when I say "assist," I

24     don't mean financial assistance, because we couldn't afford that, but aid

25     in food, medicines, et cetera.

Page 15916

 1             After sporadic incidents in the territory of Croatia, the armed

 2     conflict expanded, and the Crisis Staff of the Serbian Radical Party

 3     started receiving requests from crisis staffs in Croatia to give them

 4     help in manpower.  At our sessions of the Crisis Staff, we decided it

 5     would be possible and feasible to send volunteers to Croatia, of course,

 6     once we were satisfied that these volunteers were absolutely

 7     indispensable there.

 8             JUDGE HARHOFF:  Thanks.  Why would crisis staffs in Croatia call

 9     the SRS Crisis Staff in Belgrade for manpower?  Did you advertise the

10     ability to organise the sending of volunteers?

11        A.   No, that's not what it was.  In actual fact, in the beginning of

12     1991 the only legal army at the time, the JNA, took a neutral position.

13     They were more a buffer between enemy forces than fighting on any side in

14     areas, of course, where the JNA was present.  Where the JNA was not

15     present, the conflict was open.  We had declared ourselves as a

16     nationalist party.  There were other parties in Serbia, of course, but

17     not with the same orientation.  It was quite logical for them to address

18     themselves to us as a nationalist party, because that was our standing.

19             Can I continue?

20             JUDGE HARHOFF:  Yes, but tell me one thing.  The crisis staffs

21     that asked you for assistance, whose crisis staffs were they?  Were they

22     the municipal crisis staffs in the various municipalities in Croatia or

23     were they the SRS crisis staffs?  In which organisational context did

24     these crisis staffs operate?

25        A.   It was the crisis staffs of the Territorial Defence in areas of

Page 15917

 1     what was then the Republic of Croatia.

 2             JUDGE HARHOFF:  Thanks.  Please proceed.

 3        A.   So we would receive fax messages in the office of the

 4     Crisis Staff of the Serbian Radical Party.  And considering that we had

 5     an intensive co-operation with the Association of Serbs in Croatia, then

 6     headed by the retired general, Mr. Pekic, we wanted to know his opinion

 7     as well, because he was more familiar with the situation in Croatia than

 8     us.  If he told us that in a given area there was real need for manpower,

 9     then we would convene the municipal boards of the Serbian Radical Party

10     or the Serbian Chetnik Movement - these didn't matter anymore because we

11     acted in a united way - and ask them to make lists of volunteers who were

12     prepared to go to Croatia, to areas where the Serb population was in

13     danger, to defend them.  The JNA at the time was not very active, and the

14     response to JNA mobilisation call-ups was very poor because certain

15     parties, which were not of nationalist orientation, but of a different

16     orientation, and we personally saw them as traitor parties, worked to

17     reduce the response to JNA mobilisation call-ups.

18             If you need a more extensive explanation, I can provide it.

19             JUDGE HARHOFF:  We may get back to this.  But can I just ask you

20     about this retired general, Mr. Pekic.  Was he considered to be a

21     nationalist also?

22        A.   In principle, yes, although he used to be a Communist general,

23     but probably later, when these things started happening in Croatia, he

24     changed his views.

25             JUDGE HARHOFF:  Right.  So while the JNA was unable or unwilling

Page 15918

 1     to provide any real assistance to the Serbian nationalist side, we had

 2     this retired general who was on the scene in Croatia and was able to

 3     determine the areas where manpower assistance was needed.  Was it then

 4     him who facilitated, through the crisis staffs of the TOs in Croatia, the

 5     requests that were made to the party in Belgrade?

 6        A.   Yes, he was the president of the Association of Serbs in Croatia

 7     and outside Croatia, in Serbia.

 8             JUDGE HARHOFF:  Very well.  So then you took contact with the

 9     TOs, if I understood you correctly, and made an assessment of how many

10     men were needed to go to Croatia; is that correct?

11        A.   Correct.

12             JUDGE HARHOFF:  And then, if I understood you correctly, you

13     mobilised these men through the local branches of the SRS party in

14     Croatia, where such branches existed.  Did I understand that correctly?

15        A.   No, not in Croatia.  In Serbia.

16             JUDGE HARHOFF:  Very well.  Thanks for this clarification.  So

17     through the SRS branches in Serbia, you got in contact with young men who

18     were willing to go to Croatia to fight on the Serbian side.  That's very

19     well.  Now, these --

20        A.   Correct.

21             JUDGE HARHOFF:  These young men, where did they report to?  Did

22     they go to their local branch or did they have to show up in Belgrade, at

23     your office, for the purpose of recruitment?

24        A.   They would report to the local headquarters or branches of the

25     Serbian Chetnik Movement and the Serbian Radical Party.  These branches

Page 15919

 1     would make a list, and then they would come to Belgrade, where the

 2     central headquarters were, where the Crisis Staff was.  And then they

 3     would be escorted and transported to areas where they were needed.

 4             JUDGE HARHOFF:  We'll get to that in just a minute.  My question

 5     is:  Apart from the young men who reported directly to the SRS branches

 6     in the various municipalities, did young men also spontaneously address

 7     themselves to the municipal authorities, to the TOs, or to the crisis

 8     staffs in Serbia in order to sign up as volunteers?

 9        A.   I'm sorry, I didn't really understand that question.  Could you

10     repeat?

11             JUDGE HARHOFF:  I would, and forgive me for perhaps putting the

12     question a bit unclear to you.

13             I'm asking because I read somewhere, in some of your statements,

14     that young men were also referred to the SRS party in Belgrade by the

15     municipal authorities, meaning that it wasn't only through the SRS

16     branches that the young men were guided to go to your office in Belgrade,

17     it was also through the municipal authorities, the TOs and perhaps the

18     crisis staffs.  So I just wanted to clarify if the municipal authorities

19     would also and could also advise young men to report to the SRS main

20     office in Belgrade.

21        A.   That must be a mistake.  I was talking about the municipal boards

22     of the Serbian Radical Party.  Everyone else who wanted to sign up went

23     through military authorities.  There was a military department in every

24     municipality, and everyone could sign up into the JNA through those

25     military departments.  I hope you understand now.

Page 15920

 1             JUDGE HARHOFF:  I do, and I was obviously mistaken.  So it was

 2     exclusively through the SRS's own party machinery that the recruitments

 3     took place?  The municipal authorities did not assist in this; is that

 4     correct?

 5        A.   That's right.  Every municipality, as I said, had a military

 6     department for those who wanted to sign up into the JNA.

 7             JUDGE HARHOFF:  Very well.  At one point, the young men started

 8     showing up in Belgrade, and they wanted to volunteer.  What did you do

 9     with them at that point?

10        A.   From that moment on, a central list had to be made, and they all

11     had to have their military service books on them, because one of the

12     conditions to go into the field was to have completed compulsory military

13     service.  We tried to make sure not to send alcoholics or criminals.  Of

14     course, if we were able to check their files, but our ability to do that

15     was limited.  If somebody had a mental health problem, that would

16     normally be written in their military service book.  Then we would bus

17     them to a destination.  And once there, we would turn them over to the

18     headquarters of the Territorial Defence, on whose orders they were sent,

19     and then the TO would take charge of their accommodation, food for them,

20     and providing weapons.

21             JUDGE HARHOFF:  I understand.  So first there was a screening of

22     the volunteers, where you looked through their military booklets and

23     where you were able to take out those who had indications of alcoholism

24     or other mental reasons.  Did you train them, and how was that organised,

25     and where did you train them?

Page 15921

 1        A.   At the very beginning, in the early days before we started

 2     joining directly the JNA, we had a centre for training volunteers in

 3     Prigrevica.  I don't know if it can really be called a training centre

 4     because it was a very accelerated course.

 5             JUDGE HARHOFF:  How long did it last, and who were the teachers,

 6     and what was the curriculum during this training?  What did they learn?

 7        A.   That centre was set up with the assistance of General Pekic.  He

 8     had brought two instructors who said they had been members of the elite

 9     63rd Parachute Brigade.  The courses were short, around 15 days.  During

10     the course, the men would be acquainted with certain types of weapons,

11     certain types of combat, and a combination of tactical and fitness

12     training.

13             JUDGE HARHOFF:  The instructors that General Pekic used, were

14     they soldiers?

15        A.   They introduced themselves as members of the

16     63rd Parachute Brigade, which is an elite unit.

17             JUDGE HARHOFF:  And did General Pekic, himself, take part in the

18     training?

19        A.   No, he did not, but he did send them.  At least that's what they

20     told me.

21             JUDGE HARHOFF:  And how many volunteers were trained at the same

22     time, roughly, if you can remember?

23        A.   They were in groups of 20, 30, 40 men.

24             JUDGE HARHOFF:  Right.  So groups of 20 to 40 young men were sent

25     on a two weeks' training course with two professional soldiers from the

Page 15922

 1     elite unit that you mentioned.  After that -- that's correct; right?

 2        A.   Correct.

 3             JUDGE HARHOFF:  And so after that, they were ready for

 4     deployment?

 5        A.   Correct.

 6             JUDGE HARHOFF:  Now, how was the process in deciding which places

 7     they would be sent to, and how many would go to each place?  How was that

 8     decision made?  Was that exclusively made in the Crisis Staff of the SRS

 9     party, where you sat, or did you involve Pekic or others in the decision,

10     or eventually were the -- the local TOs in Croatia, were they also heard

11     on the matter?

12        A.   Your Honour, based on the local Territorial Defence requests in

13     Croatia, we sent a certain number of volunteers to each of those places.

14             JUDGE HARHOFF:  And who decided the number of volunteers to be

15     sent to each place?

16        A.   It was part of their request.  They specified how many

17     volunteers, approximately, they would need.

18             JUDGE HARHOFF:  But the decision to select each individual

19     volunteer to go to this place or to that place, that was the decision

20     that was taken in the SRS War Staff, is that correct, that is to say, by

21     you and your fellow members?

22        A.   It depended on priorities.  The priority was the kind of

23     situation where volunteers were sent.  If the crisis had escalated, where

24     there were hotbeds of crisis, we considered those places a priority, and

25     that's where we sent more volunteers.

Page 15923

 1             JUDGE HARHOFF:  I understand that.  I just want to make sure that

 2     I understand fully that the selection of each individual volunteer was

 3     your selection.  Nobody else was involved in that?  I'm talking about the

 4     Crisis Staff of the SRS party at the time.

 5        A.   Correct.

 6             JUDGE HARHOFF:  Well, so now we have selected some young

 7     volunteers that are going to one place and another number of young

 8     volunteers are going to another place in Croatia in 1991.  Then you told

 9     me that they were transported by bus up to the various places, and there

10     they were handed over to the TOs.  How did the transportation take place,

11     how was that done?

12        A.   Buses would come to Prigrevica.  That's where the volunteers got

13     on the buses.  They would go to Croatia, accompanied by lists.  They

14     would be handed over to the Territorial Defence.  The Territorial Defence

15     members would sign the list confirming their receipt.  They would keep a

16     copy of the signed list, and one was sent back to me, and I would then

17     hand it over to the staff of the Crisis Staff.

18             JUDGE HARHOFF:  Right.  Whose buses were they?  Who paid for the

19     buses or who organised the buses?

20        A.   The buses were organised by the Association of Serbs who had been

21     residents of Croatia but now resided in Serbia, and that was at the

22     beginning.  And later on, it was the JNA.

23             JUDGE HARHOFF:  So you say that at some point the buses were

24     organised by the JNA to transport the SRS volunteers to the field; is

25     that it?

Page 15924

 1        A.   Correct, after the 1st October 1991, and after the immediate

 2     threat of war was proclaimed.

 3             JUDGE HARHOFF:  I just want to clarify --

 4                           [French interpretation on English channel]

 5             JUDGE HARHOFF:  -- one little detail.  I read somewhere in your

 6     statement, and to be honest, I can't remember where, that Mr. Petkovic

 7     was in close contact with, I think, the Ministry for Relations with

 8     Serbians Outside Serbia or something, in organising this transport.  Can

 9     you confirm this, or was that misunderstood?

10        A.   There is an error there, or perhaps somebody did not interpret my

11     words properly on purpose.

12             Mr. Petkovic and myself on one occasion went to the Ministry for

13     Relations with Serbians Outside Serbia, which was the ministry of the

14     Government of the Republic of Serbia, and Minister Petkovic said that he

15     was supposed to have a private conversation with Mr. Cvijan.  I was with

16     him in the ministry, but I was sitting in front of the office while they

17     were in the office talking for some 10 minutes.  I don't know what they

18     were talking about.  He told me that the conversation would be private.

19             JUDGE HARHOFF:  Sure.  I'm not in any way interested in breaking

20     into the confidentiality.  My only interest was to find out whether in

21     any way the ministry was providing assistance to the transportation of

22     volunteers to the combat zones.

23        A.   As far as I know, that was not the case.

24             JUDGE HARHOFF:  Then you arrive to the local TO where you were

25     supposed to hand over the detainees.  Did you travel with the volunteers?

Page 15925

 1        A.   Yes, in most cases.

 2             THE ACCUSED: [Interpretation] Objection.  The interpreter

 3     interpreted the word "detainees."  I suppose you referred to volunteers,

 4     whereas the interpreter interpreted your words as if you had said

 5     "detainees."

 6             JUDGE HARHOFF:  Thank you, Mr. Seselj.  No, I think -- I think,

 7     actually, it was my mistake.  I meant to say "the volunteers."

 8             THE ACCUSED: [Interpretation] No.  No, Mr. Harhoff.  I'm looking

 9     at the transcript in English, and your words were correct.  You said

10     "volunteers," and the interpreter says "detainees" on purpose.  You have

11     to intervene immediately.  You have to replace the interpreters.  This is

12     not the first time that they are misinterpreting on purpose.  You've been

13     saying "volunteers" all the time.  Why would they interpret your words as

14     if you had said "detainees"?

15             JUDGE HARHOFF:  Mr. Seselj, I have full confidence in the

16     interpreters, and I'm sure that there's no intention to change the

17     substance of what I'm saying.  I thought -- it struck me that I thought I

18     was the one who actually used the word "detainees," and I realised, as

19     soon as I said it, that it was wrong.  I meant to say "volunteers," of

20     course.

21             MR. MARCUSSEN:  And you did, Your Honour.  At page 45, line 21,

22     the transcript actually says "hand over the detainees" in your question,

23     so the accused is not correctly representing what is in the English

24     transcript.

25             JUDGE HARHOFF:  In any case, let's move on.  This is not

Page 15926

 1     material.

 2             My question to you, Mr. Rankic, was whether you escorted your

 3     volunteers to the takers, so to say, the institutions who would receive

 4     them, and I can't remember your answer.

 5        A.   I said that in most cases, I did.

 6             JUDGE HARHOFF:  And what was, then, the procedure when you stood

 7     face to face with the local TO commander, with 20 volunteers behind you?

 8     How did the exchange proceed?

 9        A.   I handed over the list with volunteers, and then he would sign

10     confirming that they had arrived.  There were two copies of that list.

11     He would keep one copy for himself, and the other copy I returned to the

12     Crisis Staff of the Serbian Radical Party.  In the meantime, while I was

13     there, they were duty-bound to show me that those volunteers would be

14     billeted, that they would receive weapons and uniforms.

15             JUDGE HARHOFF:  So the volunteers came in their civilian clothes

16     to the TO in Croatia, and there they were given uniforms and weapons; is

17     that correct?

18        A.   Correct.

19             JUDGE HARHOFF:  What sort of uniforms were they given; do you

20     remember?

21        A.   At first, those were classical olive-drab JNA uniforms, and later

22     on there were also camouflage uniforms.

23             JUDGE HARHOFF:  And the weapons?

24        A.   It was a standard-issue type of weapons that existed in the JNA,

25     infantry weapons.

Page 15927

 1             JUDGE HARHOFF:  The automatic rifles?

 2        A.   M-48 to M-56 rifles.  There were also M-57s and automatic rifles,

 3     M-70.  But that was all later.  At first, we would be issued with

 4     obsolete weapons, such as Thompson and Spagins, those kind of weapons

 5     that the JNA had written off and kept in reserve.

 6             JUDGE HARHOFF:  The weapons which the volunteers were given, were

 7     they the same as -- the same kind of weapons as the weapons used in the

 8     two weeks' training prior to the deployment?  In other words, were the

 9     volunteers familiar with the weapons that they were issued by the TOs?

10        A.   Yes, yes, at the beginning.

11             JUDGE HARHOFF:  Right.  So you gave him the lists of, assuming it

12     was a man, of the volunteers, and you handed over the volunteers to the

13     TO, and the TO would then provide them with uniforms and weapons and

14     accommodation.  Did you --

15        A.   And food, yes, as well, yes.

16             JUDGE HARHOFF:  Right.  Did you ever receive any confirmation

17     that now the TO had taken over the command of these people?

18        A.   At the moment they stamped the list, they confirmed that they had

19     taken over the volunteers.  The list was stamped, and it was signed by

20     the commander of the TO, and that was my confirmation.

21             JUDGE HARHOFF:  And you then brought the stamped and signed list

22     back to the head office in Belgrade; is that correct?

23        A.   Correct.

24             JUDGE HARHOFF:  Were the volunteers paid for their service?

25        A.   As far as I know, at first not a single volunteer received any

Page 15928

 1     money for anything.  Later on, when we fell under the JNA, they enjoyed

 2     some privileges, like any other mobilised recruit, anybody who was

 3     forcibly mobilised.  Before the 1st of October, 1991, nobody received

 4     anything.

 5             JUDGE HARHOFF:  Do you know if the volunteers had to sign a

 6     receipt for the weapons that they were given at the TOs?

 7        A.   As far as I know.  And people showed me some papers, some

 8     documents proving that they had been issued with weapons, and I'm saying

 9     that in respect of the volunteers who had come back from their field

10     missions.

11             JUDGE HARHOFF:  And that leads me to the next question; namely,

12     were the volunteers asked to give back the weapon before they left the

13     place?

14        A.   Between Serbia and Croatia, there was border -- state border

15     police, and nobody could cross the border to Serbia carrying a

16     long-barrelled rifle, unless, of course, they smuggled them.

17             JUDGE HARHOFF:  Did that happen; do you know?

18        A.   Well, it probably happened.  I suppose it did.  I don't know, but

19     I am inclined to think that it did.

20             JUDGE HARHOFF:  Other than the volunteers who were either killed

21     or wounded, did any of them remain in the areas of combat after they had

22     completed their first task or did they all return to Belgrade?

23        A.   You said "detainees," or I'm receiving a misinterpretation.

24             JUDGE HARHOFF:  I guess I may have made the same mistake again.

25     I apologise for this.  We've been sitting in another trial this morning,

Page 15929

 1     where all the talk was about detainees, so maybe this word is just

 2     circling in my head.  But I meant --

 3             THE ACCUSED: [Interpretation] Objection.

 4             JUDGE HARHOFF:  Mr. Seselj, please let me finish.  I meant to say

 5     "volunteers," of course.

 6             THE ACCUSED: [Interpretation] Objection, Mr. Harhoff.  Again, I'm

 7     looking at the English transcript, and I don't see the word "detainees"

 8     anywhere.  I'm inviting Mr. Marcussen to find it.  A little while ago, he

 9     pretended that he had found it, when it was already long gone from the

10     screen.  There is no word "detainees" anywhere.

11             JUDGE HARHOFF:  Drop it.  You can take it up later on.  Let me

12     proceed with my examination.

13             My question to you, Mr. Rankic, was whether all the volunteers

14     returned to Centar, so to say, or whether some of them stayed and

15     continued on their own.

16        A.   It all depended on the needs on the ground.  Some volunteers

17     joined the police force on the ground and some returned.  It all depended

18     on the situation as it was in a particular area.

19             JUDGE HARHOFF:  Did you maintain any sort of contact with your

20     volunteers while they were in combat under the command of the TO?

21        A.   Yes.  I even went there to visit them.

22             JUDGE HARHOFF:  And what was the purpose of those visits?

23        A.   To inspect their conditions of life, to see what the discipline

24     was, and if there were any problems that had to be dealt with.

25             JUDGE HARHOFF:  Was it necessary to nurse them?  I mean, you had

Page 15930

 1     signed off command over them to the TO, and I suppose that they were

 2     involved in the armed forces under the TO's command.  So if there were

 3     any problems, the TO would report to you; otherwise, it would be

 4     unnecessary to go and inspect on your own?

 5        A.   Well, if -- even if I hadn't been the deputy chief of the

 6     War Staff, I would have done it as a human being.

 7             JUDGE HARHOFF:  Do you know if other volunteer units also came to

 8     the conflict areas in Croatia, that is to say, volunteers who had not

 9     been sent by the SRS?

10        A.   Yes.

11             JUDGE HARHOFF:  Who sent those other volunteers?

12        A.   I am familiar with the case of Arkan's volunteers or the Serbian

13     Volunteer Guard.  I'm also familiar with the case of Mirko Jovic or the

14     White Eagles.  Anybody else could go on their own, as a private

15     individual, without the backing of any organisation.

16             JUDGE HARHOFF:  Do you know if these volunteers were recruited

17     according to the same procedure as the SRS volunteers were recruited;

18     that is to say, if they were recruited on the basis of demands made by

19     the TOs or requests made by the TOs?

20        A.   I really don't know how they went.  I'm not familiar with the

21     procedure at all.

22             JUDGE HARHOFF:  Did you know if the requests that you received

23     from the TOs were also sent to others?

24        A.   I don't have such information.

25             JUDGE HARHOFF:  When you described to me that the TOs were

Page 15931

 1     sending out requests for assistance in the form of young combatants, and

 2     you also told me that Arkan's men were represented, the White Eagles were

 3     represented, and other volunteer groups were present in the area, it

 4     would suggest to me, at least, that there was a market out there for

 5     volunteers.  Have I understood this correctly?

 6        A.   I don't know how to word all that.  I worked with the volunteers

 7     of the Serbian Radical Party.

 8             JUDGE HARHOFF:  Very well.  Let me just ask one more question in

 9     relation to the contact that you held with the volunteers while they were

10     in service.  How long did you retain your contact with the SRS

11     volunteers; for a couple of months, or until the end of the war, or how

12     long?

13        A.   Until the end of 1991.

14             JUDGE HARHOFF:  That's when you resigned, but do you know if

15     the --

16        A.   Correct.

17             JUDGE HARHOFF:  Do you know if the Crisis Staff of the SRS

18     continued their contacts with the volunteers after you resigned?

19        A.   Yes, the contacts went on, but I'm not familiar with the details

20     thereof.

21             JUDGE HARHOFF:  At several places in your statements, Mr. Rankic,

22     you mentioned Milan Lancuzanin, and you said that he was the Chetnik

23     commander in Vukovar, and that some of the SRS volunteers were put under

24     his command.  What was Lancuzanin's position?  Was he an officer in the

25     JNA, or did he work for the TO, or where was he placed?

Page 15932

 1        A.   Mr. Milan Lancuzanin was the commander of the

 2     Leva Supoderica Unit on the strength of the Territorial Defence of

 3     Vukovar.  He was not an active JNA officer.  And you just said he was a

 4     Chetnik commander.  I don't agree with that expression, because all of us

 5     were Chetniks in their eyes.

 6             JUDGE HARHOFF:  The issue boils down to under whose command he

 7     was.  Was he under the TO's command or under the JNA's command?

 8        A.   Under the command of the Territorial Defence, and the Territorial

 9     Defence was under the JNA.

10             JUDGE HARHOFF:  Under the Guards Brigade; is that right?

11        A.   The Guards Brigade did have operative command in that area.

12             JUDGE HARHOFF:  Did the JNA Guards Brigade have the overall

13     authority to direct the units in the area during the combat operations?

14     In other words, Mr. Rankic, I'm looking for who was holding the overall

15     military command in Vukovar, just to take one example, during the combat

16     operations?

17        A.   I must put it this way:  The city of Vukovar, itself, was divided

18     into two sectors, Sector North and Sector South.  As far as I know, the

19     operative command was in the hands of the Novi Sad Corps in Sector North.

20     I believe that the commander was General Bjorcevic [phoen].  And in OZ

21     South, the operative command was in the hands of the Guards Brigade of

22     the JNA, under the command of General Mile Mrksic.

23             JUDGE HARHOFF:  Thank you.  Now, you mentioned earlier on that --

24     I think it was on 1st November 1991, you entered into a form of

25     co-operation with the JNA.  Is that correct?

Page 15933

 1             I didn't hear your answer, sorry.  I did not hear --

 2        A.   Correct, correct.

 3             JUDGE HARHOFF:  Very well.  What was that co-operation?  Can you

 4     describe it for us?  How did it come about, and what did it imply?

 5        A.   On the 1st of October, 1991, the state of an imminent threat of

 6     war was proclaimed in the territory of Yugoslavia.  The JNA launched an

 7     active fight against the secessionist forces.  There was no longer need

 8     for us to send volunteers through Territorial Defence staffs.  We could

 9     do it directly through the JNA.

10             JUDGE HARHOFF:  I'm not sure I understand.  Why did the

11     proclamation of a state of imminent threat of war imply that you did not

12     any longer have to send volunteers through the TOs?  I mean, I suppose

13     that the TOs were still requesting assistance.  Weren't they?

14        A.   The thing is that from the time the imminent state of war was

15     proclaimed, the JNA got involved in armed clashes with secessionist

16     forces.  Until then, it had been neutral.

17             JUDGE HARHOFF:  Right.  But even after the JNA engaged itself in

18     armed conflicts with the separationist forces, I suppose that the TOs and

19     the local crisis staffs out there in Croatia would still request

20     assistance from the SRS.  Wouldn't they?

21        A.   Yes, yes.  But I just explained a moment ago the Territorial

22     Defence is an integral part of the JNA, so it's under the direct command

23     of the JNA.

24             JUDGE HARHOFF:  After 1st October 1991, who sent requests to the

25     SRS for assistance?

Page 15934

 1        A.   Territorial Defence staffs, but under the direct command of the

 2     JNA.

 3             JUDGE HARHOFF:  But how was the procedure different?

 4        A.   The procedure was different because we were able to address

 5     ourselves directly to the JNA to get weapons, uniforms, transportation,

 6     and everything else that was needed.

 7             JUDGE HARHOFF:  Right.  So basically you were still dealing with

 8     the TOs, and the difference was just that now the TOs were under the

 9     command of the JNA; is that how it's to be understood?

10        A.   Roughly, yes.

11             JUDGE HARHOFF:  So in your view, after October 1st it was now the

12     JNA that issued requests to the SRS asking for volunteers to arrive and

13     to assist in the armed conflicts; is that correct?

14        A.   Indirectly, yes.

15             JUDGE HARHOFF:  And directly?

16        A.   Directly, it was the Staff of the Territorial Defence.

17             JUDGE HARHOFF:  Did you also, from time to time, provide

18     volunteers to the MUP?

19        A.   We never sent volunteers to the MUP.  All the volunteers we had

20     were engaged by the local MUPs in Croatia.  We have to get one thing

21     clear.  It was not the MUP of the Republic of Serbia.

22             JUDGE HARHOFF:  And do you know if, in 1992, albeit after you had

23     resigned, that the SRS provided volunteers not only to the JNA, or would

24     then eventually become the VRS, but also to the MUP, the Serbian MUP in

25     Bosnia and Herzegovina?

Page 15935

 1        A.   I heard that some volunteers were engaged in the Serbian MUP of

 2     Bosnia and Herzegovina, but I'm really not qualified to speak about that.

 3             JUDGE HARHOFF:  After you had resigned, when we move into 1992,

 4     and again I know that you had resigned so you may not have first-hand

 5     knowledge of this, but do you happen to know how the organisation was --

 6     or how the provision of volunteers to the VRS was organised?  Did that

 7     follow the same routine as with the JNA earlier on; namely, that it would

 8     be the local TOs or the crisis staffs in Bosnia and Herzegovina who would

 9     ask for assistance from the SRS for volunteers?  In other words, did the

10     procedure continue roughly along the same lines into 1992; do you know?

11        A.   I suppose so.

12             JUDGE HARHOFF:  Do you know if the SRS ever provided any uniforms

13     or weapons to the volunteers?

14        A.   The SRS never had any weapons or uniforms.  Only the JNA could

15     provide that; and the MUP of Serbia, which had weapons and uniforms, but

16     we did not have any co-operation with them.

17             JUDGE HARHOFF:  So to your knowledge, the volunteers were never

18     dispatched to the police, to the MUP, and therefore never went into the

19     MUP organisation and under the MUP command?  Is that what you're saying?

20        A.   While I was deputy chief of the War Staff, I can say with full

21     responsibility that not a single volunteer went anywhere through the MUP

22     of Serbia.

23             JUDGE HARHOFF:  You mentioned, though, that in some instances

24     volunteers moved on from having fought under the command of the TO, and

25     after the battle they moved on and signed up with the MUP, so my question

Page 15936

 1     is:  Did you still retain contacts with those volunteers who left the TO

 2     and started working with the MUP, or did you lose contact with them as of

 3     that point?

 4        A.   From that moment on, they were no longer our responsibility.

 5     They were the responsibility of the local MUP.  They were on the payroll

 6     of that MUP, and they belonged to a different agency, a different

 7     structure.

 8             JUDGE HARHOFF:  So your organisation of volunteers was limited to

 9     providing volunteers to, first, the TOs, and then after October 1st,

10     1991, to the JNA, and that is as far as the co-operation between the SRS

11     and the armed forces went; is that correctly understood?

12             For the record, sir, please provide your answer.  I saw that you

13     were nodding, but you have to say something.

14        A.   Yes, that's right.

15             JUDGE HARHOFF:  Thanks.  My final question relates to a piece of

16     information that I also read somewhere in the statements about

17     information that you did receive of insubordination on the part of some

18     of the volunteers that you had sent.  I think you mentioned -- you used

19     the word, somewhere in your statements, the word "independently," that

20     small units of former volunteers started to act independently.  What

21     exactly did you mean by that word?  Do you remember having said that, and

22     do you understand the meaning of my question?  What happened with these

23     guys?  What did they do?

24        A.   Could you tell me -- could you give me a reference?  What cases

25     are we talking about?

Page 15937

 1             JUDGE HARHOFF:  I think there was an incident in the municipality

 2     of Zvornik, where some SRS volunteers had been registered with the TO,

 3     but subsequently started to act, and this was your word, independently.

 4     And I was curious to know what actually you meant by that --

 5        A.   I would appreciate it if you made a distinction between 1991 and

 6     1992.  Zvornik was 1992.  1992 can only be what I know from hearsay and

 7     may not be true.

 8             JUDGE HARHOFF:  Very well.  My last question to you, Mr. Rankic,

 9     is -- and let me go back a bit to the point where you were handing over

10     your volunteers to the TO command.  Do you know if the volunteers were

11     told that they could stay together as a unit, while they were under the

12     TO command, once the fighting started?

13        A.   Well, for the most part, they acted as units together, because

14     they knew each other best, they knew their commander best, so it was

15     logical for them to act as a unit, but, of course, within the Territorial

16     Defence and with specified tasks.

17             JUDGE HARHOFF:  But maybe this is where the word "independently"

18     comes in.  Do you know if they were allowed to act independently, of

19     course, still under the overall command of the TO?  But while in combat,

20     did they have their own leader with them and able to carry out the orders

21     independently?

22        A.   In the field, every unit would get a certain task, an assignment.

23     However, the executive command in the field belongs to the Command of the

24     TO.  That means that all units act in a synchronised way as part of the

25     Territorial Defence.

Page 15938

 1             JUDGE ANTONETTI: [Interpretation] We are now going to move to

 2     questions put to you by Judge Lattanzi, and I'm not going to interrupt

 3     her.

 4             JUDGE LATTANZI: [Interpretation] Thank you.

 5             Witness, good afternoon.  I need to get some clarification on

 6     some preliminary issues regarding all those parties.  It seems that as in

 7     Italy, you have tens and tens of parties, and I'm rather confused.

 8             We are talking about the Serbian Radical Party.  Could you

 9     perhaps give me the acronym in your own language?

10        A.   SRS.

11             JUDGE LATTANZI: [Interpretation] Thank you.  Then you have the

12     Popular -- or People's Radical Party.  Could you perhaps give me the

13     acronym in your language?  Perhaps it's not the correct translation, but

14     this is the party of which you were a member, if I'm not mistaken.  What

15     was the acronym in your own language?

16        A.   You just inverted the word order.  It's the

17     Popular Radical Party, NRS.

18             JUDGE LATTANZI: [Interpretation] NRS.  Very well.  And then we

19     hear of the SNO, and I don't quite understand what this is about.  Do you

20     know anything about that ?

21        A.   It's the Serbian People's Renewal, led by Mirko Jovic.

22             JUDGE LATTANZI: [Interpretation] Ah, okay, very well.  Thank you.

23     And then we have the MCS, which is the Serbian Chetnik Movement; right?

24     MC, with the sign on top, and this is the movement -- the Serbian Chetnik

25     Movement.  But what is the acronym in your own language, please?

Page 15939

 1        A.   The acronym for the Serbian Chetnik Movement is SC, with a

 2     diacritic, P.

 3             JUDGE LATTANZI: [Interpretation] Very well.  Now I can find my

 4     way through this, because I was rather confused.

 5             You talked at length with Judge Harhoff on the recruitment within

 6     the party, and namely the Serbian Radical Party, and you were very well

 7     informed, even if you were not a member of the Serbian Radical Party,

 8     because you told us this afternoon that you did not take part in the

 9     setting up of the Serbian Radical Party and you never had a membership

10     card.  So you were very well informed, as you told us, but I would like

11     us to confirm or deny that.

12             As I was saying, you were very well informed, because you said to

13     us this afternoon that you worked at the headquarter, and even if, like

14     Mr. Seselj, you were part of this wider movement, namely, the Serbian

15     Chetnik Movement, you said that, We were working like a unit.  You said

16     this this afternoon; correct?  I can give you the reference in the

17     transcript.  It's page 38, from lines 5 to 7.

18             So what I would like to know is to have more information,

19     basically, on the volunteers of this wider movement, as well as

20     volunteers from the Serbian Radical Party.  What was their relationship?

21     Were they all organised in the form of a single unit, even when it comes

22     to the various branches of the Serbian Radical Party, be it in Belgrade

23     or elsewhere, whether buses that were organised were boarded by all of

24     them?  Was there really a single unit that you mentioned?  And if that is

25     true, as you have testified this afternoon, if it is true that we were

Page 15940

 1     talking about all those volunteers as the Chetnik volunteers?

 2        A.   I can tell you about the enemy force.  They called us all

 3     Chetniks, whereas we, amongst us, knew who was who.

 4             JUDGE LATTANZI: [Interpretation] But the volunteers that were

 5     specifically organised by the Serbian Radical Party, under the

 6     authority -- the political authority and the moral authority of the

 7     accused, were they also considered as Chetnik volunteers; is that how we

 8     referred to them, Chetnici [as interpreted].

 9        A.   Yes, yes, we were all called Chetniks, and they called even the

10     JNA Chetniks.

11             JUDGE LATTANZI: [Interpretation] Thank you.  Now I would like to

12     touch upon another issue.

13             At some stage in your testimony, you said that all those Chetnik

14     volunteers had the possibility to organise themselves and then to work

15     towards defending the Serbian people, as you said.  Now, before

16     mobilisation, before there was a danger that was announced, there was a

17     law, if you will, that stated that after this point in time, something

18     happened, and then you had a unit, you had the TO, you had the army, you

19     had the volunteers, and so on and so forth.  But what I would like to

20     know, I would like to know when volunteers were organised.  Was that

21     before the mobilisation in 1991, and was it before it was declared that

22     there was an imminent threat of war?  I would like to know when

23     volunteers started to be recruited, because there were perhaps one-off

24     volunteers that signed up after the mobilisation and after Yugoslavia

25     decided to mobilise its troops, because you also mentioned volunteers --

Page 15941

 1     one-off volunteers or individual volunteers who signed up, but that was

 2     after mobilisation.  Okay.  And from what I understood in your testimony

 3     today, you already had volunteers that had organised themselves through

 4     the various political parties, through this Chetnik movement, and so what

 5     I would like to know is when this started.

 6        A.   Beginning with 2nd May, the attack at Borovo village by units of

 7     the Croatian MUP.  From that moment on, we started sending volunteers

 8     across the Danube.

 9             JUDGE LATTANZI: [Interpretation] Okay, after Borovo Selo.  Yes,

10     thank you.

11             What I wanted to know is the following:  They could not get the

12     help from the TO or from the JNA, or could they already get help from the

13     TO already at that stage?  When it comes to equipment, to weapons, and to

14     logistics, did they immediately get help from the TO?

15        A.   From the TO, yes.  From the JNA, no.

16             JUDGE LATTANZI: [Interpretation] So they received weapons from

17     the TO.  The TO had weapons at their disposal, or was it that the TO

18     received weapons only after national mobilisation?

19        A.   The Territorial Defence already had weapons at their disposal,

20     but those were mostly old, perhaps obsolete weapons.

21             JUDGE LATTANZI: [Interpretation] So it means that the TO had

22     weapons even during peacetime.  Even if these were obsolete or

23     unsophisticated weapons, they could keep those weapons during peacetime?

24        A.   Yes, yes, that was the rule in the former SFRY.

25             JUDGE LATTANZI: [Interpretation] Thank you.  In your testimony,

Page 15942

 1     you also talked about SAVA.  I think that you mentioned that when

 2     Judge Harhoff put some questions to you, or perhaps Judge Antonetti.  You

 3     talked about the Association of Serbs abroad.  Was that called "SAVA"?

 4        A.   No, those are two different organisations.

 5             JUDGE LATTANZI: [Interpretation] My apology.  At some stage, the

 6     association, SAVA, disappeared, and this new Party of Serbian Renewal

 7     came about; is that correct?

 8        A.   Correct.  Yes, that's correct.

 9             JUDGE LATTANZI: [Interpretation] Thank you.  And this new Party

10     of Serbian Renewal, did it have a similar ideology to defend the Serbian

11     people?

12        A.   For the most part, yes.

13             JUDGE LATTANZI: [Interpretation] Talking about this ideology, I

14     was wondering whether you could be more precise.  What did this mean, and

15     defending the Serbian people?  Did this involve defending, stricto sensu,

16     oneself against somebody else who's attacking you, or was it also in the

17     aim of gaining some territory?  We're talking about this border and the

18     concept of a Greater Serbia, because it's important.  You said that

19     volunteers started to organise themselves around defending the Serbian

20     people, so I would like to know exactly what was meant by that.

21        A.   The idea to defend the Serbian people depends on the year.  If

22     we're talking about in the year 1990, when the Serbian National Defence

23     was established, then we meant to defend the Serbian traditions, the

24     culture, script.  And if you're talking about the period when the armed

25     conflict started, it was about defending Serbs who resided outside of the

Page 15943

 1     territory of the then Republic of Serbia.

 2             JUDGE LATTANZI: [Interpretation] And this Serbian defence outside

 3     the territory of Serbia - I'm not talking about Yugoslavia, I'm talking

 4     about Serbia - I was wondering whether it meant extending the territory

 5     of Serbia.

 6        A.   In the areas that we went to, Serbs were a majority population,

 7     for the most part.  I don't know what you mean when you say "extending

 8     the territory of Serbia."

 9             JUDGE LATTANZI: [Interpretation] I would like to come back to

10     this point.  You were saying that Serbs were a majority population, which

11     means, according to you, that this territory should be part of Greater

12     Serbia?

13        A.   I don't use that term at all.

14             JUDGE LATTANZI: [Interpretation] So what word would you use?

15        A.   We were against the fragmentation of Yugoslavia.

16             JUDGE LATTANZI: [Interpretation] You were against the

17     fragmentation of Yugoslavia.  Indeed, I understand that very well, and I

18     also understand how this attempt came about to be against any secession.

19     But once you understood that secession was unavoidable, and when you

20     realised -- or when you saw that the ideology of a Greater Serbia

21     developed, in a way it meant that Serbia would become Greater Serbia,

22     including occupied territories when there was -- where Serbs were a

23     majority population in Bosnia, specifically?

24        A.   I apologise.  I don't know what you mean when you say "the

25     Greater Serbia."  Serbia did not start existing in 1945, but in 1918.

Page 15944

 1             JUDGE LATTANZI: [Interpretation] Let's leave that aside.  Greater

 2     Serbia was a political ideal, I believe.  But if you are not aware of

 3     this, let's move on.

 4        A.   I apologise.  I have to provide a very brief explanation, if the

 5     Trial Chamber allows me to do so.

 6             This is what it is about:  In 1918, Serbia proclaimed its western

 7     borders on the Kupa and Ilok [as interpreted], and if somebody considers

 8     that to be the Greater Serbia, it's a different issue.  However, if

 9     somebody starts to fragment the state, then it is only logical to take

10     away what they brought into the state in the first place.

11             THE ACCUSED: [Interpretation] Objection.

12             JUDGE LATTANZI: [Interpretation] Just a second.

13             And this objective that you are talking about in order - how

14     could I say this? - to reclaim its 1918 borders, I was wondering whether

15     this objective was going to be reached through peaceful means or through

16     military means.

17        A.   I was not one to have a say in deciding on that objective.

18             JUDGE LATTANZI: [Interpretation] Were you aware of this

19     objective, that it was to be achieved through armed force and what has

20     been termed ethnic cleansing?

21        A.   As far as I know, the objective was to preserve Yugoslavia, and

22     politicians decided on the rest.

23             THE ACCUSED: [Interpretation] Can I now voice my objection?  I

24     waited intentionally.

25             I have the right to object to your questions, Ms. Lattanzi.  I'm

Page 15945

 1     sure you're aware of that.

 2             JUDGE LATTANZI: [Interpretation] I'm not convinced that you have

 3     a right to do so, but please go ahead.

 4             THE ACCUSED: [Interpretation] I waited on purpose for the witness

 5     to finish his answer in order not to influence his answer.

 6             I protest, Ms. Lattanzi, to your words, that the ideology of the

 7     Greater Serbia developed in the sense that Serbia became the Greater

 8     Serbia and included occupied territories in Bosnia which where Serbs were

 9     a majority.  Who was it who occupied those territories?  Was it the Serbs

10     who did it to themselves?  You are accepting the ideology of a certain

11     [indiscernible].  How could the Serbs occupy themselves?  I protest

12     against such an interpretation on your part.

13             JUDGE LATTANZI: [Interpretation] I asked for clarification from

14     the witness.

15             Sir, I would like to know this now:  I would like to know

16     something about the relations between the accused and Milosevic,

17     President Milosevic.

18             JUDGE ANTONETTI: [Interpretation] The question is an important

19     one, and our break is also important.

20             We shall have a 20-minute break now.  After that, we shall resume

21     around 10 minutes to 6.00.  And if my colleague finishes in the time that

22     has been allotted, Ms. Biersay can start on her cross-examination or,

23     rather, questions put by the Prosecution, because we are dealing with a

24     witness of the Court.

25             A 20-minute break.

Page 15946

 1                           --- Recess taken at 5.38 p.m.

 2                           --- On resuming at 5.56 p.m.

 3             JUDGE ANTONETTI: [Interpretation] The court is back in session.

 4             Judge Lattanzi.

 5             THE ACCUSED: [Interpretation] I would like to raise a short

 6     procedural issue, if I may.

 7             Your Honours, you assigned two hours to the Trial Chamber, two

 8     hours to the OTP, and two hours to the Defence, and the question that I

 9     would like to ask is whether the Trial Chamber has the right to go on for

10     longer than two hours.  Your two hours have expired, if we deduct from

11     that time my objections, the Prosecutor's objections, and the procedural

12     issues.  Maybe you have the right to surpass the time, but I would like

13     to know.

14             JUDGE ANTONETTI: [Interpretation] I will answer straight away.  I

15     don't believe we've had two hours.  I have spent a lot of time reading

16     out oral decisions, and I haven't put many questions.  Judge Harhoff

17     perhaps exceeded the 40 minutes, I don't know, and my colleague has just

18     started.  So in the overall time, I'm not so sure.

19             Second question.  This is a witness of the Court, and the Judges

20     take the time they feel is necessary.  We have decided to grant the

21     Prosecution two hours and to grant you two hours.  If we had decided to

22     question this witness for 10 days, we would be entitled to do so and say

23     the Prosecutor will have one hour and the Defence one hour.  This is a

24     matter of discretion for the Bench.  We said the Trial Chamber would have

25     two hours, the Prosecution two hours, and the Defence two hours.

Page 15947

 1             That said, the questions must relate to the important issues

 2     which people are familiar with now; the sending of volunteers, the

 3     potential co-operation between Seselj and Milosevic.  So I believe that

 4     Judge Lattanzi will have finished in half an hour's time, maybe, and

 5     Ms. Biersay can then start, which means that the Prosecutor can use its

 6     two hours and you can use your two hours.  Normally speaking, this should

 7     be our last witness, so the questions are very specific and go to the

 8     heart of this case.

 9             This is what I wanted to say.

10             JUDGE LATTANZI: [Interpretation] I hope this is not the last

11     witness.  I hope that there will be another two witnesses.  We shall see.

12             If you know anything about this, because if you don't know

13     anything about it, do not reply.  Do you know what the relations were

14     between Mr. Seselj and Milosevic, President Milosevic, before the war and

15     during the war?

16        A.   As far as I know, Mr. Seselj and Mr. Milosevic were political

17     opponents.

18             JUDGE LATTANZI: [Interpretation] That was also the case during

19     the entire time of the war?

20        A.   Well, I learned from the media in 1997 that they were together in

21     the government of national salvation, if my memory serves me right.  That

22     was after the war.

23             JUDGE LATTANZI: [Interpretation] The question I put to you

24     related to the war.  I asked you the question "during the war."

25        A.   [Previous translation continues]... political opponents.

Page 15948

 1             JUDGE LATTANZI: [Interpretation] If they were political

 2     opponents, did it make sense to ask for assistance from the JNA - how did

 3     you respond to Judge Harhoff - to ask for volunteers from the SRS as

 4     well?  Perhaps it does make sense if you explain it to us.

 5        A.   I assume that they had common interests, and that was to preserve

 6     Yugoslavia.

 7             JUDGE LATTANZI: [Interpretation] What were the relations between

 8     Mr. Seselj and Arkan?

 9        A.   As far as I know, their relations were never good.  Just the

10     opposite was true; they were enemies.

11             JUDGE LATTANZI: [Interpretation] If we set aside their personal

12     relations, I would like to talk about their public relations, i.e.,

13     sharing a common objective.  The volunteers of the SRS were co-operating

14     with the volunteers?

15        A.   We never co-operated.  I don't understand the meaning of the word

16     "co-operate."  We never co-operated with the volunteers of the Serb

17     volunteer guards or Arkan's volunteers, but they were there in the

18     region.  But we never allowed ourselves to enter an armed conflict with

19     them, because we were on the same side.

20             JUDGE LATTANZI: [Interpretation] Maybe I didn't quite understand

21     what you said earlier.  But at some point, from what I understood, you

22     said that all these volunteers were placed under the command of Arkan's

23     men in a particular area.  But maybe I misunderstood you.

24        A.   You misunderstood something.  I never said that.

25             JUDGE LATTANZI: [Interpretation] I must have confused this with

Page 15949

 1     something else.  I'm sorry.  They, therefore, never took part in joint

 2     operations?

 3        A.   Within the Territorial Defence, we had our tasks, our unit had

 4     its tasks, and I suppose that they also had their tasks and assignments.

 5             JUDGE LATTANZI: [Interpretation] So there were no joint

 6     assignments.  Assignments were always given by the TO to the men?

 7        A.   While I was deputy chief of the War Staff, there were no joint

 8     missions.  How shall I put it?  The Territorial Defence decided on who

 9     would be sent on what mission, but we made sure never to be in the same

10     sector.  They were sometimes 20 kilometres away from us, but that had

11     nothing to do with any sort of co-operation.

12             JUDGE LATTANZI: [Interpretation] Fine.  According to what you

13     have said, incidents took place that had been provoked by

14     volunteers of the SRS or, rather, Chetnik volunteers.  You mentioned, for

15     instance, something which occurred in 1992 at Loznica, the Loznica

16     volunteers who were sent off to Zvornik.  The head of this group was

17     Zuca.  He was a member of the Serbian Radical Party, was he?

18        A.   I can't speak about the period after 1992 because I was no longer

19     deputy chief of the War Staff, and everything that I could share with you

20     is hearsay.  And as far as Vojin Vuckovic goes, also known as Zuca, he

21     was our volunteer in 1991, but I heard that later on he was excluded from

22     the membership.

23             JUDGE LATTANZI:  [No interpretation]

24        A.   I don't know when.

25             JUDGE LATTANZI: [Interpretation] [Previous translation

Page 15950

 1     continues]... excluded from the party.

 2        A.   [Previous translation continues]... are volunteering in East

 3     Slavonia in the events that took place in 1991.  If we're talking about

 4     1991, he was there.

 5             THE INTERPRETER:  "You don't know on what date he was excluded

 6     from the party?"  Previous question.

 7             JUDGE LATTANZI: [Interpretation] Do you remember a visit made by

 8     Mr. Seselj in Zvornik in the spring of 1992?

 9        A.   In spring 1992?

10             JUDGE LATTANZI: [Interpretation] I'm sorry, I didn't hear your

11     answer.

12        A.   Well, I asked you whether you wanted to know about spring 1992.

13             JUDGE LATTANZI: [Interpretation] Yes.

14        A.   Mr. Seselj was not in Zvornik in spring 1992.  He was there in

15     1990, but that was before the conflicts broke out in Bosnia and

16     Herzegovina, if my memory serves me well.

17             JUDGE LATTANZI: [Interpretation] You made a mistake when you

18     mentioned this visit in two of your statements?

19        A.   What I said or what is perhaps written in that statement, that

20     was the suggestion of the OTP if it says that he was there in spring

21     1992.

22             JUDGE LATTANZI: [Interpretation] I would like to know this:  When

23     the Chetnik volunteers talked about the Ustashas, what did they mean by

24     that?  Did they include all the Croats, did they include some Croats, did

25     they include the men that could go to war, the able-bodied men?  What did

Page 15951

 1     they mean when they used this term?

 2        A.   Only those who waged the war, who bore arms.  Military-age,

 3     able-bodied men carrying weapons.

 4             JUDGE LATTANZI: [Interpretation] The volunteers that were in

 5     Vukovar, what was their aim?  Was their aim for all these combatants or

 6     fighters to be killed; yes or no?

 7        A.   The objective of the Serbian volunteers in Vukovar was to free

 8     Vukovar.

 9             JUDGE LATTANZI: [Interpretation] In two of your statements, you

10     mention something which had purportedly been said by Mr. Seselj, Not a

11     single Ustasha should leave Vukovar alive.  Is this a mistake that you

12     have made in your statement?  Is this something which the Prosecutor has

13     suggested to you?  What is this?

14        A.   I don't think that was recorded authentically.  He didn't say

15     that, or at least I don't remember that Mr. Seselj said that.  We

16     appealed to them several times to surrender, and I was in Vukovar, too.

17     And, of course, if somebody doesn't surrender, everyone knows what

18     happens next.

19             JUDGE LATTANZI: [Interpretation] But you said that this was said

20     in the presence of 50 people, all these details?

21        A.   I did not say that in that way.

22             JUDGE LATTANZI: [Interpretation] I have another question.

23             What about the volunteers?  Well, there were those volunteers

24     that had been -- or got themselves organised in Belgrade.  Some had got

25     themselves organised locally and some had come from Belgrade?

Page 15952

 1        A.   Yes, yes.

 2             JUDGE LATTANZI: [Interpretation] But these were still volunteers,

 3     if we talk about Chetnik volunteers?  These were still volunteers who

 4     were working together with the same objective in mind, whether these were

 5     local volunteers or whether these were volunteers coming from Belgrade;

 6     is that right?

 7        A.   Of course.  All Serbs naturally had the same aim, and I'm talking

 8     now about patriots.

 9             JUDGE LATTANZI: [Interpretation] These Chetnik volunteers, when

10     they were organised, when they were recruited, well, were speeches being

11     addressed to them?

12        A.   Yes.

13             JUDGE LATTANZI: [Interpretation] What were they being told?

14        A.   That they had to go fight courageously, honorably, in the spirit

15     of the Serbian Army.  They had to obey the prevailing rules, the Geneva

16     Conventions, and the Rules and Customs of War.

17             JUDGE LATTANZI: [Interpretation] Who held these speeches?  Was it

18     Mr. Seselj or was there someone else who addressed himself to these

19     volunteers before they left?

20        A.   Once or twice, Mr. Seselj said that.  Once or twice,

21     Mr. Ljubisa Petkovic and I, myself.

22             JUDGE LATTANZI: [Interpretation] You talked to them about the

23     Geneva Conventions, that one must abide by the Geneva Conventions?  That

24     is what you deny in your statements.

25        A.   As I said, I don't know what's in that statement.

Page 15953

 1             JUDGE LATTANZI: [Interpretation] You did not sign these

 2     statements?

 3        A.   I did sign them, but I never got them to read or to correct if

 4     something is not consistent with the truth, although I had insisted.

 5             JUDGE LATTANZI: [Interpretation] And why did you sign these

 6     statements?  Did someone actually hold your hand so that you signed

 7     these?  Did someone force you to sign these?

 8        A.   I said in my introductory remarks how my statement was taken.  I

 9     suppose you can understand from all that why I signed.

10             JUDGE LATTANZI: [Interpretation] I'm awfully sorry, but I have

11     not understood at all.

12             One last point -- last question I wanted to put to you.

13     Incidents occurred when there is a war, and this is something which you

14     mention in your statements.  There are always incidents where volunteers

15     were involved in something which did not meet the Geneva Convention

16     requirements.  This is something you mentioned yourself in your

17     statements, and I would like to know this:  Were there any reactions to

18     this on the part of an organisation, a group or -- that had drafted these

19     men?  You said that these people had been chosen, and you made sure that

20     you were not drafting, in these groups, alcoholics and the like.  Did

21     someone do anything?  How did this organisation that had recruited them

22     and chosen them react to this?

23        A.   I have to explain a couple of things to the honourable Trial

24     Chamber.

25             In the field, it was the Territorial Defence Staff that had

Page 15954

 1     operative command over the volunteers or the military unit acting in that

 2     area.  We had no operative command in the field whatsoever.  If something

 3     happened involving volunteers, but not only volunteers of the SRS, the

 4     locals as well, then the local military command was in charge and they

 5     had to react.  There was also the civilian police on the ground.  The

 6     Serbian Radical Party had no operative command whatsoever.

 7             JUDGE LATTANZI: [Interpretation] That is something I understand

 8     perfectly well.  I was not actually referring to that.  I was referring

 9     to the moral authority of this organisation that had screened these men

10     and that were involved due to their behaviour, so it was for them to

11     react.  I'm not talking about only reaction in the form of a criminal

12     sanction.  I was asking you whether this organisation was checking that

13     the volunteers were behaving properly on the battle-field.

14        A.   The only responsibility, the only competence we had, was to expel

15     such a person from the party.

16             JUDGE LATTANZI: [Interpretation] So this was always done after

17     having been informed about something that had happened, i.e., one or

18     other volunteer misbehaving?

19        A.   While I was part of the staff of the Serbian Radical Party, I

20     regularly did that.

21             JUDGE LATTANZI: [Interpretation] In your statements, you say

22     something else.

23             Thank you very much.  I have finished.

24             JUDGE ANTONETTI: [Interpretation] Witness, I have a follow-up

25     question for you, which is going to be an extremely short question.

Page 15955

 1     Please listen carefully.  I'm putting this question to you because you

 2     answered the questions put by my colleagues in a very clear way.  I have

 3     the feeling that you are an educated man and you have some knowledge of

 4     political matters, because in the 1990s you were affiliated to a

 5     political movement.  And I feel that you are perhaps the last witness,

 6     and therefore I feel it necessary to put this question to you.

 7             In the indictment, the Prosecutor alleges that there was a form

 8     of ethnic cleansing in Vojvodina.  As you know, Vojvodina is a province

 9     which is specific and distinct from Serbia, but it is part of the

10     Republic of Serbia.  Mr. Seselj gave an interview to a press agency

11     called "Tanjug," and this is to be found in the Prosecution Exhibit 1732.

12     And a question is put to him about Kosovo.  Mr. Seselj has already

13     discussed Kosovo at length with us, and he says, and I have the text

14     before me - this is on page 12 in the English version.  It states that

15     Kosovo Metohija [realtime transcript read in error "Medjugorje"], an

16     integral part of Serbia, and of the Yugoslav republic, because at the

17     time he gives his interview the Yugoslav republic still exists, and he

18     says as follows.  He says that on the 6th of April, 1941, there was

19     360.000 Albanians emigrated to Kosovo, and that as far as he was

20     concerned, since Albania is a democratic country, there is no reason why

21     these refugees should remain in Kosovo.  One could, therefore, infer that

22     according to him, he felt that these Albanian people in Kosovo should go

23     back to Albania.  This is what he says in his interview, which is

24     Exhibit 1732.

25             Based on that, and if I take a closer look at the history of your

Page 15956

 1     country, I have realised there have been several waves of immigration.

 2     In 1690 - perhaps you know, perhaps you don't know - there was a great

 3     wave of immigration.  At the time, there was a conflict between Austria

 4     and the Turks, and as part of the coalition, strangely enough, there was

 5     the Republic of Venice which was involved and which everybody knows is

 6     Italian.  There was Austria, there was Russia, and Serb farmers called

 7     Heduc [phoen], and this coalition lost against the Turks.  So the

 8     patriarch then organised a wave of immigration, and Serbs were to be

 9     saved, and 40.000 to 200.000 Serbs left for Vojvodina and Slavonia, i.e.,

10     Croatia.  So a great number of Serbs left for Croatia.

11             In 1737, the war broke out with the Turks again.  They were

12     defeated, and a new wave of emigration occurred, and the Serbs left for

13     Croatia then also.

14             When I read this again and if I set it against the backdrop of

15     what Mr. Seselj said about the Albanians in Kosovo, as far as you are

16     concerned, the Serbs that had emigrated to Croatia, do you think that

17     they should have returned to Serbia, since Serbia is a democratic

18     country, in 1991, 1992, 1993?  Seemingly, maybe not, but it was a state,

19     in the same way that the Albanians could return to Albania.  What do you

20     think about what Mr. Seselj was saying about Kosovo, and could his theory

21     not be applied to the Serbs that had left for Croatia?

22             THE ACCUSED: [Interpretation] I have an objection, Mr. President.

23             In line 18, we have on the transcript "Kosovo Medjugorje" instead

24     of "Kosovo Metohija."  This is not an accident that I'm intervening

25     against the interpretation.  There are too many Croats among our

Page 15957

 1     interpreters.  How did "Medjugorje" find itself here along with "Kosovo"?

 2     Medjugorje is the false place of worship where they imagine our lady

 3     appeared to them.  Medjugorje and Kosovo had nothing to do with each

 4     other.

 5             JUDGE ANTONETTI: [Interpretation] We shall not discuss the

 6     Virgin Mary that appeared in Medjugorje.  I believe that the Pope is

 7     going to Fatima in Portugal today.

 8             THE ACCUSED: [Interpretation] This is being done by interpreters,

 9     not me.

10             JUDGE ANTONETTI: [Interpretation] It is, of course, Kosovo

11     Metohija and not Medjugorje.  That makes sense, of course.  So I didn't

12     follow the transcript.  When I put a question, I look at the witness, and

13     I do not always have my nose on the transcript like Anglo-Saxon Judges

14     do.  I would rather look at the witness, or the Prosecutor, or the

15     accused.

16             So can you answer my question, Witness?

17        A.   Your Honours, I am not an expert in history.  Mr. Seselj is an

18     incomparably greater expert in the area.  Therefore, I'm reluctant to

19     discuss the subject.  But as far as Vojvodina is concerned, I know about

20     that because I've read a lot in the press, seen a lot on television.

21             Mr. Seselj did not say that Croats need to move out of Vojvodina.

22     Instead, he recommended that they swap properties with Serbs in Croatia.

23     That's what I know.

24             JUDGE ANTONETTI: [Interpretation] So you can answer questions

25     about Vojvodina and not about other issues.  Thank you very much.

Page 15958

 1             Ms. Biersay, you have 25 valuable minutes.  Please proceed.

 2             MS. BIERSAY:  Your Honour, while I rearrange my position here, I

 3     would like to hand this binder of the B/C/S versions of the witness's

 4     various statements, and I'll give that over.

 5             And in the interim, could I please have Exhibit P27 called up

 6     while I rearrange.

 7             JUDGE ANTONETTI: [Interpretation] Registrar, P27, please.

 8             Ms. Biersay, is that the document that is on the screen?

 9             MS. BIERSAY:  Go to the B/C/S page 1, around paragraph 11, and

10     the English, I believe, would be page 2.  I will get to it, but I wanted

11     to have it ready to go.

12                           Cross-examination by Ms. Biersay:

13        Q.   Good evening, Mr. Rankic.  My name is Lisa Biersay.  I -- as you

14     may well have guessed, I am with the Office of the Prosecutor, and I'm

15     going to be asking you questions on behalf of the Prosecution today.

16             Now, I'm introducing myself because we have never met before; is

17     that correct?

18        A.   Correct.

19        Q.   Now, I had handed to you a binder of some statements that you

20     have signed.  And before we get to those, I see that you have some other

21     documents on your table.  Could you tell us what those documents in the

22     pink and blue folders are?

23        A.   Those documents were my responses to subpoenas and more

24     subpoenas, an aide-memoire for me, and so on.  But I'm not using it here,

25     as you can see.  But if the Court wants a document from me, I have to

Page 15959

 1     have it on me to be able to produce it.

 2        Q.   Could I ask you, please, to turn to tab 3 in your binder before

 3     you.

 4             THE ACCUSED: [Interpretation] I am nonplussed for the first time

 5     since this trial began.  What is this aide-memoire all about?  I don't

 6     know anything about an aide-memoire of the witness.  Who gave him an

 7     aide-memoire?

 8             JUDGE ANTONETTI: [Interpretation] Just a second.  We don't seem

 9     to have any translation into French.

10             Very well.  Mr. Seselj, what did you want to say?

11             THE ACCUSED: [Interpretation] Ms. Biersay asked the witness about

12     some sort of aide-memoire.  This is the first time I'm hearing about an

13     aide-memoire.  Where did it come from?  Who gave him that aide-memoire,

14     or did the witness himself prepare it?  This is the first time I hear of

15     it.

16             MS. BIERSAY:  Hopefully this will not be [overlapping speakers].

17             JUDGE ANTONETTI: [Interpretation] There is no aide-memoire.  I'm

18     just repeating -- I'm going to repeat.

19             The witness said that he had a folder with all the subpoenas and

20     the answers, as well as personal files that could help jog up his memory,

21     but he's not using it, he's not entitled to use it, and he will only

22     answer to the questions based on the documents that have been put forward

23     by Ms. Biersay.

24             So, Ms. Biersay, please go ahead.

25             THE ACCUSED: [Interpretation] Mr. President, I'd understood

Page 15960

 1     Ms. Biersay was asking him about the file that she had just given him.  I

 2     don't see any other file.  Maybe somebody placed this lectern right

 3     between me and the witness, so I can't see what he has before him.  I

 4     just saw the file given him by Ms. Biersay.

 5             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, you gave the

 6     witness a binder.  I was wondering why Mr. Seselj does not have the same

 7     binder, because that would help us to gain some time.

 8             MS. BIERSAY:  Mr. Seselj, as well as the Trial Chamber, has these

 9     statements of the witness.  What has been given to the witness are simply

10     the B/C/S versions of what was contained in the very first compliance

11     binder 1 given to the Court and given to the accused.  So hopefully I can

12     proceed.

13             JUDGE ANTONETTI: [Interpretation] Okay, go ahead.

14             MS. BIERSAY:

15        Q.   I'd like you to turn to paragraph 14 of that statement.  And the

16     one specifically that we're looking at now is the one that is dated

17     September 19th, 2006.

18             Judge Lattanzi asked you some questions about what it meant to be

19     fighting on the behalf of the Serbian cause, and you made a distinction

20     between that struggle, what it was in 1990 versus what it was in 1991.

21     Do you remember those questions asked by Judge Lattanzi, Mr. Rankic?

22        A.   I remember the question, but I don't see it in paragraph 14.

23     Something different is written there.

24        Q.   Exactly.  Now, you described to Judge Lattanzi that the

25     purpose -- the Serb cause, as you saw it, in 1990, was to preserve Serb

Page 15961

 1     tradition and Serb culture and Serb script.  Do you remember saying that

 2     to her at page 63 of the transcript?

 3             THE ACCUSED: [Interpretation] Objection.  The witness was saying

 4     that about the SAVA organisation, not the Serbian Chetnik Movement, and

 5     that was in response to Judge Lattanzi's question about the SAVA

 6     organisation.

 7             MS. BIERSAY:

 8        Q.   Do you recall making a distinction between the purpose of the

 9     Serb cause in 1990 and 1991, yes or no, or would you like me to have it

10     read back to you?

11        A.   Yes, yes.

12        Q.   You remember?

13        A.   I remember that.

14        Q.   And you described the purpose as being to preserve the Serbian

15     tradition and culture and script.  That's what you told the Trial

16     Chamber; is that correct?

17        A.   Correct.

18        Q.   Now, I'd now like to turn your attention to the paragraph 14 of

19     your September 2006 statement.  And what follows in that statement is an

20     excerpted portion of the political platform; is that correct?

21        A.   I'm sorry.  You said "2006"?

22        Q.   No.  Just look under tab 3.  Are you there?

23             And perhaps you could be assisted.

24             Well, while you're being assisted, could you tell the Trial

25     Chamber where, in the political programme of the Serbian Chetnik

Page 15962

 1     Movement -- tab 3, page 4 of your --

 2        A.   [In English] Yes.

 3        Q.   So it would be paragraph 14 which commences on page 4.  Do you

 4     see that?

 5        A.   [In English] Yes.

 6             MS. BIERSAY:  And for the Court's ease, it is also -- the

 7     original document is Exhibit P27, which is what is on the screen

 8     currently.

 9        Q.   Could you tell the Trial Chamber where, in the Serbian Chetnik

10     programme, there is any mention of preserving Serb tradition, culture,

11     and script?  Do you recall that being in the platform, the 1990 Serbian

12     Chetnik Movement platform?

13             THE ACCUSED: [Interpretation] Objection.

14             Your Honours, the gentleman never said that about the Serbian

15     Chetnik Movement.  Ms. Lattanzi, you will remember --

16             [Overlapping speakers]

17             THE ACCUSED: [Interpretation] I'm talking to the Trial Chamber.

18     I'm not talking to Ms. Biersay.

19             Do you remember, Ms. Lattanzi, that the witness told you about

20     the Serb Chetnik Movement, or was he talking about the organisation

21     called SAVA and the Serbian Renewal Movement?  You did not ask him about

22     the programme of the Serbian Chetnik Movement.  Kindly, can -- find it in

23     the transcript, please.  It is not in the transcript.

24             MS. BIERSAY:  I am asking him about the Serbian Chetnik Movement.

25     I am asking him.

Page 15963

 1             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I believe that my

 2     colleague was putting a question of a general nature, and you had the

 3     Chetnik Serbian Movement, the SAVA association.  The question was of a

 4     general nature, and so was the answer.

 5             Now, going from the general nature of the question, Ms. Biersay

 6     is going to a specific question, and she's showing you the platform of

 7     the Chetnik Movement, which is at paragraph 14.  So there we go.  This is

 8     how I see things.

 9             Ms. Biersay, please proceed.

10             MS. BIERSAY:

11        Q.   Was the focus of the Serbian Chetnik Movement -- was it focused

12     on the tradition, the culture, and the script of the Serbian people?

13        A.   I would have to answer to the Trial Chamber and to you, of

14     course, what I said a minute ago, I meant the year 1990 and the SAVA and

15     the Renewal Movement, and the Serbian Chetnik Movement had its own

16     programme which is --

17        Q.   I'm not asking you about the SAVA.  I am asking you about the

18     Serbian Chetnik Movement.  My question to you is:  Where, in the platform

19     of the Serbian Chetnik Movement, published in 1990, where does it say

20     that the purpose of the movement is to protect Serb culture, script, and

21     tradition?  Maybe the answer is it doesn't, and maybe the answer is it

22     does.  I would like to know which way your answer is.

23        A.   That does not exist here, it's not written in here.

24        Q.   Well, it's not written in there, being your statement.  Is

25     there -- before you is Exhibit P27, which is the platform.  Does it exist

Page 15964

 1     in the platform that's on your screen, as far as you recall?

 2             Let me ask you another question.  If you -- again in

 3     paragraph 14, Roman numeral IV, in the platform it specifically discusses

 4     and says:

 5             " ... raising of the question of the responsibility for genocide

 6     committed and wartime destruction."

 7             Do you see that?

 8             " ... by those persons whose members --"

 9        A.   I see that, yes.

10        Q.   "-- took part en masse in the attempt to exterminate the Serbs

11     during the Second World War."

12             Do you see that?

13        A.   I do.

14        Q.   So in 1990, before the events, certainly, of 1991 and 1992, the

15     Serbian Chetnik Movement's political programme discussed the issue of

16     genocide against the Serbs during the Second World War; correct?

17        A.   Yes, but that was always part of the agenda.  That question was

18     always something that needed to be resolved and answered.

19        Q.   And in that very paragraph, it continues that:

20             "The independent state of Croatia, the appearance of a new

21     Ustasha leader ..."

22             Do you see that?

23        A.   Yes, yes.

24        Q.   So it reads:

25             "Particularly so in the circumstances of the restoration of the

Page 15965

 1     independent state of Croatia and the appearance of a new Ustasha leader,

 2     as well as the general protection of the Serb population which is

 3     presently endangered by the new genocidal policy."

 4             That's what's written there; correct?

 5        A.   Yes.

 6        Q.   And that is what is written in the programme, the political

 7     programme of the Serbian Chetnik Movement; correct?

 8        A.   Well, probably, if this is well presented.

 9        Q.   So in 1990, the association with the state of Croatia with the

10     new Ustasha leader was already being put forth by the Serbian Chetnik

11     Movement; is that correct?

12        A.   That was a fear from a new genocide.

13        Q.   And so the Serbian Chetnik Movement's political programme was

14     based on the idea of addressing past wrongs that had been committed

15     against the Serbian people?

16        A.   No, but rather that the Serbian people had to be reminded of what

17     had happened.

18        Q.   Be reminded, yes.  And on that point, in his speeches Mr. Seselj

19     almost always reminded people about the past wrongs committed against the

20     Serbs in World War II, didn't he?

21        A.   Well, that was part of the programme.  I suppose so.

22        Q.   That was part of the programme.  And part of the programme, as we

23     see here again in the same paragraph, is the idea of expulsion of

24     Albanian emigrants and their offspring.  Do you see that?

25        A.   Yes.

Page 15966

 1        Q.   Now, Judge Lattanzi asked you some questions, I believe, about

 2     this concept of Greater Serbia, and you responded that you didn't use

 3     those terms or that term; is that correct?

 4        A.   No.  I believe that the Great Serbia does not exist.  We're

 5     talking about a territory that Serbia brought into the territory of

 6     Yugoslavia in the first place.  And if somebody thinks then that that is

 7     Greater Serbia [as interpreted], then that's a different story.

 8        Q.   Well, let's talk about that different story.  I am not talking

 9     now about the concept -- let's leave the concept of Greater Serbia aside

10     for a minute.  I'm more interested at this time in the --

11             THE ACCUSED: [Interpretation] Your Honours, again the

12     interpretation was not good.  The witness's answer was misinterpreted:

13             [In English] " ... and if somebody thinks that that is Greater

14     Serbia, then that's a different story."

15             [Interpretation] And what about what he actually said, that

16     that's for him normal Serbia?  I'm very well inclined today to follow the

17     interpretation.  I've not done it before, or I did it only rarely, but

18     what the witness did -- actually said has not been interpreted.  He said

19     that that's a normal Serbia for him.

20             JUDGE ANTONETTI: [Interpretation] Indeed, in the French version I

21     heard "normal Serbia."

22             So, Witness --

23             THE ACCUSED: [Interpretation] But it's not in the English.

24             JUDGE ANTONETTI: [Interpretation] Indeed.

25             So, Witness, what was the exact words that you used in your

Page 15967

 1     answer?

 2             And I'm asking the interpreters to interpret the witness very

 3     close to his words.

 4             THE WITNESS: [Interpretation] I said the following:  In a divorce

 5     case, everybody takes out what they had brought in, and for me it's

 6     normal Serbia.

 7             MS. BIERSAY:

 8        Q.   Are you familiar with the publication -- the magazine -- the

 9     newspaper called "Velika Srbija"?

10        A.   Yes.

11        Q.   And was "Velika Srbija" a newspaper at the beginning of the

12     Serbian Chetnik Movement, when it began in 1990?

13        A.   Correct.

14        Q.   And when the Serbian Chetnik Movement evolved with the SRS,

15     "Velika Srbija" then became the newspaper for the SRS; is that correct?

16        A.   Correct.

17        Q.   In the discourses of the accused that you heard or attended,

18     would he use the phrase "Greater Serbia"?

19        A.   As far as I can remember, yes.  But Mr. Seselj is not ashamed of

20     that.  He still uses the term.

21        Q.   I'm not asking you to opine about shame or no shame.  I am simply

22     asking you whether or not you've ever heard him use that phrase in his

23     many discourses.

24        A.   Yes.

25             JUDGE ANTONETTI: [Interpretation] A follow-up question to you,

Page 15968

 1     Witness.

 2             Unfortunately, I cannot follow the political activity in your

 3     country in Serbia, but I was wondering whether today some political

 4     figures talk about Greater Serbia, or is this what -- all those words,

 5     are they no longer used?

 6             THE WITNESS: [Interpretation] As far as I know, currently nobody

 7     in Serbia talks about that.  We are a state under occupation.

 8             JUDGE ANTONETTI: [Interpretation] You say that you're a state

 9     under occupation.  Occupied by whom?

10             THE WITNESS: [Interpretation] NATO.

11             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, please proceed.

12             MS. BIERSAY:  Thank you, Your Honour.

13        Q.   I'm asking you these questions because on page 64 of the

14     transcript, you said -- in response to the question posed by the Trial

15     Chamber, you said:

16             "I don't use that term 'Greater Serbia' at all."

17             Do you remember that?  Do you remember telling the Trial Chamber

18     that?

19        A.   Yes.

20        Q.   But although you now say that you don't use the phrase "Greater

21     Serbia" at all, it was a core part of the language used by the accused in

22     his discourses; is that correct?

23        A.   Mr. Seselj knows why he did that.  I don't know.

24        Q.   I'm not, again --

25        A.   And for me, it's nothing but normal Serbia.

Page 15969

 1        Q.   I'm not asking you to go into his [overlapping speakers] --

 2             THE ACCUSED: [Interpretation] Your Honours, Ms. Biersay insists

 3     on notorious matters that I never denied during these proceedings, and

 4     she's trying to portray the witness as an expert who is now -- you're not

 5     receiving interpretation.  I never contested having used the term.  These

 6     are notorious facts, and now she puts him in the position of an expert

 7     who is here to interpret my words and what I meant when I used them.

 8     That's ridiculous.

 9             JUDGE ANTONETTI: [Interpretation] I don't think that Ms. Biersay

10     is venturing into this area, because I would have cut her off.  She's

11     trying, through her questions, to bring to light something that I'm

12     waiting for, so let's wait and see.

13             MS. BIERSAY:

14        Q.   In paragraph 15 of the statement that's before you, you describe

15     that the Greater Serbia was the concept that was set out in the first

16     goal of the platform of the Serbian Chetnik Movement; isn't that true?

17        A.   Well, I don't know.  I would first have to look at the concept.

18        Q.   Well, look at it:

19             "... the restoration of a free, independent, and democratic

20     Serbian state that would include the whole of Serbdom and all Serb

21     lands."

22             So in your statement --

23        A.   Yes, but I don't see the term "Greater Serbia" anywhere here.

24        Q.   Do you see it in paragraph 15 of your statement?

25        A.   In para 15, yes.

Page 15970

 1        Q.   So you have used that phrase before in your statements?

 2        A.   I may have quoted Mr. Seselj.  This is not my turn of a phrase.

 3     This is not what I would normally use.

 4             MS. BIERSAY:  Do I have time for one more question, Your Honours?

 5     I'd like --

 6             JUDGE ANTONETTI: [Interpretation] If there are no objections, you

 7     have another two minutes, yes.

 8             MS. BIERSAY:  Thank you.

 9        Q.   You told the Trial Chamber that you heard the accused talk about

10     the Geneva Conventions to SRS volunteers.  You told the Trial Chamber

11     that; correct?

12        A.   Yes.

13        Q.   I'd like you to turn to paragraph 35 of that statement, and I'd

14     like you to look at the last two sentences in paragraph 35:

15             "I have never heard Seselj talk of the Geneva Conventions to the

16     SRS volunteers or during any public address.  As far as I can remember,

17     no one from the War Staff ever gave any instructions regarding the

18     treatment of POWs."

19        A.   These are not my words.

20        Q.   So this is a lie?

21        A.   No, this is not true.

22        Q.   And you're looking at the version of the statement in your

23     language; is that correct?

24        A.   This is a statement, but not mine.

25        Q.   You signed that statement; is that correct?

Page 15971

 1        A.   Correct.

 2             JUDGE ANTONETTI: [Interpretation] Very well.

 3             Witness, just a few instructions.  You will be back here at

 4     quarter past 2.00, because we have an afternoon session and my colleague

 5     Judge Harhoff has another hearing in the morning, so we will meet again

 6     in the afternoon.  Until then, please have no contact with anyone, except

 7     for close members of your family.  Please do not talk to journalists or

 8     anybody else, in order to avoid for anyone to say that someone has called

 9     you or threatened you in the meantime.  So please don't answer the phone,

10     unless you have phone calls from your family.  You can watch television,

11     you can read, but do not have any contact with anyone, so that when you

12     come back at quarter past 2.00 tomorrow, it is as if we had a longer

13     break than the ones we've had.  And during the breaks, as you know, you

14     don't have any contact with anyone.

15             Have you understood correctly what I've just said?

16             THE WITNESS: [Interpretation] Yes, I have.

17             JUDGE ANTONETTI: [Interpretation] Very well.

18             I wish you a good evening, as well as to everybody else, and

19     we'll meet again tomorrow afternoon.

20                           [The witness stands down]

21                           --- Whereupon the hearing adjourned at

22                           7.02 p.m., to be reconvened on Wednesday, the 12th

23                           day of May, 2010, at 2.15 p.m.