Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11237

 1                           Wednesday, 10 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.06 a.m.

 5             JUDGE DELVOIE:  Good morning to everyone in and around the

 6     courtroom.

 7             Madam Registrar, could you call the case, please.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is the case

 9     IT-04-75-T, the Prosecutor versus Goran Hadzic.

10             JUDGE DELVOIE:  Thank you.

11             May we have the appearances, please, starting with the

12     Prosecution.

13             MS. BIERSAY:  Good morning, Your Honours.  Lisa Biersay on behalf

14     of the Prosecution, along with STA Douglas Stringer, Case Manager

15     Thomas Laugel, and our legal intern, Moritz von Normann.

16             JUDGE DELVOIE:  Thank you.

17             And for the Defence, Mr. Zivanovic.

18             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

19     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell, along with

20     Ruzica Ciric and Michael Connelly, legal interns.

21             JUDGE DELVOIE:  And the legal advisor for Mr. Seselj.

22                           [Trial Chamber confers]

23                           [Trial Chamber and Registrar confer]

24             JUDGE DELVOIE:  Could -- yes.

25             MR. TERZIC: [Interpretation] Milan Terzic.


Page 11238

 1             JUDGE DELVOIE:  Thank you.

 2             The witness may be brought in.

 3                           [The witness takes the stand]

 4             JUDGE DELVOIE:  Good morning, Mr. Seselj.  May I remind that you

 5     are still under oath.

 6             Ms. Biersay, please continue.

 7                           WITNESS:  VOJISLAV SESELJ [Resumed]

 8                           [Witness answered through interpreter]

 9             THE WITNESS: [Interpretation] Your Honour, would you allow me

10     three minutes, only three minutes, to address the Trial Chamber.  I

11     believe it would be very important for me to do that.  Three minutes

12     only.

13             JUDGE DELVOIE:  Ms. Biersay.

14             MS. BIERSAY:  I apologise.  The Trial Chamber didn't invite me to

15     make comment, but at this time the Prosecution would oppose Mr. Seselj

16     giving a three-minute speech essentially not knowing what is he going say

17     and given his inclination of what we consider to be inflammatory language

18     and speeches.

19             JUDGE DELVOIE:  Mr. Zivanovic.

20             MR. ZIVANOVIC:  I don't know why the Prosecution opposes to this

21     request of Mr. Seselj not knowing what he would say.

22             THE WITNESS: [Interpretation] Your Honour, I don't intend to use

23     any inflammatory words.  I just want to address the Trial Chamber and

24     talk to them for three minutes to provide them with a piece of

25     information.  That's all.  I believe that you will be interested in what

Page 11239

 1     I have to say to you.

 2             JUDGE DELVOIE:  Mr. Seselj, is that a piece of information with

 3     regard to this case?

 4             THE WITNESS: [Interpretation] Yes, with regard to this case, and

 5     the importance of the information is huge.  And it will not be

 6     inflammatory because you can't say anything inflammatory in

 7     three minutes.

 8             JUDGE DELVOIE:  It is not -- for me, the question is not whether

 9     it is inflammatory or not.  The question is this -- these proceedings are

10     party-driven.  The parties decide on what they want to put forward in

11     court.  Mr. Zivanovic decided upon what he would like to ask you and what

12     he did not ask you, so it is not your decision to add information that

13     perhaps Mr. Zivanovic doesn't want you to elicit it -- elicit.  Sorry.

14             THE WITNESS: [Interpretation] Your Honour, this has nothing to do

15     with the examination-in-chief that was led yesterday by Mr. Zivanovic.  I

16     would like to remind you of the proceedings from other cases.

17             In my case, for example, one witness wanted to greet me and we

18     kissed each other in the middle of the courtroom.  There are a lot of

19     such proceedings showing that the Trial Chamber allowed the accused to

20     address them.  I'm only asking for three minutes.  The three minutes are

21     already over.  I would have already finished if the -- if Ms. Biersay did

22     not object.

23             JUDGE DELVOIE:  One moment, please.

24                           [Trial Chamber confers]

25             JUDGE DELVOIE:  You have three minutes, Mr. Seselj.

Page 11240

 1             THE WITNESS: [Interpretation] Your Honours, yesterday Ms. Biersay

 2     claimed that I never put my accusations against Vesna Bosanac face to

 3     face.  I looked at the transcript from my case yesterday evening, and I

 4     realised that at the end of Vesna Bosanac's testimony I asked the floor

 5     and then I lay great charges at her expense.  Judge Antonetti interrupted

 6     me and ordered that everything I had said should be removed from the

 7     transcript.  That's why my words are not in the transcript and his order

 8     is.  And then he apologised to Vesna Bosanac and then he gave us a break.

 9             I'm finishing.

10             After the break, which was a normal break, we had a discussion or

11     a debate for over half an hour involving Judge Antonetti,

12     Prosecutor Mundis, and myself about the principle of using Rule -- and

13     applying Rule 92 ter in the case.  I was right, your professional

14     services may check that, and you can have that on your screens within a

15     minute.  I did speak, I did say, I did confront Vesna Bosanac but

16     Judge Antonetti ordered my words to be erased from the transcript.

17             I have finished and thank you very much.  And it was even less

18     than three minutes.

19             JUDGE DELVOIE:  You want to intervene at this point in time,

20     Ms. Biersay.

21             MS. BIERSAY:  I think the time has passed, Your Honour, but thank

22     you for the opportunity.

23                           [Trial Chamber confers]

24             JUDGE DELVOIE:  Please proceed, Ms. Biersay.

25                           [Trial Chamber and Registrar confer]


Page 11241

 1             MS. BIERSAY:  Thank you, Your Honour.

 2                           Cross-examination by Ms. Biersay: [Continued]

 3        Q.   Good morning, Mr. Seselj.  I'd like to talk to you about your

 4     evidence about the 200 executed at Ovcara.  Do you remember that from

 5     yesterday?

 6        A.   Of course.  I remember everything.

 7        Q.   If -- I'd like to repeat what I understand you to be saying.

 8             If I understand you correctly, you are saying that those

 9     200 remained in the custody of the JNA and that they were never turned

10     over to the civilian authorities; right?

11        A.   Yes.

12        Q.   I understand -- thank you.

13        A.   There is not -- there's not a single piece of evidence that they

14     were turned over.  Ms. Biersay, you have --

15        Q.   You answered my question.  You said yes.  And now I'd like --

16     I'll give you an opportunity, but first, I need to set the foundational

17     questions first.  So I understood that correctly.  Thank you.

18             Now, if I also understand your Milosevic testimony, there it was

19     your testimony that the 200 executed were turned over to the civilian

20     authorities; right?

21        A.   That's what I thought at the time.  I didn't lie.  That was my

22     mindset at the time, based on what I had read in the media up to then,

23     and based on the outcome of the proceedings conducted before the

24     supreme court in Belgrade.

25        Q.   Okay --

Page 11242

 1        A.   I believe General Gojovic was the president of the supreme

 2     military court in Belgrade at that time.

 3        Q.   I see.  If we could now turn to Defence tab 19, I believe it is,

 4     which is 1D02805.  And I'm interested in beginning at page 61.

 5        A.   General Gojovic.  I said it.  It wasn't recorded.  [In English]

 6     "I believe General Gojovic was the president of the supreme ..."

 7             MS. BIERSAY:

 8        Q.   Now --

 9             JUDGE DELVOIE:  Mr. Zivanovic.

10             MR. ZIVANOVIC:  I would object, Your Honours.  The same document

11     I tried yesterday to show to the witness and the Prosecution objected,

12     and I object on the same ground.

13             MS. BIERSAY:  I am showing his previous inconsistent statement

14     which is perfectly admissible, I would think, in -- during

15     cross-examination.

16             JUDGE DELVOIE:  Just one moment, Mr. Zivanovic.  Yes,

17     Mr. Zivanovic.

18             MR. ZIVANOVIC:  I think it is -- it was quite legitimate for me

19     to show the witness and explore this issue with him during

20     my examination-in-chief, and I don't believe that different -- different

21     standards should be applied to the Prosecution.

22             MS. BIERSAY:  May I, Your Honour?

23             JUDGE DELVOIE:  Yes, Ms. Biersay.

24             MS. BIERSAY:  Thank you.  My memory, if it serves me properly, is

25     that my objection was based on the manner in which Mr. Zivanovic was

Page 11243

 1     trying to use this, and it was an issue of memory, if the Trial Chamber

 2     recalls, because the Trial Chamber did deliberate on this point.

 3             MR. ZIVANOVIC:  As far as I recall, the Prosecution opposed to

 4     the -- to the use of this document to -- and to explore with the witness

 5     something that was in this document.

 6             JUDGE DELVOIE:  Indeed, Mr. Zivanovic, for the reason Ms. Biersay

 7     mentioned, and now is there different reason.  The objection is

 8     overruled.

 9             MS. BIERSAY:

10        Q.   So I know that before you -- it sounds like your English is quite

11     good and the transcript before you is in English, and I will read it in

12     English and they'll translate it for you just so I can put it on the

13     record.

14             So this --

15        A.   [Interpretation] I don't understand a word of English.  I can

16     only speak English.  I cannot listen to the English language.  Everything

17     has to be translated into Serbian for me.

18        Q.   Understood.  Let me begin at page 43604 of this transcript, which

19     is your testimony in the Milosevic case on 1 September 2005.  And you

20     were asked a question about the events relating to Ovcara.  And this was

21     your answer:

22             "A.  I know something about these events because I made efforts

23     to find out, but I'm not an eye-witness.  And what I found out is rather

24     reliable; namely that the authorities of the Autonomous District of

25     Eastern Slavonia, Baranja, and Western Srem asked the JNA that some

Page 11244

 1     prisoners from the Vukovar Hospital be turned over to them, with a demand

 2     that they be tried for the crimes that they had previously committed over

 3     the civilian population of Vukovar.  And the information I got is that a

 4     certain number - I don't know exactly how many - of those prisoners were

 5     turned over to them, after which the prisoners were taken to the farm

 6     called Ovcara whereupon the execution of those prisoners occurred.

 7             "Q.  From all that you managed to find out, who was involved?

 8     Was the JNA involved in any way?"

 9        A.   Ms. Biersay --

10             MS. BIERSAY:  Your Honour, I would object to this.  I have not

11     finished reading.  And I don't know what Mr. Seselj is pulling out of his

12     briefcase and we would strongly object to this procedure.

13             JUDGE DELVOIE:  Mr. Seselj, you -- indeed, you should wait for

14     the questions to put to you.  And may we ask what you are pulling out of

15     your briefcase?

16             THE WITNESS: [Interpretation] I sincerely thought that

17     Ms. Biersay had finished reading, and I started answering her question.

18     And as for my briefcase, this is a previous statement --

19             JUDGE DELVOIE:  There was -- Mr. Seselj, there was no question at

20     all.  She was still reading, and even if she finished reading, there was

21     no question yet.  And say again, please, what is it you took out of your

22     briefcase?

23             THE WITNESS: [Interpretation] What I've pulled out are

24     two folders.  In one of them, there is a statement that I gave

25     Mr. Zivanovic, Mr. Hadzic's legal representative.  And in the other,

Page 11245

 1     there are several documents, including copies of my book, "The Defence

 2     Witness for Slobodan Milosevic in The Hague."  I published my entire

 3     testimony and I photocopied those parts which Ms. Biersay is partly

 4     quoting from.  She's not quoting the entire thing.  She has chosen only

 5     some parts to quote from.  If you want me to take -- put them back into

 6     my briefcase, I can do that.  I can also offer to make photocopies for

 7     you, because I myself published that book and it was published in

 8     21.000 copies.  It was published in English.  It's available on the

 9     Internet.  I can provide you with all of that.

10             JUDGE DELVOIE:  We would appreciate, Mr. Seselj, if you would put

11     the documents back in your briefcase as you offered to do.

12             The parties, of course, know all of this, and I repeat once

13     again, that the -- the proceedings are in the hands of the parties.  They

14     decide on what they want to show to Court, what they want to ask you, and

15     what they want to hear from you as the truth as you know it.

16             Please continue, Ms. Biersay.

17             MS. BIERSAY:  Thank you, Your Honour.

18        Q.   "Q.  From all that you managed to find out, who was involved?

19     Was the JNA involved in any way?

20             "A.  According to my information, not a single officer of the JNA

21     was involved.  And from what I learned, it was some locals who did it,

22     who had some outstanding accounts with the prisoners, but I have no

23     direct knowledge about" --

24             MS. BIERSAY:  This is -- if we could continue.  I've stopped

25     reading.  If we can continue to the next page, which is page 61 in

Page 11246

 1     e-court.

 2             "... but I have no direct knowledge about it because I wasn't

 3     there."

 4        Q.   You also continued, Mr. Seselj, to say:

 5             "I dealt with it because it was one of the charges in my

 6     indictment, so I had to research it extensively and my experts are

 7     working on it, and the knowledge I have was obtained actually by my

 8     expert."

 9             Now, you go on to talk about Aleksandar Vasiljevic, and Judge

10     Kwon asked you about this first-hand information that you said you had:

11             "What do you mean by first-hand, Mr. Seselj?"

12             And you replied:

13             "I learned from people who were there.  There is reliable

14     information that I got because I dealt with this question, in a way."

15             And Judge Kwon asked you:

16             "From whom did you hear that?"

17             And you answered:

18             "I talked to a large number of people.  I talked, in particular,

19     to the commander of the Leva Supoderica Unit, Milan Lancuzanin, also

20     known as Kameni.  I couldn't even tell you the names of all the people

21     with whom I discussed it."

22             That's what you said in the Milosevic case; correct?

23        A.   I demand that I may be allowed to answer as extensively as the

24     question was.  You did not put it on paper so it is not easy for me

25     remember everything you said.  You want me to start answering

Page 11247

 1     immediately?

 2        Q.   My question to you is simply:  By hearing the interpretation that

 3     you had, is that what you said during the Milosevic trial?

 4        A.   You have made here a compilation of my statements made during

 5     that testimony.  You cherry-picked what you believe necessary to put

 6     forward now but you left certain things out.  For instance, I see that

 7     one sentence is missing here, that my investigators are still working on

 8     it.  Why did you omit that?  It is in my statement.  It is also in the

 9     transcript.  I mean in the recording of my testimony.

10             Now, my knowledge up to that moment was as follows.  I mentioned

11     yesterday Milan Lancuzanin known as Kameni.  I insisted on finding out

12     from him whether the volunteers of the Serbian Radical Party had been

13     involved.  He said no.  I also had consistent information from the media

14     that all the prisoners had been handed over.  And, third, there was the

15     investigation, the inquiry, carried out in Belgrade and such was the

16     outcome.

17             I studied it the first years I've --

18        Q.   Thank you, Mr. Seselj --

19        A.   -- spent in The Hague but at that time I did not have legal

20     advisors and no privileged communication.

21        Q.   One moment, please.  I understand this because you explained it

22     extensively to Mr. Zivanovic, and I -- you answered my question that

23     this, in fact, is information that you gave the Trial Chamber in the

24     Milosevic case.  I understand your position about that.

25             My question to you is:  Do I understand you correctly that you're

Page 11248

 1     saying that your information is more accurate now than it was in 2005,

 2     when you testified?  Yes or no, your information is more accurate now?

 3        A.   Now I have incomparably more accurate information, but I'm not

 4     ever going to answer you with a yes or no because this is not a TV quiz.

 5     I am testifying here with full awareness of the importance of my

 6     evidence, and you cannot manipulate me as you do other witnesses.

 7        Q.   Thank you, Mr. Seselj.  So, Mr. Seselj, is it fair to say that

 8     you tailor the facts to exonerate yourself or certain accused charged

 9     before this Tribunal?

10        A.   I have never tailored any fact in favour of my own Defence or the

11     Defence of Mr. Milosevic, Mr. Karadzic, or Mr. Hadzic.  I found out here

12     in The Hague and Sljivancanin confessed in his own case that he had

13     brought the buses with prisoners to Ovcara; whereas I had earlier thought

14     that the prisoners had been handed over to the civilian authorities in

15     the Vukovar barracks.

16             Here you called many witnesses in my trial and you provided me

17     with their statements, statements of victims, survivors from Ovcara,

18     Emil Cakalic and others, from which it is evident that the JNA officers

19     were at Ovcara all the time.  They compared lists.  They released them,

20     et cetera.

21             So you subsequently showered me with information here that runs

22     counter to what I had thought.  Now the first witness in my trial,

23     Goran Stoparic --

24        Q.   Mr. Seselj -- Mr. Seselj, one moment, please --

25        A.   [Overlapping speakers] ... recounted here how he had made

Page 11249

 1     arrangements with Kameni --

 2        Q.   One moment, please.  I think you have answered my question loud

 3     and clearly.  And --

 4        A.   You may think so, but I didn't.  I have one more sentence.

 5     Please, do not run away from the truth.

 6        Q.   One more sentence, okay.

 7        A.   [In English] One more sentence.

 8             [Interpretation] Goran Stoparic stated here that he, Kameni, and

 9     Kinez got together on somebody's instructions or somebody's demand over

10     there, I can't remember who, to agree how they should testify, give the

11     same evidence to exonerate Sljivancanin.  Before I heard him --

12        Q.   Mr. Seselj --

13        A.   -- I had completely different information.  I was taken aback.  I

14     was surprised.  You're again running away from the answer.

15        Q.   Thank you.  I'd now like to, if we could -- I believe this is

16     tab 100, which is 65 ter 4955.1.  And this is a video-clip.  And pursuant

17     to our internal protocol, I wanted to check with the interpreters to see

18     if they have been able to locate the transcript for this video, 4955.1,

19     which, for the record, is an extract from the main exhibit, from

20     30 minute, 08, to 31 minute, 11, and I believe --

21             THE INTERPRETER:  We have it.

22             MS. BIERSAY:

23        Q.   So before we start playing, Mr. Seselj, I'd like you just to take

24     a look at this video.  And then after it's finished, I'll ask you some

25     questions about it.

Page 11250

 1                           [Video-clip played]

 2             THE INTERPRETER: [Voiceover] "These are our volunteers who are

 3     part of the Territorial Defence.  We haven't got any units of our own

 4     here.  All the people are our people.  All the units here are our units.

 5     And, of course, those who came here of their own will to fight, know full

 6     well why they are here and what they're fighting for, and they don't need

 7     to be persuaded to fight because they themselves wanted to do so.  And

 8     therefore one should not be surprised at their courage.

 9             "Q.  How significant is the liberation of Vukovar for Serbia and

10     the Serbian people?

11             "Vojislav Seselj:  It is of exceptional significance, exceptional

12     significance.  This is the most powerful Ustasha stronghold.  Once

13     Vukovar is taken, Ustashas have no chance of saving either Osijek or

14     Vinkovci.  There is nothing to stop our forces.  Vukovar is the key line

15     that needs to be broken through, that needs to be captured, and then

16     there will be nothing Ustashas can do.  The Ustashas know that if Vukovar

17     falls here, if Slunj falls in Serbian Krajina, then Tudjman's Ustashas

18     regime in Zagreb will fall too.  And that is why this battle is

19     decisive."

20             MS. BIERSAY:

21        Q.   You recognised yourself, of course, I take it.

22        A.   Ms. Biersay, I'm impressed at how good I looked and how well I

23     spoke at that time, and I hope that you are impressed too.

24        Q.   But, of course.  Now, Mr. Seselj, do you recall the occasion on

25     which you gave this interview?  According to our information, it was not

Page 11251

 1     long before the liberation of Vukovar.

 2        A.   It couldn't have been after 8 November.  It could have been

 3     during my first visit in October, or during my second visit, on the

 4     8th of November.  It couldn't have been later.  And Vukovar was liberated

 5     on 18 November; that is to say, ten days later.

 6        Q.   And it's accurate at the time, was it not, that the volunteers,

 7     "our volunteers," your volunteers, made up a part of the Territorial

 8     Defence?

 9        A.   And the Territorial Defence was part of the Motorised Guards

10     Brigade, completely integrated into their complement.  And the

11     1st Assault Detachment, which participated the most in the fighting for

12     Vukovar, was made up, if I remember well, of three companies of the

13     Guards Brigade, two companies of the Territorial Defence, and the

14     detachment called Leva Supoderica.  That was the composition of the

15     assault detachment commanded by Major Borivoje Trajkovic.  This is

16     exhaustive information, and this is something that I witnessed.

17             MS. BIERSAY:  At this time, the Prosecution tenders

18     65 ter 4955.1.

19             JUDGE DELVOIE:  Admitted and marked.

20             THE REGISTRAR:  Exhibit P3556, Your Honours.

21             MS. BIERSAY:  I'd now like to turn to a document --

22             THE REGISTRAR:  I apologise.  3256.  Thank you.

23             MS. BIERSAY:  A document which has already been admitted as

24     P2625, and it's tab 38.

25        Q.   Now, you can see it already on your screen, Mr. Seselj, and --

Page 11252

 1        A.   Could you make it a bit larger?  I don't see very well.

 2        Q.   Is that better?

 3        A.   Now I recognise the document, but I can't read it very well yet.

 4        Q.   Slobodan Katic, his name appears at the very bottom.  You know

 5     who that is; right?

 6        A.   Yes.

 7        Q.   And who is it?

 8        A.   Slobodan Katic was the commander of a group of volunteers that

 9     had arrived with him from Belgrade and was integrated into the

10     Leva Supoderica Unit.  Because of his merits in the war, I later

11     proclaimed him a Chetnik vojvoda, duke, too.  However, when Vukovar was

12     liberated, he stayed to live in Vukovar and he got married there.  And I

13     believe he continued to live there until the Croats recaptured Vukovar

14     again in the beginning of early 1996, if I'm not mistaken.

15        Q.   Now this document is dated 9 December 1991, and it's a request

16     for promotion for the people listed below; right?  So you have Katic and

17     he's proposing -- he's asking the chief of the War Staff,

18     Ljubisa Petkovic and his deputy Zoran Rankic from Belgrade to propose the

19     following warriors for promotion, right?  That's what's happening in this

20     document?

21        A.   Ms. Biersay, this document did not exist at the War Staff.  It

22     was never registered in the protocol.  It was the private property of

23     Ljubisa Petkovic and he turned it over to the OTP, to the investigators.

24     Indeed, Slobodan Katic did address Ljubisa Petkovic and his deputy asking

25     for the promotion of all these people but they are not members of the

Page 11253

 1     Serbian Radical Party, and I cannot understand what kinds of sentiment

 2     this reflects, whether Ljubisa Petkovic was supposed to influence somehow

 3     his connections in the War Staff or what.  None of them was in the

 4     Leva Supoderica Unit, except for Milan Lancuzanin, known as Kameni, and

 5     Kameni was in the first group that I proclaimed Chetnik vojvodas.  I

 6     don't know any of the other people.

 7        Q.   Now, this is not a request to the JNA for promotion to these

 8     people; right?  This request is going to the chief of the SRS War Staff

 9     and Zoran Rankic, not to the JNA?

10        A.   Ms. Biersay, ignorant, unschooled people are incapable of using

11     the proper form when they write something.  Slobodan Katic did not have

12     much schooling.  He was a good warrior but not very educated.  We did not

13     have any agreement with the JNA, and the first officer ranks were granted

14     by Duke Momcilo Djujic on the 13th of May, 1991, at Ravna Gora, and he

15     promoted into officers all members of our volunteer group that had fought

16     in Borovo Selo.  There are more cases -- was I now cut off?  There are

17     more cases.  It's important for me to tell you this.

18        Q.   One moment, Mr. Seselj.  We'll get there.  But what I wanted to

19     do now is to show you another document, which is tab 35, P2576.  And

20     while we're waiting for it to be brought to the screen, it is dated

21     9 November 1991.

22             And the signature at the bottom is -- it's written that this is

23     Ljubisa Petkovic signing this document.  And it's addressed to the

24     commander of the Leva Supoderica Detachment.  And in the first

25     paragraph it notes that:

Page 11254

 1             "All the volunteers that the Serbian Radical Party has sent you

 2     are being placed under your command and the protection of the Vukovar TO.

 3     The SRS War Staff has appointed Slobodan Katic, a brave and experienced

 4     soldier from Belgrade, as the commander or the komandant of the

 5     volunteers in Vukovar."

 6             Is that consistent with the information that you have?

 7        A.   It is not clear enough.  Slobodan Katic was appointed by the

 8     War Staff as commander of the group that had arrived with him on the

 9     9th of November.  Ljubisa Petkovic knows about the order of the commander

10     of the Guards Brigade to send volunteers to the unit.  This group of

11     volunteers was taken to Bubanj Potok.  They got weapons there and

12     uniforms, and they were bussed to Vukovar.  This is a letter that he was

13     sending with Slobodan Katic.  I don't see anything odd about it.  It's

14     not perfectly articulate or literate, but I don't see anything

15     problematic about the content.

16        Q.   I'd like to show you another video-clip.

17             MS. BIERSAY:  And if I could just check with the interpreters

18     before we get there, it would be 88 -- P88.50.

19                           [Prosecution counsel confer]

20             THE INTERPRETER:  We've got it.  In fact, we have two of them:

21     50.3 and 50.8.

22             MS. BIERSAY:  Thank you.  Thank you.  And could I also confirm

23     that the interpreters have P1740?

24             THE INTERPRETER:  Yes.

25             MS. BIERSAY:  Thank you.

Page 11255

 1        Q.   Mr. Seselj, some of your very early contacts with people in

 2     Borovo Selo was with Vukasin Soskocanin.  Excuse me for my pronunciation.

 3     Do you recall that person, Soskocanin?

 4        A.   I remember Vukasin Soskocanin very well.  He was the commander of

 5     the Territorial Defence of Borovo Selo.  And the last time I saw him was

 6     in April 1991, when we agreed about the integration of volunteers.

 7        Q.   And in your -- you recall giving an interview for the documentary

 8     "Death of Yugoslavia" to Laura Silber?

 9        A.   Yes.  I gave that interview.  It was more than 30 minutes and

10     they actually used only five minutes.  But I published the entire

11     interview in one of my books.  I could not allow all the smart things I

12     said to go unheard.

13        Q.   You describe in that interview that he provided your volunteers

14     with weapons; is that correct?

15        A.   Vukasin Soskocanin?  Yes.  Our volunteers went there wearing

16     civilian clothes and no weapons.

17        Q.   And you explained that later on you developed contacts with the

18     Serbian police and also with the General Staff of the JNA.

19        A.   Ms. Biersay, those were our contacts, of course, but all these

20     contacts were done through Ljubisa Petkovic.  I was never in the security

21     service or the Serbian police in general or the General Staff of the JNA.

22     And I never personally visited the General Staff of the Army of

23     Yugoslavia, the VJ.  But we did have these contacts on a number of

24     issues.

25        Q.   Sure.  So you would have people who worked for you deal with

Page 11256

 1     contacts with other people.  You didn't do everything yourself.  Is that

 2     what you're saying?

 3        A.   Well, yes.  You see, Ljubisa Petkovic went as one of my men both

 4     to the State Security Service and the General Staff, and then, in the

 5     meantime, the State Security Service recruited him to work for them

 6     against the party.  And when I heard about that, I interrogated

 7     Ljubisa Petkovic before TV cameras and after that he was expelled from

 8     the party.  And he confirmed all that.  He even confirmed that the

 9     State Security Service had given him a car for his use, and he took out a

10     driving licence on which was written "the MUP of Serbia," the Ministry of

11     the Interior.

12        Q.   He was expelled from the party.  But you had a reconciliation

13     during the course of your trial; right?

14        A.   Ljubisa Petkovic was questioned by OTP investigators several

15     times.  He provided very extensive statements.  He provided documents

16     that he had in his possession, that is to say, documents he had had at

17     home, and he collaborated with the OTP all the way up until the

18     Security Council decided that no new indictments could be raised.  In

19     fact they decided that all the indictments had to be issued by the

20     beginning of 2005.

21             Ljubisa Petkovic was scared because he was threatened with an

22     indictment.  He was very co-operative with investigators until that time

23     and he even brought them new witnesses for interview.  However, when he

24     realised that there could be no indictment against him any longer, he

25     addressed my assistants.  He offered his co-operation and assistance, and

Page 11257

 1     he gave them even a copy of a long interview he had given to OTP

 2     investigators, and that was in 2006 --

 3        Q.   Mr. Seselj --

 4        A.   -- and that is pure truth.  And, of course, we embraced him

 5     because he was useful.

 6        Q.   He was useful.  And in fact, Mr. Petkovic refused to testify in

 7     your trial as either a witness for the Prosecution or a witness for the

 8     Trial Chamber, and he was convicted of contempt for that.

 9        A.   Yes.  And that was the reason why after a while we appointed him

10     a Member of Parliament.  One MP happened to die after the elections.

11     That was Dragan Tasic, a legal assistant of mine.  He was a graduate of

12     the --

13        Q.   [Previous translation continues] ...

14        A.   -- university in Montpellier.  He spoke perfect French,

15     et cetera.

16        Q.   Thank you, Mr. Seselj.

17        A.   When he died, we rewarded Ljubisa Petkovic by offering him his

18     seat in the parliament.

19        Q.   It's been brought to my attention that I think at transcript

20     page 15 what's written is "Borivoje Trajkovic" in relation to the

21     commander of the 1st Assault Detachment.  Do you recall the commander?

22        A.   Certainly.  Many newspapers published our photograph during our

23     inspection of the front line in Vukovar, and I even said that, on one

24     occasion, Borivoje Trajkovic complained that he had had a lot of trouble

25     because of that photograph because when we made an alliance with

Page 11258

 1     Milosevic, he got into trouble over that --

 2        Q.   Mr. Seselj --

 3        A.   -- he later became commander of the gendarme service and a

 4     general.  I want to provide you with complete information.

 5        Q.   Is the name Borivoje Tesic familiar to you?

 6        A.   Sorry, it's my mistake.  It's not Borivoje Trajkovic.  It's

 7     Borivoje Tesic.  He was the commander of the 1st Assault Detachment.  It

 8     was my slip of the tongue.  He posed for a photograph together with me at

 9     that time, and it was published in all the newspapers.

10        Q.   I'd like to --

11        A.   I misspoke because there was also a man called

12     Borivoje Trajkovic.

13        Q.   Mr. Seselj -- I understand.

14             MS. BIERSAY:  If the interpreters could now go to the P1740.

15             May I just have a confirmation.  I know you said it before, I

16     just -- directing my comments to the interpreters.  I just want to make

17     sure.

18             THE INTERPRETER:  Yes, we have it.

19             MS. BIERSAY:  Thank you.

20             At this time I'd like to play P1740, which is also tab 129.

21                           [Video-clip played]

22             THE INTERPRETER: [Voiceover] "Dr. Vojislav Seselj, president of

23     the Serbian Radical Party, visited Borovo Selo today.

24             "Seselj:  The Serbian people located in the most endangered areas

25     have to persevere.  They have to show as much patience and will as

Page 11259

 1     possible as they are bearing a heavy burden.  Most things depend on their

 2     strength, courage, and determination.

 3             "Reporter:  Are the units of your party ready to help at this

 4     moment?

 5             "Seselj:  We have no party units.  What we do is organising the

 6     registration of volunteers in Serbia and then sending them where they are

 7     needed; i.e., they are going to the villages where they are asked to come

 8     by Serbian villagers and they're immediately joining the local units

 9     under the command of the village staff.  That means that we do not have

10     any special units in this region nor do we have the need for them.  We

11     are all Serbs regardless of the party affiliation.  We are not taking

12     into account the party divisions until the borders of Serbia are secured.

13             "Reporter:  Vojislav Seselj, president of the Serbian Radical

14     Party, met with the Orthodox bishop Lukijan from the ... Osijek-Polje,

15     who, among other things, said the following:  All Serbs must be unanimous

16     as that is in their best interest.  Enough with the divisions."

17             MS. BIERSAY:

18        Q.   And so, Mr. Seselj, this is an accurate reflection of what was

19     happening at the time.  Namely that your volunteers were being asked to

20     go to certain villages; is that correct?

21        A.   I spoke about that yesterday and I'm confirming it today.  Yes,

22     this clip was taken in Borovo Selo in April.  I suppose.  First we sent

23     them to Borovo Selo and then we started selling [as interpreted] them to

24     other endangered villages.  I can give you some of the names of those

25     villages, if you wish, if you are interested.

Page 11260

 1        Q.   Yes, please, tell us just the names of the villages that you

 2     remember.

 3        A.   Trpinja, Tenja, Mirkovci, Laslovo, and Ernestinovo.

 4     Tomislav Nikolic, the current president of the Republic of Serbia, also

 5     fought there, and as a result, he was also bestowed the title of a

 6     Chetnik vojvoda.  There are other villages that I can try and remember.

 7        Q.   Regarding your comment about Mirkovci, if I could now please turn

 8     to tab 150, and this is P1741.  I think this relates to what you're

 9     describing.

10        A.   I don't see anything yet.

11        Q.   Some patience, please.

12             And this appears to be coming from the Mirkovci local community

13     going to the Serbian Radical Party in Belgrade.  Can you see that?

14        A.   Yes.  It was signed by Zoran Beldar who was the president of the

15     local commune of Mirkovci.  He thanked us for our assistance consisting

16     of our volunteers who were sent there.  He emphasises three persons who

17     played an especially prominent role -  Kosta Carina, Nenad Vukanovic,

18     Ranislav Dragojlovic.  I can tell that you that Kosta Carina was their

19     leader, and I can tell you that they captured the state-of-the-art

20     Armbrust rocket-launcher which is used in antitank struggle.  They

21     brought it to my office in Belgrade.  We held a press conference and we

22     demonstrated that piece of weaponry and that was aired on all Serbian

23     television channels.  Maybe Ljubisa Petkovic could have provided with you

24     that clip because he was the one who kept them.  I fully confirm this

25     information.

Page 11261

 1        Q.   One clarification, Mr. Seselj, because the last name is not yet

 2     entered on the transcript.  For Zoran.  You said:  "The president of the

 3     local community was Zoran," could you spell the last name, please, for

 4     the record.

 5        A.   Beldar.  That's his -- [In English] Beldar, B-e-l-d-a-r.

 6     [Interpretation] You see how good I am spelling, Ms. Biersay?  I don't

 7     speak English at all, but I can spell.

 8        Q.   Quite remarkable.  Mr. Seselj, could you describe for us your

 9     view about whether or not Baranja is, in fact, Croatian territory

10     historically.

11        A.   Baranja was never Croatian territory, absolutely never.  It was

12     part of Hungary.  It did not belong to any of the counties which

13     subsequently became parts of Croatia.  It never belonged to the county of

14     Slavonia, for example.  After the First World War, a great national

15     council of Serbs and people from Bunjevo [phoen] called Bunjevci --

16     Bunjevci are a Slav people very close to us Serbs.  They met -- Bunjevci

17     have their idiosyncrasies in their culture and language and they reached

18     a decision that Banat, Backa, and Baranja would directly join Serbia.

19     After the Second World War, however, the Communists made Baranja a

20     Croatian territorial unit.  Croats will have to return Baranja and all

21     the other Serbian lands to us, sooner or later.

22        Q.   So am I correct that in your view, Baranja properly belongs to

23     the territories that belong to Serbs?

24        A.   Yes, of course.

25        Q.   Now, you describe the famous line that is the western border of

Page 11262

 1     what would be Serbian lands, the one that runs through Croatia.

 2        A.   Yes, this is the line Karlobag-Ogulin-Karlovac-Virovitica.  And

 3     that line actually is why I should go down in history.

 4        Q.   I'd like to direct your attention to a document and -- tab 118,

 5     previously admitted exhibit 2955.2913.  This is a newspaper article, and

 6     it doesn't ...

 7        A.   Again, I can't see it yet.

 8        Q.   Can you see it now?

 9        A.   [In English] No.

10        Q.   Okay.  It's coming.  Can you see it?

11        A.   Again, this has to be enlarged.  I think that only the text you

12     are interested in should be on the screen.  It would automatically be

13     larger, and I would be able to read it then.

14        Q.   I am interested in the article called:  "Western borders of

15     Slavonia now open."

16        A.   As I can see, this is Goran Hadzic's press conference, but I

17     cannot read the text.  If you want my comments on the text, you will have

18     to provide me with a hard copy of the article.  The letters are too small

19     for my age.

20             JUDGE DELVOIE:  Mr. Zivanovic.

21             MR. ZIVANOVIC:  Your Honours, I would just let you know we have

22     it in hard copy in original size and we could provide it to the witness,

23     but not right now from -- approximately for several minutes.

24             MS. BIERSAY:  It's fine.

25             JUDGE DELVOIE:  Ms. Biersay.

Page 11263

 1             MS. BIERSAY:  I'll move on in a different way.  In the same

 2     document could we scroll into the English -- to the English translation,

 3     please.

 4        Q.   I am -- perhaps can you see.  It's the section that says:

 5     "Ilija Petrovic."  If you can't see it, I'll read it to you.

 6        A.   Yes, I can see that.

 7        Q.   Now, it says "Ilija Petrovic" who is identified as the

 8     information minister.  You knew him; correct?

 9        A.   I can't remember him.  Yesterday I mentioned Ilija Petkovic and

10     Ilija Koncarevic.  Ilija Petrovic, that doesn't ring a bell.  I don't

11     know that I ever met him.  His deputy was Rade Leskovac.  He was well

12     connected on Serbian TV.  That's why he was very often seen giving

13     statements instead of the minister himself.  I may have met him but I

14     can't remember.

15        Q.   I'd like to read you -- into the record what this says.  It says:

16             "The information minister in Hadzic's government recalled that

17     the proposal of the Serbian National Council of these districts was to

18     establish the contentious western border along Ilova-Virovitica stretch

19     if necessary by moving the Serbian and Croatian population [sic]."

20             And my question to you:  The Ilova-Virovitica line would be the

21     very northern-most boundaries of the line that you mentioned earlier, the

22     one for which you should go down in history?

23        A.   This line is much more modest than mine.  Less challenging or

24     demanding, if you will.  My line comprises a lot more, significantly a

25     lot more territory.  That's why I will go down in history and not

Page 11264

 1     Ilija Petrovic.

 2        Q.   Your line, of course, also cuts down over in the Knin Krajina

 3     area; right?

 4        A.   Ms. Biersay, with regard to Slavonia itself, my line encompasses

 5     much more territory than the one starting in Ilova.  If you look at the

 6     line Karlobag-Ogulin-Karlovac and then onwards to Virovitica, you will

 7     see that that comprises a lot more territory than the Ilova-Virovitica

 8     line.  If you had a map, I could show it to you on the map.

 9        Q.   What I'd like to ask you about is the idea of population

10     exchanges.  You have previously said that you advocated population

11     exchanges in certain situations; correct?

12        A.   Ms. Biersay, you charged only me with that.  Although many people

13     advocated that.  In Croatia it started with Tudjman.  Dobrica Cosic

14     adopted that idea.  There was a meeting somewhere on the Adriatic coast,

15     I don't know where exactly.  He actually met up with Tudjman in order to

16     agree that.  It was to be a civilised exchange of population where

17     differences could not be reconciled.  It was a repeating theme.  I was

18     not the only one.  Ilija Petrovic was not the only one who mentioned it.

19     Many, many politicians - more of them on the Croatian side than on the

20     Serbian side - kept on mentioning that.  The Croats were the ones who

21     started mass expulsion of the Serbs in 1990 already, and later on they

22     decided to put forth that proposal.

23             JUDGE DELVOIE:  Ms. Biersay --

24             MS. BIERSAY:  Yes, Your Honour.

25             JUDGE DELVOIE:  -- just to clarify, is -- or was this question

Page 11265

 1     still based on the document we have in front of us at the moment?

 2             MS. BIERSAY:  Not regarding Mr. Seselj's own views about the

 3     population exchange, and it was based on the attribution to Petrovic

 4     about moving the Serbian and Croatian population.

 5             JUDGE DELVOIE:  My concern was the word "exchange" and

 6     "exchanging," because in this document, it said "moving."

 7             MS. BIERSAY:  Exactly.  So my question to Mr. Seselj was about

 8     his view of population exchanges.

 9             JUDGE DELVOIE:  But not about population moving.

10             MS. BIERSAY:  No, Your Honour.

11             JUDGE DELVOIE:  Thank you.

12             MS. BIERSAY:  Thank you.

13             If I could now have --

14             THE WITNESS: [Interpretation] Ms. Biersay --

15             MS. BIERSAY:

16        Q.   There's no question yet, Mr. Seselj.  If you could wait for

17     one minute while I show you another document, which I believe is

18     tab 11 --

19             JUDGE DELVOIE:  Ms. Biersay, the document -- the hard copy --

20             MR. ZIVANOVIC:  We provided the document [overlapping speakers]

21     --

22             JUDGE DELVOIE:  The hard is there.

23             MS. BIERSAY:  It's okay.  I've finished.  I don't need it

24     anymore.  Thank you.

25             JUDGE DELVOIE:  You've finished the document.

Page 11266

 1             Thank you, Mr. Zivanovic.

 2             THE WITNESS: [Interpretation] But I did not fully answer your

 3     question.  I did not give you a full answer.  It says:  "Moving the

 4     Croatian and Serbian populations."  This is an exchange.  If it was only

 5     Croatian or only Serbian, it would be a different thing.  However, if the

 6     populations of two ethnic groups move at the same time, this constitutes

 7     an exchange.  It is not done subsequently.  It is done at the same time,

 8     one move to the place from which the others have moved out.  That's an

 9     exchange.

10             MS. BIERSAY:

11        Q.   So I take it that you agree with what Ilija Petrovic is saying in

12     this article.

13        A.   No.

14        Q.   And in what way do you disagree with him?

15        A.   I don't agree with him at all.

16        Q.   And in what way do you disagree with him?

17        A.   I don't agree in terms of the western border of the Serbian

18     Slavonia or in terms of people moving out.  It was only in 1992 that I

19     started advocating the idea of the exchange of population when

20     300.000 Serbian refugees and displaced persons arrived in Serbia.  In

21     1991, I believe that I was never in favour of this idea, unless you have

22     something to prove that I did.  It was only when Serbia was swamped with

23     refugees from Croatia that I started advocating the idea of the exchange

24     of population as a partial solution to the problem.

25             MS. BIERSAY:  If I could now have tab 60, which is 65 ter 155.

Page 11267

 1        Q.   And, Mr. Seselj, this is a transcript of an interview given on

 2     24 May 1991 with you called:  "Chetnik revenge will be blind."

 3             Do you recall that?

 4        A.   I remember it, and yes, the revenge will be blind.  That's what I

 5     said.

 6        Q.   And if we could go to -- actually, Mr. Seselj, we'll come back to

 7     this document.

 8        A.   So should I retain it in my memory until then?

 9        Q.   No, no need.

10             MS. BIERSAY:  I'll move to another 65 ter number, which is

11     65 ter number 6613.  And for the Trial Chamber, that is tab 138.  If we

12     could go to the second page in the English.

13        Q.   So I am interested in the portion that begins:  "However

14     regarding Croatia," and I think it begins at the bottom of the page that

15     you're looking at in Serbian.  Do you see it?  It says:

16             "However, regarding Croatia, we, the Serbian Chetniks, are

17     constantly telling to the new Ustasha leader Franjo Tudjman ..."

18             Do you see that, Mr. Seselj?

19        A.   Again, can this be enlarged just a little?  Can you highlight

20     only that part and put it on the screen?

21        Q.   Is that any better?

22        A.   Why don't you read it and I will listen.

23        Q.   So you can't see it?

24        A.   With difficulty.  You read it.

25        Q.   You say here:

Page 11268

 1             "The new Ustasha leader, Franjo Tudjman, and the new Ustasha

 2     authorities in Croatia not to play games with the Serbian people that

 3     lives in the areas of the present improvised Croatian state community.

 4     This is the Serbian territory, populated by the Serbian people, and we

 5     shall never allow it to be separated from its mother country.  The Croats

 6     may separate themselves from Yugoslavia; in other words, they may have an

 7     independent state, may merge with someone else.  However, they must know

 8     at all times that at all costs that the price of new rivers of blood, we

 9     shall not let them separate any territory that contains Serbian villages,

10     Serbian mass graves, Serbian slaughter-houses, Serbian pits, Serbian

11     camps, Serbian Jasenovac, destroyed Serbian churches.  We shall never

12     allow that."

13        A.   You should now show the last page of the interview.  We need to

14     see the date.  Or perhaps you can just give us the date.  Please take a

15     look and give us the date.  And then I'll just pretend that I believe

16     you.

17             There should be the date on the last page and the place where

18     this was published or the name of the journalist, or perhaps it was a TV

19     show.  I'm sure that it was a TV show but -- because it says "presenter."

20             Do you have the entire interview?

21        Q.   We do but not in our electric electronic system and I can get

22     that after the break.

23             But my question to is now is:  Based on what I've just read, it

24     sounds like what you're saying here, it's that wherever Serb villages,

25     Serb mass graves, slaughter-houses, pits, camps, churches were, that that

Page 11269

 1     was Serbian -- Serb territory.  Do I understand that correctly?

 2        A.   Well, you did not fully understand me because you're absolutely

 3     not familiar with those things.  I am saying that the results of genocide

 4     should not be recognised, and I'm talking about the genocide that

 5     Croatians committed against the Serbian people during the Second World

 6     War.  The Croats wanted to erase what happened during the Second World

 7     War and then to establish borders according to the current ethnic

 8     composition.  Our position was we should not admit that the number of the

 9     Serbian population was -- has been reduced because they were killed

10     during the Second World War.  The Croats cannot enjoy the fruit of the

11     genocide that they had committed against the Serbian people.

12             I said this sometime in the first half of 1991, before the war

13     started, if my memory serves me properly.  That's why you are not very

14     keen on giving us the date and the place.  However, if you are a serious

15     Prosecutor, you should always have that information at the tip of your

16     fingers.  You have to have that information.  You should have preceded

17     this question by giving us the time and the date.

18        Q.   Mr. Seselj --

19        A.   This is what I would do if I were in your shoes.

20        Q.   So you confirm that this, in fact, is in 1991; correct?

21        A.   I can't confirm this because this could have been in 1990.

22     However, judging from the contents you can tell that the war had -- did

23     not start yet.

24        Q.   Thank you, Mr. Seselj.

25             MS. BIERSAY:  I see the time for the break, Your Honours.  I'm

Page 11270

 1     happy to stop here.

 2             JUDGE DELVOIE:  Thank you, Ms. Biersay.  We take the first break,

 3     30 minutes.  We will be back at 11.00.

 4             Court adjourned.

 5                           --- Recess taken at 10.30 a.m.

 6                           --- On resuming at 11.01 a.m.

 7             JUDGE DELVOIE:  Ms. Biersay, please proceed.

 8             MS. BIERSAY:  Thank you, Your Honour.

 9        Q.   Mr. Seselj, do you recall attending the Great National Assembly

10     of Slavonia, Baranja, and Western Srem in September of 1991?

11        A.   Possibly.

12             MS. BIERSAY:  If I could have tab 4, please, which is P22.

13        Q.   And I'm sure it will need to be expanded for you, Mr. Seselj.

14     It's the article discussing "constitutional law adopted."

15             And you can see at the top, it says:

16             "Meeting of the Great National Assembly of the Serbian District

17     of Slavonia, Baranja, and Western Srem, Beli Manastir, 25 September."

18             Now, what I'm interested in is actually found on page 3 in the

19     English and it should be towards the end of the -- this article, and I

20     believe the paragraph begins:  "Seselj went on to say ..."

21             Actually it's the paragraph that begins:

22             "'Your Territorial Defence has restored the glory of Serbian

23     soldiers,'" said Dr. Vojislav Seselj, addressing the deputies."

24             Do you see that in the Serbian?

25        A.   No, it's not before me.  Now I see it.

Page 11271

 1        Q.   Does this refresh your recollection about whether or not you

 2     attended that session, that assembly --

 3        A.   Yes, yes.

 4        Q.   And so --

 5        A.   No doubt.

 6        Q.   Why did you go to that meeting; do you remember?

 7        A.   Well, somebody must have invited me or informed me, and I went

 8     there to give my support to the highest body of the legislative branch of

 9     Slavonia, Baranja, and Western Srem.  I gave my support through my

10     presence and my speech.

11        Q.   And I take it at this time you had no political conflict with

12     Goran Hadzic in 1991?

13        A.   You know what?  I really didn't even know Goran Hadzic at that

14     time.  He was at this session, and maybe we shook hands in passing, but I

15     don't remember that we ever talked.  We could have met.  We could have

16     shaken hands, but that's all.  I knew much better Caslav Ocic, for

17     instance, who was also elected foreign minister.  And I also -- I already

18     told you about Ilija Koncarevic and Mr. Petkovic.  One of them must have

19     invited me.

20        Q.   I'd like to move to a different topic regarding Arkan.  You

21     described yesterday in great detail your conflict with him when he

22     threatened you; do you recall that?

23        A.   Yes.  And I returned the threat.

24        Q.   I take it you also knew that, by reputation, he was wanted by

25     Interpol?

Page 11272

 1        A.   Well, at that time, I wasn't really informed about that.  There

 2     was talk that he had robbed banks in Sweden.  There were stories of that

 3     kind.  But in 1986, I was interested in him as a means to target Stane

 4     Dolanc.  Arkan was then an unimportant person, whereas Stane Dolanc was

 5     one of the top leaders in Yugoslavia and --

 6        Q.   I understand.  So you're saying that all the information that you

 7     had about him being a bank robber and all those -- all that criminal

 8     activity, that was information you had in the 1980s?

 9        A.   Well, I had information that he was involved in the murder of

10     Djurekovic.  And yesterday when I returned to Scheveningen, I saw on TV

11     that Germany had asked the Serbian authorities to issue a certificate

12     confirming that Arkan is dead or that he is alive, what a coincidence.

13     Obviously the Germans have the same information and you had much better

14     contact with Arkan.  He negotiated with you in order to be relieved from

15     prosecution to appear as a witness in exchange in the Milosevic and some

16     other trials.

17        Q.   Mr. Seselj --

18        A.   I don't mean you personally.  I mean the Office of the

19     Prosecutor.

20        Q.   You and Arkan had this personal conflict but you reconciled in

21     1991 at the funeral of a volunteer; right?

22        A.   If that was real reconciliation.  We shook hands then.  Perhaps

23     we exchanged a couple of words.  That's when Mirko Lovadinovic, known as

24     Uco, got killed.  He was a volunteer in Slavonia.  And when a group of

25     our volunteers withdrew, he had decided to stay and join Arkan and his

Page 11273

 1     men, and he got killed fighting with Arkan's Men.  And Arkan and I both

 2     attended his funeral.  And a similar thing happened to another person.  I

 3     think it happened twice.

 4             There was another meeting I had with Arkan when Arkan came to my

 5     home.  Are you interested in that?  In November --

 6        Q.   In November --

 7        A.   Are you interested?

 8        Q.   In November of what year?

 9        A.   It was in October, 31st October 1992.  I can tell you all about

10     it if you're interested.

11        Q.   Well, let me show you these documents first and perhaps we'll get

12     to that.

13             MS. BIERSAY:  I'd like now to have tab 145, which is P1743.  It's

14     been previously admitted.  And this interview, the date of it, is given

15     as 29 November 1991.  The B/C/S page, I think it's -- it begins at the

16     very end of the third page.  I think it should say page 123 at the bottom

17     of the B/C/S text.  And so the very bottom, which hopefully we can

18     enlarge for Mr. Seselj.  And, in the English in which I'm interested,

19     at -- is on page 2.  Before we move to the Arkan part that I want to --

20     to go to, I just wanted to address an issue on this page.

21        Q.   And, so the part I'm interested in is the part that starts:

22     "The army has already cleansed its ranks ..."

23             Do you see that text?  I'm sure you're familiar with it as it's

24     your -- you published it.  So it says on page --

25        A.   Yes, yes.

Page 11274

 1        Q.   "The army has already cleansed its ranks quite a bit.  It should

 2     keep cleansing them and cleanse them to the maximum ..."

 3             Further on it says:

 4             "Now we trust the army, because the army has shown -- show us in

 5     practice that it is fighting to defend the Serbian people, Serbian

 6     territories, our western borders.  The army is acting in co-operation

 7     with all of our men, and without their acting in co-operation, neither

 8     one of them would have achieved the results which are being achieved."

 9             And that is the view that you held at the time that you gave this

10     interview; is that correct?

11        A.   Yes.

12             MS. BIERSAY:  And now going to page 7 in the English, and I

13     believe it's the very end of 124 in B/C/S.  It's a sentence that carries

14     over into 125.

15             Okay.  I believe we have the B/C/S well situated.  And for the

16     English we need to go back a few pages to get to the portion that I want.

17             THE WITNESS: [Interpretation] Which excerpt have you shown me in

18     Serbian?

19             MS. BIERSAY:

20        Q.   It will be the very -- the very last -- "sto," the very last

21     thing that you see, "sto" on the last line on that page.  You see where

22     there is a period and then it begins "sto ..."

23        A.   I see that but I need the -- the continuation.

24        Q.   Right.

25        A.   "As for ..."

Page 11275

 1             MS. BIERSAY:  If we could go in the English go -- go backwards

 2     one more page.  Okay.  There we go.  And if, for the English, if you

 3     could enlarge the first paragraph.

 4        Q.   So, Mr. Seselj, if you could -- you've read that -- that line.

 5             MS. BIERSAY:  If we could now move in the B/C/S to the next page,

 6     125, at the very top.

 7        Q.   Now, you were asked a question about co-operation, and here it

 8     says:

 9             "As far as the Serbian Volunteers Guard, headed by Zeljko, Arkan,

10     Raznjatovic, is concerned, we co-operate with them and our men have

11     participated in many battles together."

12             Does that correctly reflect the situation when you gave this

13     interview in November of 1991?

14        A.   One point should be cleared up here.  The statement is correct,

15     it was correctly quoted.  It was the end of November 1991.  In the course

16     of that month of November, our volunteers, just as Arkan's volunteers,

17     were under command of Radovan Stojicic, known as Badza, in the

18     Operative Group North commanded by the Novi Sad Corps.  So Arkan's Men

19     were there as well.  They took part in some combat such as the battle for

20     Tenja, but the two groups of fighters did not mix.  Both of them were

21     engaged but they did not join together and they did not mix.  We were

22     under the same command but each had their own section of the front line

23     where they fought.

24             And my aim at that time was not to increase tensions between me

25     and Arkan so that our people, our men on the ground, would not clash

Page 11276

 1     mutually.  That was my concern.  Because on a couple of occasions, a

 2     conflict, an armed conflict, a skirmish between our two groups of men was

 3     barely avoided.

 4             MS. BIERSAY:  I'd like to now turn to tab 151, which is

 5     65 ter 2039.2.

 6        Q.   If you just be patient while we find this document.

 7        A.   I have all the time in the world for you, Ms. Biersay.  I like

 8     you best of all the Prosecutor's Office.

 9             MS. BIERSAY:  And in -- in the B/C/S, I think we can go forward

10     to page 10 to 11 in the B/C/S, and I think it also corresponds to

11     pages 10 to 11 in the English as well.  And this is an extract of an

12     interview given to B92 and it was republished in April of 1994.  So

13     65 ter 2039.2.

14                           [Prosecution counsel confer]

15             MS. BIERSAY:  My colleague made it even easier than I thought.

16     So only the two pages of the B/C/S are in -- are uploaded.

17        Q.   While we're waiting for this, Mr. Seselj, if I can ask you what

18     information at the time did you have about Arkan and the criminal

19     activities that he was involved with in Slavonia?

20        A.   I had information about his robberies and looting.  I knew about

21     several murders he committed.  I once even filed a criminal complaint

22     about the murder of Iso Lero.  Arkan's Men kidnapped him in Belgrade,

23     took him to Slavonia.  They killed him, covered him with cement, and

24     threw him into the Danube.  And a police inspector later came to tell me

25     they couldn't do anything.  Arkan was so dangerous that even the police

Page 11277

 1     couldn't do anything about him.  So I had information about robberies.

 2     And only when I came here did I receive extensive documentation about the

 3     war crimes he was responsible for.

 4        Q.   And did you have any information about his activities with the

 5     Djeletovci oil expiration [sic]?

 6        A.   Exploitation, you mean.  I didn't hear of any explosion.

 7             I believe that, in many places where he went, he would kind of

 8     impose his presence so that he could go on doing whatever he pleased.  I

 9     had information that for a while he appropriated this oil field, exported

10     and sold that oil.  The time of this story, of this text, is much closer

11     to the time when it was all happening, and my memory now is certainly not

12     so fresh as this text.

13        Q.   Okay.

14             MS. BIERSAY:  At this time are we -- let me check to see if we

15     are able to display 65 ter number 2039.2?

16                           [Prosecution counsel confer]

17             MS. BIERSAY:  Could I have the next page in English, please.

18     Thank you.

19             And if I could have the next page in the B/C/S as well.

20        Q.   So what I'm interested in, Mr. Seselj, it's at the top of that

21     page.  And I will read the part in English that I -- I'm interested in.

22     You're talking about Arkan, and at the end of that first full

23     paragraph -- in the middle of the first full paragraph it begins:

24             "In 1991, though, there was a war and what cannot be denied is

25     that Arkan was a brave soldier in this war.  His courage cannot be

Page 11278

 1     denied.  He fought.  He really fought.  I can testify to this.  But the

 2     problem is the other side of the coin.  The problem lies in all the

 3     large-scale plundering that took place in the war and in which he was

 4     implicated.  Then there's his link with the former president of the

 5     Republic of Serbian Krajina, Goran Hadzic ..."

 6             What link did you have in mind there?

 7        A.   Between Hadzic and him?

 8        Q.   Yes.

 9        A.   Or the authorities in Serbia?  Well, I saw on more than one

10     occasion that Arkan was appearing in various places together with

11     Goran Hadzic, and based on that, I concluded there were ties between

12     them.  And then Arkan later imposed himself, thanks to Radovan Stojicic,

13     Badza, and he'd simply do as he pleased.  He went wherever he wanted to.

14     He even attended sessions of the government of Slavonia, Baranja, and

15     Western Srem.  He would come to the government session and nobody could

16     do anything about it.  Nobody even dared asked him --

17        Q.   Thank you.  I --

18        A.   -- why he had come.  As for ties with the regime in Serbia -- oh,

19     you don't want me to say that.

20        Q.   Mr. Seselj, I want you to slow down so I can catch up with the

21     translation.

22             I'd like to go back in time, back to 1990 when you were trying to

23     have the Serbian Chetnik Movement registered.  You talked about that

24     yesterday.

25             MS. BIERSAY:  At this time, if I could please have 65 ter 6611,

Page 11279

 1     tab 137.  And this is -- it was published in 1994 and it's dated 1990.

 2             And in the English, if we could go to the third page.  In the

 3     English, could we have the next page, please, and the page after that.

 4     Sorry, the next page, obviously.  Thank you.

 5             And in the B/C/S, if we could go to page 5, I think.  Yes, at the

 6     bottom.

 7        Q.   So, Mr. Seselj, this is the decision rejecting the application of

 8     the political party, the Serbian Chetnik Movement.  Now, at the bottom of

 9     the page that you're looking at you can see the beginning of it, and when

10     you're finished looking at that, I can move to the next page.  Can I --

11        A.   Move to the following page, please.

12             MS. BIERSAY:  And the same in English, please.

13        Q.   Now, in the -- the statement of reasons, it's written here by the

14     deputy, the republican secretary, that:

15             "It is known from the recent history of Yugoslavia that members

16     of the Chetnik movement in World War II ended the war on the losing side

17     and their leaders were convicted as war criminals by people's courts

18     because of massacres and other forms of terror against the peoples of

19     Serbia, Montenegro, and Bosnia and Herzegovina.

20             "Believing that the submitted name offends public morals in the

21     Socialist Republic of Serbia, this secretariat has rejected the

22     application of the political party, the Serbian Chetnik Movement ..."

23             Is that what you meant yesterday by the Serbian Chetnik Movement

24     being denied registration?  Is this the document you had in mind?

25        A.   Yes, this is the document I had in mind.

Page 11280

 1             MS. BIERSAY:  At this time we'd move for the admission of

 2     65 ter 6611.

 3             JUDGE DELVOIE:  Admitted and marked.

 4             THE REGISTRAR:  Exhibit P3257, Your Honours.

 5             JUDGE DELVOIE:  Thank you.

 6             MS. BIERSAY:  And if we could now move to tab 136, which is a

 7     one-page document.  And it is 65 ter number 6610.  I now fast-forward to

 8     1991.

 9        Q.   And now directing your attention to this, this, in fact, is a

10     decision registering the Serbian Radical Party in 1991; correct?  Is this

11     the document you had in mind?

12        A.   Yes.

13             MS. BIERSAY:  And it's -- for the record, it's dated

14     12 March 1991.  And at this time we'd move for admission of 65 ter 110.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  Exhibit P3258, Your Honours.

17             MS. BIERSAY:  And just to let the interpreters know, the next

18     trio of clips that I'd like to play would be P88.50, and it would be the

19     .3 document that you have, and the .8 document you have.  And then

20     Exhibit 2030.  And then 65 ter 4936.1.

21        Q.   Mr. Seselj, I'd like to talk about Slobodan Milosevic and your

22     relationship and the party's relationship with him.  Now, in 1991, 1992,

23     and 1993, you and your party were receiving assistance from him; is that

24     correct?

25        A.   We as a party never received any assistance from Milosevic.

Page 11281

 1     However, the Milosevic's regime helped us sending volunteers to Serbian

 2     Krajina.  I told you how yesterday.  Those volunteers had guaranteed

 3     labour rights, even privileges, in their workplaces.  The federal

 4     authorities through the JNA provided additional guarantees.

 5             As I explained yesterday, Milosevic's regime tried as hard as

 6     they could to prevent successful mobilisation into the JNA.  They feared

 7     that the generals would take an opportunity to topple himself and

 8     Tudjman.  But he knew that he needed to help western Serbs.  That's why

 9     his regime helped the sending of volunteers as of September 1991, when

10     the volunteers of the Serbian Radical Party started joining JNA units.

11     Before September 1991 --

12        Q.   So in the future when I -- if I'm tapping my headphone it means

13     that the interpretation needs to catch up to you.  And if you could just

14     stop, let the interpretation finish and then continue, it would be

15     helpful.

16        A.   Ms. Biersay, I noticed your signals, but I misinterpreted them.

17     I thought that they meant something entirely different.  Now you have

18     made the thing clear.

19             MS. BIERSAY:  If the interpreters are ready, we can proceed with

20     the playing of P88.50 and the first clip is -- will go from, I believe,

21     14:40 to 16:24.  And the next clip will -- .8 will go from 37:41 to

22     38:48.

23             May I get a confirmation --

24             THE INTERPRETER:  We are ready.

25             MS. BIERSAY:

Page 11282

 1        Q.   So, Mr. Seselj, if you please just listen and watch the video.

 2                           [Video-clip played]

 3             THE INTERPRETER: [Voiceover] "Therefore, we were in direct

 4     conflict with the regime and at that time Milosevic's policies were

 5     prominently Communist.  His reversal came as late as 1991, when we --

 6     some communication was established between us, meaning that he came over

 7     to our side instead of us coming over to his.

 8             "LS:  And how did you ... when you signed up those volunteers for

 9     Knin, how did you obtain weapons, or how did they obtain them just in

10     case they needed to do something there?

11             "Seselj:  We did not obtain weapons in 1990.  We only signed up

12     volunteers and sent them on occasion if there was a need to do so, but

13     these were very small groups.  In 1991 we began to organise greater

14     numbers of volunteers and to send them to the front lines that had

15     already been formed, particularly those in Eastern Slavonia and here in

16     the eastern part of the Republic of Serbian Krajina.  Our volunteers

17     really proved themselves in the battle in Borovo Selo on 2nd May 1991,

18     when they overpowered the more powerful Croatian forces, the Croatian

19     police and parapolice forces.  We received weapons from Milosevic's

20     police, first from the then-minister of the interior, Radmilo Bogdanovic,

21     and when he was replaced, from his successor.  We also received old

22     weapons from the Territorial Defence depots.  These were old American

23     Thompson rifles that had long been out of use, and old M-48 rifles, the

24     so-called Tandzare.  These were all obsolete and the army had stopped

25     using them a long time ago, or had stored them in Territorial Defence

Page 11283

 1     depots.  They didn't want to destroy them completely so they simply gave

 2     them to us.  But it was these weapons that allowed us to defeat the

 3     Croats who were armed with modern weapons."

 4             MS. BIERSAY:  And now moving to .8.

 5                           [Video-clip played]

 6             THE INTERPRETER: [Voiceover] "LS:  When you received those

 7     weapons, did that ... you said that the regime gave weapons to your

 8     party, I mean, the volunteers, was that in ... with the political

 9     leadership's, with Milosevic's knowledge, or through the police and

10     through ...

11             "Seselj:  This was all done with Milosevic's knowledge, there's

12     no doubt about that.  And key people in the police with whom we

13     co-operated at the time were Radmilo Bogdanovic, Mihajl Kertes and

14     others ... Franko Simatovic, also known as Frenki, who later commanded

15     the Red Berets.  From the General Staff, we mostly co-operated with

16     General Domazetovic, who was the deputy chief of the General Staff and

17     also at that time the head of the personnel administration, if I remember

18     correctly.  There were also contacts with lower-ranking officers and so

19     on, depending on the need and the situation.  Our volunteers came to

20     Belgrade, the barracks in Bubanj Potok.  That is where we put on

21     uniforms, and where they were given weapons and buses to take them where

22     they wanted.  They were under the command of the Yugoslav People's Army

23     as soon as the Yugoslav People's Army became involved in the fighting."

24             THE WITNESS: [Interpretation] Why did you interrupt the clip when

25     it became the most interesting?  It is like watching a western movie and

Page 11284

 1     somebody interrupts it at the moment of the showdown between the two

 2     opposing -- opponents.

 3             MS. BIERSAY:

 4        Q.   So it is true that Milosevic provided your volunteers with

 5     assistance in 1991, 1992, and 1993?

 6        A.   Well, it's not as simple as that.  There are two things that need

 7     be to clarified.  When you say "Milosevic," he usually personified the

 8     regime itself.  He was the most prominent politician in Serbia.  His

 9     party was the ruling party without any competition.  So when we say

10     "Milosevic," we mean Milosevic's regime.

11             Second of all, I mystify things on purpose.  For a number of

12     years I was hiding the real source of weapons, and I tried to confuse the

13     media.  At my press conferences I used to claim that we imported weapons

14     from Hungary and with the help of a Hungarian minister.  Here I involved

15     Milosevic's police in order to cover up who the actual source of weapons

16     was.  And the true source of weapons was General Dusan Pekic.  I didn't

17     mention his name in public before he died.

18             General Dusan Pekic had a huge authority in the JNA.  He managed

19     to engage some officers and reach the depots where obsolete weapons were

20     stored, the weapons that were supposed to be destroyed.  Those weapons

21     were delivered to us in the course of 1991, while we were still sending

22     our volunteers illegally and deploy them in many places.  I say that our

23     volunteers were dispatched illegally before September 1991.  As soon as

24     we made an agreement with the JNA, then we started enjoying the

25     assistance of Milosevic and the federal authorities.  As for Milosevic

Page 11285

 1     himself, I met him for the first time in April 1991 at a session of the

 2     National Assembly.  And the first time we spoke was in May 1991 in his

 3     office.

 4             MS. BIERSAY:  If we could now move to tab 32, which is

 5     Exhibit 2030.  And that is a clip from 4773, which goes from 1 hour,

 6     15 minutes and 31 seconds to 1 hour, 18 minutes and 20 seconds.

 7                           [Video-clip played]

 8             THE INTERPRETER: [Voiceover] "When we announced that you and

 9     Mr. Poplasen were going to be our guests tonight, there were a lot of

10     telephone calls and questions.  However, one of the questions was asked

11     most frequently.  It was about volunteers, the members and supporters of

12     your party, who were present in the territory of the ex-Croatia and the

13     ex-Bosnia and Herzegovina from the very beginning of the war as

14     volunteers.  However, the viewers have the impression that this has been

15     running out of steam lately, as if some of the people and some of your

16     members and supporters have lost their interest in the fate of the Serbs

17     in Republika Srpska.  Is it so, and are your volunteers still here and

18     are you, are they ready, I mean ...?

19             "Vojislav Seselj:  This is a false impression.  Firstly, our

20     volunteers are still there.  They are with Chetnik Vojvoda Slavko Aleksic

21     at the Jewish Cemetery, with Vojvoda Vasko in Ilijas, with Vojvoda

22     Manda Maksimovic on Majevica ... there are also a number of volunteers

23     with Vojvoda Brne at Ilidza, then with Vojvoda Radovic in the area of

24     Velez and so on.  There are many but there would be many more if the

25     Command of the Serbian army requested us to send volunteers.  It is much

Page 11286

 1     harder for us to send volunteers now than in 1991, 1992, or 1993.  When

 2     we were sending volunteers then, we had good co-operation with

 3     Slobodan Milosevic.  He used to give us uniforms, weapons, buses.  He

 4     granted the entire barracks in Bubanj Potok to the Serbian Radical

 5     Party - everything, all the necessary equipment and it all used to be

 6     functioning much better.  Due to the treason committed by Slobodan

 7     Milosevic, the Serbian Radical Party faces huge difficulties when sending

 8     and equipping volunteers these days.  Now our volunteers go in civilian

 9     clothes to the areas where they are called from by some -- and we are

10     sending them by buses.  They go through corridor, through Banja Luka.

11     The local Serbs already know that.  We cannot talk about numbers, of

12     course.  It is much harder for us to secure buses, the basic equipment

13     that has to be sent with the volunteers.  The volunteers are provided

14     with weapons when they arrive.  They put on uniforms there.  Our

15     situation is so much more complicated and the process to prepare the

16     volunteers for departure is longer and harder.  However, if the command

17     of the Serbian army so requests, we are fully capable of sending out

18     volunteers."

19             MS. BIERSAY:

20        Q.   And, Mr. Seselj, this is another occasion that you referenced

21     sending volunteers and having good co-operation with Slobodan Milosevic;

22     correct?

23        A.   Again, this is the regime personified.  I told you when it was

24     that I met Milosevic for the first time.  However, towards the end of

25     1991, if Milosevic had been against our volunteers, we would have been

Page 11287

 1     prevented like we were until the end of summer 1991.  His police tried to

 2     prevent our departure so we had cross the Danube illegally.

 3             I don't have the time to explain everything in detail.  In any

 4     case, Milosevic is the personification of the entire regime in Serbia and

 5     the Federal Republic of Yugoslavia.  That's how you understand to things.

 6     It is not like Milosevic had a say in every little detail.

 7             And now on to another matter and that is our volunteers.  We are

 8     still proud of them, to this very day we are.

 9        Q.   Mr. Seselj, thank you.

10             MS. BIERSAY:  And if we could now play 65 ter 4936.1.

11                           [Video-clip played]

12             THE INTERPRETER: [Voiceover] "It is the end of March, and the

13     year is 1995.

14             "Cheers!

15             "Vojislav Seselj is addressing the Serbs from Glina, only four

16     months before the operation Storm started.

17             "Seselj:  Milosevic needed us both in 1991 and 1992.  Besides,

18     Slobodan Milosevic was helping the western Serbian countries at that

19     time, Serbian Krajina as well as Republika Srpska, Serbian Krajina and

20     Republika Srpska were established with his help.  Besides that, he gave

21     us, the Serb radicals, weapons for 30.000 volunteers we were sending off

22     to almost all battle-fields, where they were most needed.  He also gave

23     us buses, uniforms, he put the whole barracks in Bubanj Potok at the

24     disposal of the Serbian Radical Party, for volunteers.  We haven't

25     forgotten that.  And also in the first days after the battle in

Page 11288

 1     Borovo Selo when we were transporting the weapons across the Danube to

 2     the Eastern Slavonia, on the rafts, by night.  The weaponry we got from

 3     the police warehouses and Serbian Territorial Defence warehouses pursuant

 4     to Milosevic's order.  We returned Milosevic the favour, we supported him

 5     when he was having the toughest of times."

 6             MS. BIERSAY:

 7        Q.   And this is again you discussing the assistance received from

 8     Slobodan Milosevic in 1991 and, in this case, 1992.

 9        A.   I'm saying from September 1991 onwards.  This was just one short

10     part of my speech.  I am not happy that you censorship the speech of

11     Aleksandar Vucic, the prime minister of Serbia, who was there and he also

12     spoke.

13             Second of all, I am again explaining to people and I use

14     Milosevic to personify the entire regime because immediately after that I

15     attacked Milosevic.  I am accusing him that he wanted to betray the

16     Republic of Serbian Krajina.  The essence of that was:  You were helping

17     us before and now you want to betray us.  And that's -- we scheduled a

18     large protest rally on St. Vitus Day in 1995, on the 28th of June.

19     However, at the beginning of June, Milosevic's police arrested me in

20     Gniljane and kept me and Tomislav Nikolic in prison for two months

21     together with some of our associates.

22             When it comes to the personification of a regime, one person is

23     the entire regime.  You don't think that Milosevic was the head of a

24     warehouse who could hand out the weapons himself.  You don't think that

25     he was the commander of the barracks in Bubanj Potok.  The JNA was in


Page 11289

 1     command of the barracks, but Milosevic had a lot of clout.  And if he had

 2     wanted to prevent it, he would have.  Milosevic's party was the ruling

 3     party and the functioning of the federal state depending on the

 4     functioning of Serbia.  The federal state could not exist without Serbia.

 5     Serbia funded everything, Serbia supported the JNA.  This is the essence

 6     of my accusations against Milosevic.  Milosevic was the entire regime.

 7             MS. BIERSAY:  At this time we tender 65 ter 4936.1.

 8             JUDGE DELVOIE:  Admitted and marked.

 9             THE REGISTRAR:  Exhibit P3259, Your Honours.

10             JUDGE DELVOIE:  Thank you.

11             MS. BIERSAY:

12        Q.   Mr. Seselj, I'd like to address the -- your three-minute speech

13     given to the Trial Chamber this morning about Dr. Bosanac.  So I have

14     these transcript pages, and it does not support the allegations that you

15     made this morning.

16             MS. BIERSAY:  And because this is a matter that was done in

17     private session, I'd ask that we move into private session.

18             JUDGE DELVOIE:  Private session, please.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11290











11 Pages 11290-11292 redacted. Private session.
















Page 11293

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25             JUDGE DELVOIE:  Your argument is on the record, Mr. Seselj.

Page 11294

 1             We go into open session.

 2                           [Trial Chamber and Registrar confer]

 3                           [Trial Chamber confers]

 4             JUDGE DELVOIE:  Please proceed, Ms. Biersay.  You have questions

 5     left?

 6             MS. BIERSAY:  No, Your Honours.  Thank you.

 7             JUDGE DELVOIE:  Thank you.

 8             Mr. Zivanovic --

 9             THE WITNESS: [Interpretation] I suppose you haven't finished.

10             JUDGE DELVOIE:  Mr. Zivanovic -- Mr. Seselj, Ms. Biersay said she

11     finished.

12             Mr. Zivanovic, would you like to -- how long will your re-direct

13     be?

14             MR. ZIVANOVIC:  It may be half an hour, maybe 40 minutes, 45 -- I

15     don't know.  I'd like to see this transcript, a copy of this transcript.

16             JUDGE DELVOIE:  Shall we take the break, then, a little bit early

17     now and start your re-direct after the break?

18             MR. ZIVANOVIC:  Yes, Your Honours.

19             JUDGE DELVOIE:  So next break.  Thirty minutes.

20             Court adjourned.

21                           [The witness stands down]

22                           --- Recess taken at 12.09 p.m.

23                           --- On resuming at 12.44 p.m.

24             JUDGE DELVOIE:  Ms. Biersay.

25             MS. BIERSAY:  Thank you.  Thank you, Your Honour. I conferred


Page 11295

 1     with Mr. Zivanovic, and he was kind enough to let me know that his

 2     estimate for re-direct would be 45 minutes and I advised him that I would

 3     be objecting to the length of that cross -- of that re-direct, given the

 4     three hours that was used in direct examination, and I believe the -- the

 5     great breadth given to Mr. Seselj during those three hours.  So it's on

 6     that basis that I object to the 45 minutes.

 7             JUDGE DELVOIE:  Mr. Zivanovic.

 8             MR. ZIVANOVIC:  My re-direct is not related to my direct and the

 9     length of my direct but for the length of cross-examination of the

10     Prosecution and it was also three hours.  And it put many, many issues,

11     and many things that I would like to clarify with this witness.  And, in

12     my estimate, as I -- as I noted, is that my re-direct might be up to

13     45 minutes.

14                           [Trial Chamber confers]

15             JUDGE DELVOIE:  Mr. Zivanovic, we will grant you the 45 minutes,

16     under the condition that you restrain the witness, who's your witness, to

17     answer questions and not to make speeches and not to dwell on other

18     matters than the answer on your questions.

19             MR. ZIVANOVIC:  I'll do my best, Your Honours.

20             JUDGE DELVOIE:  Thank you.

21             MR. ZIVANOVIC:  And I would just put two more housekeeping

22     matters now before the witness enter the courtroom.

23             Our next witness is here --

24             JUDGE DELVOIE:  Perhaps, Mr. Zivanovic, it would be better if you

25     let me start with administrative matters I wanted to handle, and perhaps

Page 11296

 1     that would answer some of yours.

 2             MR. ZIVANOVIC:  Thank you.

 3             JUDGE DELVOIE:  The first one is Witness -- Defence Witness 009

 4     and the Defence's safe conduct motion for this witness filed on the

 5     1st of September.

 6             Being filed way too late, which seems to grow into a bad habit,

 7     the Trial Chamber is not minded to ask the OTP for an expedited response

 8     and will therefore not take a decision before the witness is scheduled to

 9     come to The Hague.  Meaning, Mr. Zivanovic, that you will have to

10     reschedule.

11             Another topic is the Defence motion with regard to the practice

12     UNDU imposes on the Defence when dealing with detained self-representing

13     witnesses, such as Mr. Seselj.  After our exchange about this issue right

14     before the start of Mr. Seselj's testimony, I had the impression that the

15     problem had been solved and that, as a consequence, the motion is now

16     moot.

17             Could you confirm that, Mr. Zivanovic?

18             MR. ZIVANOVIC:  Yes, Your Honour.

19             JUDGE DELVOIE:  Thank you.  Do you have any other matter to

20     raise?

21             MR. ZIVANOVIC:  Yes, Your Honour, for our next witness.  He is

22     actually here.  However, yesterday I -- he informed me that he has one

23     more witness statement which he gave to the Prosecution several years

24     after the first one that was the subject of our Rule 92 ter motion.  And

25     we tried to identify this second witness statement, and I'd ask the

Page 11297

 1     Chamber for the permission that he start his testimony tomorrow so that

 2     we could see what he said in this -- in that second witness statement and

 3     to discuss it with him before he takes the stand.

 4             JUDGE DELVOIE:  Okay.  So what -- what you are -- what you are

 5     asking, just to be clear about it, Mr. Zivanovic, is that we would not

 6     start him today but start him tomorrow morning.

 7             MR. ZIVANOVIC:  Correct.

 8             JUDGE DELVOIE:  Mr. Stringer.

 9             MR. STRINGER:  Thank you, Mr. President.

10             We take -- there's no position or opposition from the Prosecution

11     on whether to start today or tomorrow.  We're in the process of sending a

12     message to the Defence.  There is no other statement.  The witness met

13     with some members of the Prosecution team in February of 2012.  It was

14     preliminary to the Prosecution making a list of witnesses for its own

15     case in-chief, and after meeting with this individual, it was decided not

16     to call him as a witness, and no additional statements were made.  There

17     was no real questioning of the witness at the time, and so there are no

18     more statements beyond the one that the Defence has.  And that's the

19     message that we were just about to send to the Defence.

20             JUDGE DELVOIE:  Okay.  Thank you.

21             If there's nothing else -- we'll see after your re-direct,

22     Mr. Zivanovic.

23             If there's nothing else, the witness may be brought in.  Yes --

24             MR. ZIVANOVIC:  I would -- I would ask the Chamber to start the

25     testimony of this witness tomorrow.  If I could discuss --


Page 11298

 1             JUDGE DELVOIE:  If -- if what Mr. Stringer said does not change

 2     your mind, Mr. Zivanovic, I think there's no problem.  We'll start this

 3     witness tomorrow morning.

 4             MR. ZIVANOVIC:  Thank you.

 5             JUDGE DELVOIE:  Which also means that the witness can be advised

 6     that he can leave the building.

 7                           [The witness takes the stand]

 8             JUDGE DELVOIE:  Sorry for the delay -- sorry for the delay,

 9     Mr. Seselj.  We had a few housekeeping matters to discuss.  And might you

10     be a little bit suspicious that this happened right after what some

11     people would call an incident in court, the housekeeping matters we

12     discussed had nothing at all to do with what happened in court before the

13     break.

14             Mr. Zivanovic.

15             MR. ZIVANOVIC:  Your Honour, with your permission, I would read

16     to Mr. Seselj the whole page of this particular --

17             THE WITNESS: [Interpretation] Just a moment.

18             MS. BIERSAY:  Excuse me.

19             JUDGE DELVOIE:  One moment --

20             THE WITNESS: [Interpretation] Please, Mr. President.  You have

21     to --

22             JUDGE DELVOIE:  One moment, Mr. Seselj.  Please sit down for a

23     moment, Ms. Biersay.

24             What you are about to say has, I take it, nothing to do with what

25     Mr. Zivanovic wanted to start with; right?

Page 11299

 1             THE WITNESS: [Interpretation] No.

 2             JUDGE DELVOIE:  Okay.  Then go ahead.

 3             THE WITNESS: [Interpretation] As you, Mr. President, said that

 4     there was an incident in private session, I would like to ask you to

 5     specify that I was not the one who caused the incident but rather the

 6     Prosecutor.  Nothing else.

 7             JUDGE DELVOIE:  I didn't -- Mr. Seselj, I did not -- you should

 8     listen carefully.  Unless there is a problem with the translation, I did

 9     not say that there was an incident.  I just wanted to inform and reassure

10     you that what -- what we were discussing without you being present had

11     nothing to do with what was happening in court before the break.  That's

12     all.

13             Mr. Zivanovic.

14             MR. ZIVANOVIC:  Your Honours, with your permission, I would read

15     one page of transcript because -- because Ms. Biersay did not read the

16     whole and most relevant part of this transcript that confirms the

17     statement of Mr. Seselj.

18             JUDGE DELVOIE:  Ms. Biersay.

19             MS. BIERSAY:  May I have a transcript page reference so I can

20     confirm that it is available in the public version of the transcript.

21             MR. ZIVANOVIC:  It is -- it starts with 11426 and until 11427,

22     line 18.

23                           [Trial Chamber and Legal Officer confer]

24             JUDGE DELVOIE:  I think that, if only out of abundance of

25     caution, we should go into private session.


Page 11300

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11301











11 Pages 11301-11302 redacted. Private session.
















Page 11303

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18                           [Open session]

19             THE REGISTRAR:  We're in open session, Your Honours.

20             JUDGE DELVOIE:  Thank you.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   The Prosecutor asked you about volunteers who were sent to the

23     front, and you gave an answer about the time when they were sent there.

24     You repeated it several times, but I will read out to you just one

25     section which has to do with sending volunteers to the front before


Page 11304

 1     September 1991 and after September 1991.  In connection with this, she

 2     also asked you about the contacts you had with Milosevic.  I will read

 3     out to you what was recorded in the transcript and please tell us whether

 4     that is correct or not.

 5             MR. ZIVANOVIC:  It is page 47, lines 12 to 19:

 6        Q.   "Those weapons were delivered to us in -- in the course of 1991,

 7     why we were still -- while we were still sending our volunteers illegally

 8     and deploy them in many places.  I say that our volunteers who were

 9     dispatched illegally before September 1991.  As soon as we made agreement

10     with JNA, we started enjoying the assistance of Milosevic and the federal

11     authorities.  As for Milosevic, I met him for the first time in

12     April 1991 at a session of National Assembly.  And the first time we

13     spoke was in May 1991 in his office."

14             [Interpretation] Did you really talk about this year 1991 as the

15     one when you first met Milosevic or was it a different year?

16        A.   This is also deliberate falsehood because I said clear and loud

17     that I first met Milosevic in April 1992 and that I was first in his

18     office in May 1992 which was when we talked.  1992.

19             And in 1991, in April, I was not a member of parliament at all.

20     I was in a party that had no representatives in the parliament.  This is

21     also a deliberate falsehood.  It's obvious.  The Prosecutor would like

22     that to turn out that Milosevic provided weapons to us when we went

23     illegally to defend Serbian villages.  I have explained to you that

24     General Dusan Pekic was the one who procured all discarded weapons

25     through his friends, generals, and that he should get all the merit for

Page 11305

 1     this.

 2        Q.   All right.  I would like now to remind you about something that

 3     the Prosecutor asked you yesterday, namely, your contacts with

 4     Goran Hadzic from the moment when he arrived to the Detention Unit.

 5             So please tell me whether you remember if there were any measures

 6     prohibiting your communication with Goran Hadzic.

 7        A.   Yes.  As far as I remember, there were.  Whoever new arrived here

 8     was prohibited from contacting me and I think it lasted for some months.

 9     I'm not sure how many.  I think we received this ban in writing.  And

10     what the reason was, probably the Prosecution was afraid that I might

11     inform Mr. Hadzic about everything I knew and it was information that he

12     might be interested in, because I have learned many things here.  And you

13     see what the problem with the Prosecution is.  By definition, an

14     international prosecutor is administrator, an officer of international

15     justice, but his goal to determine the truth and not to arrive at

16     convictions.  With equal care and effort, he has to collect evidence

17     which might end in conviction or in acquittal.  And if an indictment is

18     issued against someone, here it's a question of life and death for them

19     to see that that person is eventually convicted.

20        Q.   Again, today, earlier today, the Prosecution put to you an

21     excerpt from your evidence given in the Milosevic trial and part of your

22     closing arguments, the two of them being inconsistent.  You have already

23     said something about this, but you tried to explain why you are better

24     informed now about the events at Ovcara, the hand-over of prisoners,

25     et cetera.  You were trying to explain why you were better informed about

Page 11306

 1     it all in 2012 than when you testified in Milosevic.

 2        A.   With my hunger strike in 2006 I achieved a number of important

 3     things.  First of all, I forced the Tribunal to rid me of Judge

 4     Alphons Orie, who was violating my procedural rights, and to register my

 5     legal advisors and enable me to have privileged communication with them.

 6     Only then could I start my investigative work.  Until then it wasn't

 7     possible.  I heard a little bit from here and a little bit from there,

 8     but nothing really solid.  This is the moment when my real investigation

 9     began and when I began to receive reliable information.  And the

10     information I was receiving from the field was for the most part

11     consistent with the evidence given by Prosecution witnesses.  There were

12     many officers, including high-ranking officers such as colonels, who

13     testified that they had been in Ovcara all the time.

14        Q.   In 2005, when you testified in the Milosevic case, you did not

15     have privileged communication with your legal advisors, did you?

16        A.   For almost five full years, I did not have that kind of

17     communication.  I sat here, wrote books, read, and I practically didn't

18     interfere in my own case because there was no sense in doing that while I

19     had a lawyer that was imposed on me.  I needed to get rid of this lawyer

20     who was imposed on me, and I also had to get them to give me all the

21     documents in the Serbian language.  I had to make them do all that, to

22     rewind the trial to the beginning, and to enable me to represent myself.

23     And thanks to achieving that, I absolutely shattered all the evidence led

24     by the Prosecution, including the indictment, et cetera.

25        Q.   The Prosecutor showed you --

Page 11307

 1             JUDGE DELVOIE:  Mr. Zivanovic, you should be -- you should know

 2     better than to start your next question before Mr. Seselj's answer is

 3     interpreted.  Please pay attention.

 4             MR. ZIVANOVIC:  Yes.  Yes, Your Honour.

 5        Q.   [Interpretation] You have seen a video-clip footage depicting you

 6     when you arrived in Vukovar.  The Prosecutor showed it to you earlier

 7     today.  In that footage you were talking about the importance of

 8     capturing Vukovar.  On that occasion, you also visited the volunteers of

 9     the Serbian Radical Party who were there.  You were talking about whose

10     command they were under, et cetera.

11             I'm interested in this:  While the volunteers of the Serbian

12     Radical Party in -- on the Vukovar front line, do you know who provided

13     them with ammunition?

14        A.   There was a depot in the building of Velepromet held by the

15     military police, and that's where they got weapons, uniforms or parts of

16     uniforms to replace the torn ones, ammunition.  They got there everything

17     they needed, including food.  So supplies came from the same source for

18     the Guards Motorised Brigade, for guardsmen, for soldiers, and for

19     members of the Territorial Defence.  There was no discrimination among

20     them.

21             Talking about that military police.  In the same depot, the

22     military police was holding prisoners.  That's why it was under their

23     control.

24        Q.   Let us take a look at a letter sent by Ljubisa Petkovic.

25             MR. ZIVANOVIC:  [Interpretation] It's 2650.  [In English] Sorry,

Page 11308

 1     just ...

 2             JUDGE DELVOIE:  Can we have a tab number, please.

 3             MR. ZIVANOVIC:  Sorry.  It is -- it is 2576.  Sorry, I'll try to

 4     find it.  It is -- sorry, it is 3556.  P3556.  Or ... no.  No, no, no.

 5     2625, 2625.  Tab 38.

 6             JUDGE DELVOIE:  Is that on your list or the OTP's list,

 7     Mr. Zivanovic?  Tab number.

 8             MR. ZIVANOVIC:  Unfortunately, it is not this document.  It is

 9     2576.  2576.  Tab 35.

10             JUDGE DELVOIE:  35.  Your list or OTP's list?

11             MR. ZIVANOVIC:  Ah, that's it.

12             JUDGE DELVOIE:  I see it now.  It's the OTP's list.

13             MR. ZIVANOVIC:  Yes, it is on OTP list.

14             JUDGE DELVOIE:  Yes.

15             MR. ZIVANOVIC: [Interpretation]

16        Q.   Would you kindly tell us, this letter that has already been shown

17     to you by the Prosecution, was this letter sent with those volunteers who

18     were going to the front line or was it sent independently of them?  Can

19     you remember?

20        A.   I also saw this document for the first time here.  I don't think

21     it's particularly important.  I think it was done -- I mean, it was sent

22     in this way in this particular case, whereas other letters were sent by

23     different channels.  It is said here that it is addressed to the

24     commander of the Leva Supoderica Detachment, that this group was under

25     the command of Slobodan Katic.  It is suggested that they be given two

Page 11309

 1     extra days.  Is it what it says here?  It's difficult for me to read.

 2        Q.   Yes, it's a bit small.

 3        A.   What I'm trying to say, it's not some kind of prototype or

 4     template.

 5        Q.   On page 29, a document was shown to you about the movements of

 6     Croatian and Serbian population, and you mentioned 300.000 refugees.  How

 7     are you able to know this figure?  And what position did you occupy then?

 8     How did you know that there were 300.000 refugees at that time in Serbia?

 9        A.   I knew the figure of 250.000 refugees at that moment, and these

10     statistics were constantly updated, though those were official

11     statistics.  And the authorities kept publicising the figure, and we

12     didn't even need those statistics because the whole of Serbia was awash

13     with refugees.

14        Q.   Considering that you were also a Member of Parliament at that

15     time in the Republic Assembly and the Federal Assembly, were these

16     figures officially known to the authorities?

17        A.   Not only were they known --

18             JUDGE DELVOIE:  Mr. Seselj, I hoped that when I told

19     Mr. Zivanovic that he had to respect a pause between your answer and his

20     question, I hoped that you would pick up and remember that you also have

21     to respect a pause between his questions and your answer.  Because if

22     not, it is very difficult for the interpreters to have your -- your

23     statement exactly on the record.  Thank you.

24             MR. ZIVANOVIC: [Interpretation]

25        Q.   Could you please continue.

Page 11310

 1        A.   Not only did the state authorities know this data, it was

 2     broadcast on television and published in newspapers.  As the number of

 3     refugees grew, it was constantly publicised how many of them there were.

 4     It was no secret.

 5        Q.   On page 35, you said in response to certain questions put to you

 6     concerning Zeljko Raznjatovic, Arkan, that he had been in negotiations

 7     with the Office of the Prosecutor.  Could you tell us where did you get

 8     that information?

 9        A.   For the first time, I heard that on Croatian television.  And

10     then in the proceedings against me, I filed a request, a motion, that the

11     OTP share with me all the documents they have on the subject.  The

12     Prosecutor started to object and oppose my motion, to explain that it has

13     nothing to do with my case or the evidence against me.  You can find that

14     in the transcript.  It's obvious they had some dealings with Arkan, which

15     were probably left incomplete because Arkan was killed in Belgrade on

16     15 January 2000, because two high police officials were killed together

17     with him, because they just happened to be there when the murderer walked

18     in on them.

19        Q.   Did you get any official response from the OTP?

20        A.   No, I have not.  They are hiding these documents.  And if memory

21     serves me well, the Prosecutor even said something like:  None of that is

22     in the form of official documents, they are unable to provide me with

23     their work notes, et cetera.  They were making all sorts of excuses.

24        Q.   On page 36 of the transcript, document 1743 was shown to you.

25     You will probably remember the document contains a reference to the army

Page 11311

 1     needing to cleanse, to purge its ranks.  What exactly did you mean?  How

 2     should the army purge its ranks?  From whom?

 3        A.   First of all, there were many spies in the army, mainly Croats,

 4     officers, who, every now and then, would pack a full boot of their cars

 5     with confidential papers and drive off to Croatia.

 6             Second, it needed to be purged of die-hard Communists who had no

 7     fighting skills, no soldierly skills, and constantly carried out

 8     indoctrination in army ranks and prevented the army from doing its job

 9     properly.  And as long as they were there, the people would not respond

10     to mobilisation drives.

11             And the first such cleansing started in May 1992, when the army

12     was led by Blagoje Adzic.  And then we managed to get the army to replace

13     another 40 leading men in August 1993, including Zivota Panic, who was

14     involved in some sort of corruption scandal.  But among the people we

15     wanted to eliminate, the regime also included in that list some people

16     whom they wanted to get rid of, accusing them that they were close to us,

17     the radicals, and they wanted to get rid of them for that reason.  That

18     was a month or two before we began our final showdown with the Socialist

19     Party and Slobodan Milosevic.

20             I remember that I demanded in the National Assembly, in the

21     Federal Assembly, the replacement of the chief of the military security

22     service, Aleksandar Dimitrijevic and - what is the name of that spokesman

23     of the army? - Ljubodrag Stojadinovic.  I threatened that we, the

24     radicals, would not vote for the rebalancing of the budget, for the

25     adjustment of the budget, unless they meet our demands and replace these

Page 11312

 1     two people.  And then the regime blackmailed or bribed a number of our

 2     MPs and thus managed to get a majority in the Federal Assembly.  So our

 3     demand to replace these two colonels was not met.

 4        Q.   Can you tell us -- you said in the first batch about 40 people

 5     were replaced, and in the second one another 40.  Out of all of these

 6     replaced people how many were Serbs?

 7        A.   Most of them were Serbs.  You see, we used to say:  Out of all

 8     the Communists, the worst one are Serb Communists.

 9        Q.   In a nutshell, the shakeup in the army, was it supposed to be on

10     ethnic grounds or on some other grounds?

11        A.   It was not on ethnic grounds but it was well known which Croatian

12     officer was a spy, which was leaking secrets, who was sending documents.

13     But in any case, most of them had fled before the shakeup.  Only two or

14     three were still in their positions when the purges started.  Most of the

15     Serbs who were removed were removed due to the membership in the League

16     of Communists, because of placing hindrances before the attempts of the

17     Serbian people to defend themselves, for incompetence, and so on and so

18     forth.

19             Let me tell one thing.  On the 4th of May, 1991, the Serbian

20     Radical Party in Belgrade held a rally in front of Tito mausoleum.  Tito

21     is the former Communist dictator of Yugoslavia.  The official name of our

22     rally was March on the Flower House and the official demand that we put

23     forth was for Tito's mausoleum to be moved away from Belgrade.  We had

24     applied for permission to hold that rally with the police.  The police

25     did not prohibit it.  We had people in charge of peace and order, and

Page 11313

 1     there were no incidents at all.  In the beginning of May 1991, the JNA

 2     General Staff was on red alert.  They did not want us to interfere with

 3     the image of their Supreme Commander and the then-Colonel Sljivancanin

 4     placed machine-gun nests around Tito's grave and on surrounding buildings

 5     there were snipers deployed.  If we were to start destroying the

 6     mausoleum, they were going to kill us all.

 7             Sljivancanin confirmed it on several occasions here in this

 8     Tribunal.  He never hid the fact.  I believe that in his book that he

 9     published after having been released from prison he spoke about that.

10     The title of the book, "I was defending the truth," is ironic because he

11     never told the truth, he never wrote the truth.  In the book he only

12     speaks about his fellow prisoners, what people cooked, what games they

13     played, how they dressed, and so on and so forth, below any threshold of

14     dignity in any case.

15        Q.   You also said on page 38, inter alia, that you filed another

16     criminal report against Arkan and that that was sometime in 1991 or 1992

17     or thereabouts.  You said that it would amount to nothing.

18             Can you tell us very briefly when that was, who did you file the

19     report with, and who told you that it would amount to nothing?

20        A.   In Belgrade there was a person called Iso Lero.  He was a member

21     of the Roma people and he was the owner of a security agency.  He was in

22     the casino in the building of Beogradjanka in the very centre of

23     Belgrade.  You know it very well, don't you.  He got drunk and he saw

24     Arkan's poster or Arkan's photo.  He pulled out a pistol and opened fire

25     at the photo.  When Arkan heard that, he sent a group of his men to find

Page 11314

 1     him.  They located them, indeed.  They kidnapped him and they brought --

 2     took him to Slavonia, to Erdut.  And there Arkan kept him, tortured him,

 3     beat him for a while, and then he ordered that he should be killed.  They

 4     pored concrete over his legs and they threw him into the Danube.

 5             One of Arkan's men that defected from Arkan's unit came to me and

 6     told me all that.  With the help of -- of our volunteers I provided him

 7     with the shelter.  He gave a statement, he described the whole event.  I

 8     found him a shelter in the interior of Serbian -- I believe that he spent

 9     some time with Novak Savic in Loznica.  He was a member of the Serbian

10     Radical Party.  And I also filed a criminal report with the police.  The

11     senior police inspector came to me, to the seat of the Serbian Radical

12     Party.  He told me that they already knew about that but they didn't have

13     any capabilities or courage to do anything against Arkan.

14             For example, in 1991, 1992, 1993, Serbia was intersected by

15     police check-points.  On every road there was one.  Everybody had to

16     stop.  Their IDs were checked.  Their vehicles were inspected because

17     there was a constant fear of terrorist actions and the like.  Arkan could

18     zoom in through those check-points, never paying any heed to the police.

19     Not a single policemen could tell him anything, and many police officers

20     even grovelled up to him.  The only person that Arkan feared to a certain

21     extent was Radovan Stojicic, Badza.  When Radovan Stojicic, Badza, was

22     killed --

23             JUDGE DELVOIE:  Mr. Zivanovic?

24             MR. ZIVANOVIC:  Yes.

25             JUDGE DELVOIE:  Do you still remember the question you put to the

Page 11315

 1     witness?

 2             MR. ZIVANOVIC:  Yes.  Yes, Your Honour.

 3             JUDGE DELVOIE:  Okay.  That's good.

 4             MR. ZIVANOVIC: [Interpretation]

 5        Q.   I believe that you have answered my question.  We don't have to

 6     go into further detail.

 7             One more question within that context was about your claim that

 8     Arkan and Goran Hadzic were in cahoots.  We can look at it on the screen.

 9     However, I read that part of your book.  You said "the former president

10     of Serbian Krajina."  That's how you described Goran Hadzic.

11             When this was written, what was your relationship with

12     Goran Hadzic at the time?

13        A.   The relationship was hostile, absolutely hostile.  I believe that

14     that was in 1994.  In 1993, I attacked him verbally at the general

15     Serbian Assembly in the Sava centre at the beginning of May.  And in

16     November 1993 with -- a group of other officials of the Republic of

17     Serbian Krajina attacked me in writing and the entire Serbian Radical

18     Party and so on and so forth.  So then there was a lot of hostility.

19     There was no love lost between the two of us.

20             And the foundation for the claim about us being in cahoots was

21     the fact that Hadzic appeared in public together with me in the same

22     photos but -- with Arkan.  But my subsequent investigations revealed that

23     Arkan imposed themselves on anybody.  He, for example, took a petrol

24     station near Erdut and proclaimed it his.  When Badza left Slavonia, he

25     took over the training centre in Erdut and nobody dared approach it from

Page 11316

 1     then on, neither the military or the police.  In 1991 he entered the

 2     session of the government and sat down, and none of the ministers dared

 3     asked him what he was doing there.  He got involved in any debate and

 4     started talking nonsense.  So nobody could do anything to him.  The only

 5     person in all of Serbia, in the entire Serbian people, who had the

 6     courage to confront Arkan publicly and directly was myself.

 7        Q.   I wanted to ask you - you will find it on page 41 - you were

 8     shown an exhibit from the Prosecutor's list pursuant to Rule 65.

 9             MR. ZIVANOVIC: [Interpretation] 6611.  Tab 137.  It is P3257.

10     That's how it was admitted.  Or perhaps 32 --

11             JUDGE DELVOIE:  Mr. Zivanovic?

12             MR. ZIVANOVIC:  [Interpretation] -- or perhaps 3258.

13             JUDGE DELVOIE:  Please convey to the witness the court reporter's

14     note.

15             THE WITNESS: [Interpretation] I see it, Mr. President.  I've

16     taken note.  I'll try to do what I can.

17             JUDGE DELVOIE:  Thank you.

18             MR. ZIVANOVIC: [Interpretation] I'd like to call up P3258.

19             I'm sure that this is not the document that I need.

20        Q.   I'll try to put a question to you without the document.  I can't

21     find the page that I need.  It is about a decision by which your

22     application to register the Serbian Radical Movement was denied.  I am

23     sure that you remember that was shown to you earlier today.  Actually, it

24     was the registration of the Serbian Chetnik Movement.

25             You said -- you saw in the statement of reasons that this was

Page 11317

 1     done because they were defeated during -- in the Second World War and

 2     national courts had decided that they had committed crimes against

 3     various ethnic groups.

 4             What national courts were in question or people's courts?

 5        A.   When the decision was issued about our registration being denied,

 6     the regime was still fully Communist and all the ministers were Communist

 7     ministers.  The elections took place only in December of that year.  Even

 8     after the elections, the regime could not get rid of its Communist chains

 9     for quite a while.  The decision on denying our application is full of

10     Communist prejudices.

11             People's courts never tried any Chetniks.  They tried -- the

12     courts that tried them were Communist courts and they executed most of

13     the Chetniks.  They court-martialed them and summarily executed them.

14     When Drazen Mihajlovic was put on trial, the two-tier principle was

15     encroached.  He was -- the sentence was passed one day and the following

16     day he was executed.  He did not have the right to appeal.  The only

17     thing that he could do was to apply for pardon within a couple of hours

18     and that was all.

19             In any case, the Communists rely on the experience of the

20     Nuremberg trials.  There also there was no right of appeal.  The

21     sentences were passed and the accused were executed.  I'm not sorry that

22     they were executed.  I would have done it without a trial.  But basic

23     legal principles had to be honoured even with respect of the most serious

24     criminals.

25             And now back to the Chetnik movement.  It was indeed defeated in

Page 11318

 1     the Second World War but that was due to -- the Churchill's treason and

 2     the treason --

 3             JUDGE DELVOIE:  Mr. Seselj, as Mr. Zivanovic doesn't intervene,

 4     although his time is almost completely over, I'll do.  You probably don't

 5     remember the question anymore, but you answered the question.

 6             MR. ZIVANOVIC:  That's correct, Your Honour, and I --

 7             THE WITNESS: [Interpretation] Mr. President, I remember the

 8     question very well.  The question was about people's courts that

 9     allegedly tried Chetniks.

10             JUDGE DELVOIE:  So then please --

11             THE WITNESS: [Interpretation] I am getting on, but I'm not that

12     old not to remember a simple question.

13             JUDGE DELVOIE:  Okay.  Then the problem is not your memory, but

14     the problem is your talkativity, perhaps.

15             Mr. Zivanovic, how many questions do you --

16             MR. ZIVANOVIC:  I've just finished.

17        Q.   [Interpretation] Thank you, Mr. Seselj.  I have no further

18     questions for you.

19             JUDGE DELVOIE:  Thank you.

20             Yes, Mr. Terzic.

21             MR. TERZIC: [Interpretation] Mr. President, with regard to

22     today's session, I would like to point out a procedural problem.  During

23     the previous break this was already raised in the record.  We read parts

24     of the record from the Seselj trial which does not contain all the

25     elements that should have been recorded.  There seems to be a problem


Page 11319

 1     here.  Therefore, I would kindly ask you to send the transcript from this

 2     trial to both me and Dr. Seselj, and this will enable us to react on

 3     time.  Thank you.

 4             JUDGE DELVOIE:  I'm not quite sure about the nature of your

 5     request or the -- the foundation of it.  Are you saying that parts of the

 6     transcript have been read in court but didn't get into the transcript?

 7             MR. TERZIC: [Interpretation] No, you didn't understand me.  The

 8     Prosecutor read part of the record from the Seselj trial which does not

 9     exist.  In that case, this record does not exist.  However, it has become

10     part of the record in this trial.

11             JUDGE DELVOIE:  And what --

12             MR. TERZIC: [Interpretation] Judge Antonetti ordered that part of

13     that record to be expunged.  That's why we need to have the record of

14     this trial.

15             JUDGE DELVOIE:  I think you are wrong, Mr. Terzic.

16     Judge Antonetti did not order to expunge.  He ordered to redact which is

17     different.  The redacted version is the version that goes into the

18     public.

19             MR. TERZIC: [Interpretation] Well, that's what I meant.

20             JUDGE DELVOIE:  So the redacted version is in the public but the

21     original version exists officially.  And Mr. Seselj, as an accused, has

22     access to the unredacted version.  There's nothing wrong with that.  And

23     Ms. Biersay took the precaution to read the unredacted part in private

24     session so that it does not go into the public, which is in conformity

25     with what Judge Antonetti ordered.

Page 11320

 1             Yes, go ahead.

 2             MR. TERZIC: [Interpretation] Yes.  But Mr. Seselj does not have

 3     that version.  It has never been sent to him.  The problem lies in the

 4     fact that the Prosecutor has one version of the record and Seselj has the

 5     other version of the record.  Both parties in the proceedings should have

 6     at their disposal the identical version of the transcript.

 7                           [Trial Chamber and Legal Officer confer]

 8             JUDGE DELVOIE:  I personally couldn't agree more with you,

 9     Mr. Terzic.  But if Mr. Seselj does not have the original transcript, for

10     one reason or the other, he should have.  And if he wants to have it, I

11     don't even know whether he was to request for it, but if that's the only

12     way that he can get it, he has to request for it in his own case, not in

13     this one.

14             If that is all, Mr. Seselj, thank you for your assistance with

15     your testimony.  You are now released as a witness.  Thank you very much.

16                           [The witness withdrew]

17             JUDGE DELVOIE:  Thank you.  Thank you to you, too, Mr. Terzic,

18     for assisting us.  If you want to be excused, you can.  If you want to

19     stay, we -- I think we will finish the hearing here, Mr. Zivanovic?

20     That's what we agreed upon; right?

21             MR. ZIVANOVIC:  Correct, Your Honour.

22             JUDGE DELVOIE:  Okay.  And we will come back tomorrow for the

23     next Defence witness.  Tomorrow, 9.00.

24             Court adjourned.

25                            --- Whereupon the hearing adjourned at 1.52 p.m.,

Page 11321

 1                           to be reconvened on Thursday, the 11th day of

 2                           September, 2014, at 9.00 a.m.