Tribunal Criminal Tribunal for the Former Yugoslavia

Page 1853

 1                          Thursday, 8 November 2007

 2                          [Statement of the Accused]

 3                          [Open session]

 4                          --- Upon commencing at 8.59 a.m.

 5                          [The accused entered court]

 6            JUDGE ANTONETTI: [Interpretation] Mr. Registrar, kindly call the

 7    case.

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

 9    is case number IT-03-67-T, the Prosecutor versus Vojislav Seselj.

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

11            Very well.  Today is Thursday, the 8th of November, 2007.  My

12    greetings to all and everyone in the courtroom.  Ms. Dahl on behalf of the

13    Prosecution; Mr. Seselj; the court deputy; the Legal Officers; the Senior

14    Legal Officers; and also the usher assisting; the interpreters; and the

15    security guards.  You know that today's hearing is devoted to the

16    opening -- or the statement by the accused pursuant to Rule 84 bis.

17    Therefore, Mr. Seselj was granted the entire day, the entire morning, that

18    is, four hours for the purpose of his statement.

19            But before I give him the floor, there's something to say,

20    Ms. Dahl?

21            MS. DAHL:  Yes, Your Honour.  Two points, one regarding security

22    and the other one regarding Mr. Seselj's statement this morning.

23    Yesterday during my opening there was an incident that I saw out of the

24    corner of my eye that involved the security guards and persons in the

25    public gallery having contact or some communication with Mr. Seselj,

Page 1854

 1    and I would like to instruct Mr. Seselj to refrain from

 2    communicating in any manner with members in the personal gallery -- I'm

 3    sorry the public gallery, be they friends or people whom he dislikes.  I

 4    don't know the details of the incident, but I did see the security guards

 5    shooing someone away from inside this courtroom to people in the public

 6    gallery.

 7            The second concerns a request that Mr. Seselj be warned before he

 8    makes his statement that if he says anything that is incriminating, that

 9    the Chamber can use it against him in adjudicating this case if the

10    Chamber credits it with probative value.  Self-representation is hazardous

11    in this respect.  The accused may in presenting his defence convict

12    himself, and I want him to be chastened that in this instance I will use

13    what he says against him.

14            JUDGE ANTONETTI: [Interpretation] Very well, on the basis of what

15    you just told me I am going to read out Rule 84 bis for everybody to

16    understand properly, including those who follow the proceedings.  84 bis

17    from the Rules of Procedure and Evidence:

18            "Statement or the accused.

19            "(A) after the opening statements of the parties or if pursuant to

20    Rule 84 the Defence elects to defer its opening statement after the

21    opening statement of the Prosecutor, if any, the accused may if he or she

22    so wishes make a statement under the control of the Trial Chamber and with

23    the agreement of the Trial Chamber.  The accused shall not be compelled to

24    make a solemn declaration and shall not be examined about the content of

25    the statement.

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 1            "(B) the Trial Chamber shall decide on the probative value, if

 2    any, of the statement."

 3            The Trial Chamber therefore concludes that the accused can speak,

 4    make a statement before -- after the opening statement of the Prosecution

 5    with the agreement of and under the control of the Trial Chamber, so it

 6    does not have to make a solemn declaration and he shall not be examined

 7    about the content of the statement.  So Rule (B) states that the

 8    Trial Chamber shall decide on the probative value, if any, of the

 9    statement.  So this is what sets out Rule 84 bis.

10            Regarding this incident, indeed, I noticed yesterday that there

11    was a security guard making some gestures, I don't know what it was.  I'm

12    sure that there's going to be a written report by the security guard to

13    his hierarchy as to what happened.

14            Mr. Seselj, you have the floor.

15            THE ACCUSED: [Microphone not activated]

16            THE INTERPRETER:  Microphone, please.

17            THE ACCUSED: [Interpretation] Judges, Ms. Dahl is resorting to

18    untruths again and inappropriate interventions just to spend my time, I

19    believe.  She was not capable of using her own four hours, she spoke for

20    less than three hours and now she is simply envious because I am in a

21    position to speak for four hours or perhaps even more than that.  There

22    was no incident yesterday.  What happened was that a man from the public

23    gallery was sitting here right in front of me and he was staring at me in

24    a way that I personally considered to be provocative.  Perhaps it even

25    wasn't even provocative.  What crossed my mind was that something similar

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 1    happened to Viktor Korchnoi in his test match with Karpov or rather

 2    Spassky.  Now, was it in the Philippines, years ago.  I drew the guard's

 3    attention to that, the guard intervened, and they moved that man to

 4    another row in the public gallery.  Noting else happened.  I really don't

 5    see why we are turning a fly into an elephant.

 6            When the Trial Chamber or the Prosecutor are trying to violate my

 7    rights, I really know how to fight for them, and now the Prosecutor is

 8    cautioning me not to incriminate myself.  I am going to talk about the

 9    facts here, regardless of whether they incriminate me or not.  I do not

10    stop at anything in terms of your views on my positions, my behaviour, my

11    conduct over the past 15 or 20 years, I'm not interested in that.  I hold

12    the same positions today that I held 15 or 17 years ago.  I have perfected

13    them even further.  However, since you have started wasting my precious

14    time already with totally insignificant matters, I want to tell you

15    something very significant very briefly.  I established contact with my

16    associates and they found an agency Matiko in Belgrade, a translation

17    agency, translation for into foreign languages Proleterski Solidarnosti

18    number 63, the telephone number is 334-1335 in Belgrade.

19            They are in a position to translate both of my main books, the

20    ones that I insist on up until the end of January for 25.000 euro.  The

21    price can go down 4 or 5.000 euro perhaps, if we are talking about the

22    parts that the Prosecution already translated; that's about a third of

23    that book, "The Ideology of Serb Nationalism," so the Registry can reduce

24    the amount by that number of pages.  So I have handled that and I hope

25    that in the future I will not have to do the work of the Registry.

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 1            JUDGE ANTONETTI: [Interpretation] Very well.  Thank you for the

 2    information relating to the translation of your book, but now you have the

 3    floor for your statement further to the Rules.

 4            THE ACCUSED: [Interpretation] Judges, I have no intention of

 5    personally hurting any of you when I say here that I am being tried by an

 6    illegal and illegitimate court.  I am talking about that an institution

 7    that was unlawfully established in 1993 by the Security Council of the

 8    United Nations, in direct contravention of international customary law.

 9    The Security Council did that according to the diktat of the United States

10    of America.  During those years they were an unchallenged world power and

11    the other permanent members of the Security Council practically carried

12    out everything they wished without any objections.  The members of the Security

13    Council then inappropriately invoked Chapter 7 of the Charter of the United

14    Nations speaking about the establishment and preservation of world peace

15    or peace in certain regions.  This is the first court in the history of

16    mankind that was established as a means of attaining peace or preserving

17    peace.

18            So already at the outset the establishment of this court was not

19    aimed at establishing justice, but establishing a particular type of

20    peace, which is called Pax Americana increasingly in current political

21    practice, on the basis of Pax Romana, the alleged peace operations of the

22    ancient Roman Empire.  This court was established unlawfully but it also

23    has a pronounced anti-Serb orientation.  Proof of that is the fact that an

24    incredibly large number of Serbs were processed before this court in

25    relation to members of other ethnicities.  Also on a regular basis Serbs

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 1    are being sentenced to far harsher sentences than Muslims, Croats,

 2    Albanians, and others.

 3            The task of this court has been carried out through many of its

 4    judgements, and that task is to falsify modern Serb history.  A drastic

 5    example of this falsification of modern Serb history is the proclamation

 6    of a genocide having taken place in Srebrenica, inventing that 7 or 8.000

 7    Muslim prisoners of war were executed there.  Of course the truth is quite

 8    different.  The total number of corpses found was 2500, although the

 9    entire terrain was searched, dug up, a cemetery was organized, and

10    pedantic researchers established that out of these 2500 corpses, over 800

11    of them were persons who got killed on the Muslim side between 1992 and

12    1995 and one should take into account the fact that many Muslim soldiers

13    got killed during the breakthrough and also in mutual conflicts between

14    the Muslims themselves.

15            Dutch officers and the Dutch parliament were informed that indeed

16    a crime had happened, I'm not denying that, but 1.000 prisoners of war

17    were executed, it's an atrocious crime but it's not genocide.  However,

18    what was done in a premeditated manner was to brand the Serb people as a

19    genocidal people, this leading to a ruling of the International Court of

20    Justice as well.  A protected group could only be all the Muslims of

21    Bosnia and Herzegovina, the 2.170.000 of them living there, not only the

22    Muslims of Srebrenica.  This was abuse in a premeditated fashion, that is

23    to say a UN-protected area was abused, and it was qualified as a protected

24    group on the basis of the convention of genocide.

25            This trick proved to be successful in the Western media, but

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 1    thanks to me and people like me this will never succeed among the Serb

 2    people.  Why am I being tried here?  Because I became unbearable to the

 3    Americans and to their allies in Serbia, because already in 2002, there

 4    was the danger of I and my political party toppling the puppet regime of

 5    traitors that was established after the American coup of October 2000.

 6    The Americans want to have their cronies in power so that they could

 7    obtain other anti-Serb interests, so they could take away Kosovo from us,

 8    in the future Vojvodina as well, and who knows what else after that.

 9            Now why are the Americans and their Western allies against us

10    Serbs?  Because we are a small people but a people that cannot be

11    subjugated, because we are close to the Russians too, as allies, from a

12    cultural point of view, from any point of view.  We are originally

13    Russians, actually, we are originally eastern Slavs, and we are not

14    ashamed of that origin of ours, as opposed to the Catholic Slavs who

15    renounced their origin and even agreed to go against the Russians, to

16    become the enemies of the Russians.  We did not do that.  We are their

17    allies, we are small-scale Russians in the Balkans, that is why the

18    Americans hate us and that is why they are trying to destroy us.

19            An indictment lacking in seriousness was issued me.

20    Mr. President, while you were the Pre-Trial Judge, you know that on a few

21    occasions I expressed my readiness to have a direct dialogue with the

22    Prosecutor to deal with the some of the problematic issues in this

23    indictment and perhaps I could even teach them how to correct some of the

24    inaccuracies in terms of my biography; however, the Prosecutor has been

25    shunning this for the past five years like the plague, but my only

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 1    precondition was to have my associates present and to have all of this

 2    videotaped.

 3            This indictment was written in haste, it was written by legally

 4    incapable people, not exactly prone to thinking, and now I'm going to

 5    prove the ultimate incompetence of The Hague Prosecutor’s Office in this way.

 6    If we look at the first paragraph it says that from 1981 to 1984 I taught political

 7    science at Sarajevo University as an assistant lecturer. What an amazing stupidity.

 8    What goes on in your country?  Can assitant lecturers give lectures on political

 9    science or any other subject? They just have classes with students. It is

10    professors – assistant professors, associate professors, full professors, who

11    give lectures. Even when I was expelled from the department, I held the title

12    of research associate that was equivalent to that of assistant professor.

13            Then in paragraph 2 the Prosecutor says that I was originally a

14    communist.  That is not true.  Originally I was a baby and I became a

15    communist when I became an adolescent, that is, when I was admitted into

16    the communist party, I wasn't even 17-years-old.  I was thrown out of the

17    communist party in a spectacular way as soon as I ceased to be an

18    adolescent.  It was really spectacular, the way they threw me out.

19            Now, why was that placed here at all?  You know we lived under a

20    communist regime of a totalitarian nature under Tito's dictatorship and it

21    was customary there that young people be admitted into all political

22    organizations led by the communist party, and when they are on the

23    threshold of maturity, they take the best into the communist party, the

24    best students, the best pupils, et cetera.  That was the system.  Marxism

25    was the only view of the world that was allowed that could have been

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 1    studied at schools, universities, et cetera.  When I completed all of

 2    these schools and started thinking with my own head, I rebelled against

 3    communism.  Since I did not start as a communist, I was not originally a

 4    communist but a baby.  As a baby I was very troublesome.

 5            The Prosecutor had to dig far deeper into my past and to say what

 6    it is what it is I did as a baby, what I did in elementary school, and

 7    what I did as a university student, and so on and so forth.

 8            It says here that when I became critical of the communist regime

 9    in the early 1980s, I developed close relations with a group of Serb

10    nationalists.  What group of Serb nationalists?  At that time there was no

11    group of Serb nationalists.  And they are trying, in a premeditated way,

12    to find some group of Serb nationalists in the 1980s and to proclaim that

13    that group is the root cause of all evil in the Balkans, and they're even

14    trying to identify that group with the entire Serbian Academy of Sciences

15    and Arts.

16            Now, who is it that I established contact with, Ljubomir Tadic,

17    the father of the present-day president of Serbia, Boris Tadic; also with

18    Boris Tadic himself; also with Veselinka Zastavnikovic who was I was

19    arrested with, she was at the time Boris Tadic's wife, and we were

20    released from prison in 1984.  I was friends with Milovan Djilas, I was

21    friends with Nebojsa Popov, Vesna Pesic, I even went to her house,

22    Vuk Draskovic.  All of them are now notorious Serb traitors.  Also I was

23    friends with Dobrica Cosic who recently wrote in a book of his that he

24    considers himself to be the spiritual father of Zoran Djindjic and he

25    never said that he's a nationalist.  He never said that he himself was a

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 1    nationalist.  None of them ever said that they were Serb nationalists.

 2    And they did not expose themselves that way.  Most of them are the

 3    representatives of the so-called Praksis group of thought, these are

 4    dissidents within the Marxist view of the world.

 5            And during those years I exposed myself as a Serb nationalist and

 6    I am the only Serb intellectual who in the 1980s said of myself publicly,

 7    openly, and everywhere, that he was a Serb nationalist.  That's why my

 8    books were banned, that's why I wasn't able to find a job, that's why I

 9    was restricted in various other ways.  That does not mean that there were

10    not other Serb nationalists, there were millions of people at that time

11    who were Serb nationalists, however among the Serb intellectuals there was

12    not a single person who was courageous to state publicly, "I am a Serb

13    nationalist."  There were not even those who were able to say of

14    themselves, "I am anti-communist."  There were no people like that.  So if

15    they criticised the communist system, they did so with the frameworks of

16    the Marxist ideology.

17            I am proud that for all those years I was the sole person who

18    stated publicly, loud and clear, that I was a Serb nationalist.  Why

19    didn't others do that?  Because they were afraid of the repressive

20    measures of the communist regime.  The nationalists were persecuted in the

21    harshest manner, but I was not afraid.  I am not afraid today either.  I

22    have never been afraid.  I have never been afraid of anything in this

23    world, and in my acts there were just two limitations.  As Immanuel Kant

24    would have put it, I am limited by my own internal law and the starry sky

25    above me, the heavens.  Nothing more than that.  No laws, no courts, no

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 1    force, no state, no international institutions, nothing can limit and

 2    restrict me, if I consider that they are behaving in an immoral way,

 3    contrary to the law and illegally, and I am proud of that.

 4            If you take a look at the indictment you can see several other

 5    very strange and ludicrous things.  In point 4, for example, it says that

 6    in June 1990 I formed the Serbian Revival Movement Party -- Renewal

 7    Movement Party.  That is a lie.  I was never a member of the Serbian

 8    National Renewal party.  Serbian National Renewal on the 6th of January,

 9    not in June 1990, but on the 6th of January 1990, Nova Pazova was

10    organized by Vuk Draskovic with Mirko Jovic.  And I was never a member of

11    that Serbian National Renewal Party myself and that Serbian National

12    Renewal was never renamed the Serbian Chetnik Movement and that is

13    something that the whole of Serbia knows.

14            Mrs. Dahl couldn't care less that in front of the whole of Serbia

15    I have irrefutable proof that the Prosecution is lying.  They don't mind

16    about that.  That's not the only lie.  I'll show you many other lies.  And

17    then they go on to say that the elections in December 1990, his party won

18    almost 100.000 votes.  That is a lie.  My party did not take part in the

19    elections in 1990, it just did not take part at all.  My party was called

20    the Serbian Chetnik Movement and the communist regime which had not been

21    reformed yet, led by Slobodan Milosevic, refused to register the Serbian

22    Chetnik Movement as a political party.  And so we were not able to take

23    part in the elections at all, and I personally from prison - it was

24    Milosevic's prison - that I put myself forward as candidate as president

25    of the republic as a candidate put forward by the Group of Citizens, and I

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 1    was in prison when my nomination was announced on television.  And as an

 2    individual, I won 100.000 votes as one of the Group of Citizens.

 3            Now, perhaps it doesn't seem very serious to you that I insist on

 4    this because this is important for me, because it is proof that the

 5    indictment was written without any seriousness.  And then it says soon

 6    after that the authorities and the SFRY banned the Serbian Chetnik

 7    Movement.  That is a lie again.  Never did anybody ban the Serbian Chetnik

 8    Movement.  It was not banned.  They just refused to register it as a

 9    political party because the Ministry of Justice said a political party of

10    that kind with that name cannot be registered, but it continued to

11    function and had a newspaper which was called Velika Srbija and the

12    authorities never meddled in this and it was the Serbian authorities that

13    had the power.

14            Next it says in paragraph 4 of the indictment once again that

15    after the Serbian Radical Party was founded and the Serbian Radical Party

16    was founded with the unity of the Serbian Chetnik Movement and the

17    National Radical party as an amalgamation on the 23rd of February, 1991,

18    it says that at daily rallies during the election campaign I called for

19    Serb unity and war against Serb's historic enemies, namely the

20    populations, the ethnic Croat, Muslim, and Albanian populations within the

21    territories of the former Yugoslavia it says here.  That's an absolute

22    lie.  That was February 1991 still.  I always called for the unity of

23    Serbs, as I indeed do today, but at that time I didn't call to war and I

24    never called anybody to war unless it was a question of defence, the

25    defence of the Serb people.

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 1            Defence from whom?  From various enemies, traditional enemies, the

 2    Germans and the Vatican in the first place, and their exponents on

 3    Yugoslav territory.  Because this war, the war in which we Serbs have been

 4    routed, is not a war against the Croats and the Muslims that we wage, or

 5    the Albanians for that matter but against their bosses, the Vatican,

 6    Germany, America, the North Atlantic pact and so on and so forth.  And in

 7    the final stage of that war, the North Atlantic pact was directly exposed

 8    because its exponents got tired, the puppets got tired, so they had to

 9    step in.

10            Next what is claimed here, and as they cannot ascribe a single

11    crime to me, let alone, the heart-rendering story that we heard yesterday

12    and I was struck by that story - if it's true, I don't know whether it is

13    true - about a Muslim mother that was left without two children, whose two

14    young children were allegedly killed and we heard this heart-breaking

15    story for half an hour.  So that is a true example of dirty propaganda.

16    Where is the evidence and proof of those two children having been killed

17    and how is that linked to me?  In what way?  Did I wish the war?  Did I

18    cause a war, and then that happened in the war?  So how have I been

19    brought into connection with those killings?  If those killings took place

20    and we'll see that during this trial.

21            Now, furthermore what is used here is a whole construction.  It is

22    the joint criminal enterprise concept that is being used, and the

23    Prosecution, in an artificial way, is linking me up with that.  And then

24    they list a whole series of names, ad hoc.  Now, they've added to that

25    list and added Radmilo Bogdanovic, who at the end of March or the

Page 1866

 1    beginning of April 1991 tendered his resignation as minister of the

 2    interior and from that time he did not occupy a prominent post in state

 3    power and authority, he was a deputy in parliament after that for a number

 4    of years.  Then they added Milan Babic, so today it's one person, tomorrow

 5    it can be somebody else.

 6            Any enterprise was impossible in which I would take part with the

 7    persons listed.  I was openly hostile to some of them, others I never met

 8    in my life, as for others again, I asked that they be replaced like

 9    Kadijevic, the then-minister of defence and so on and so forth.

10            Now, I'm not going to tire you with long explanations as to my

11    relationships with each of these people, I have already explained that in

12    testifying during the Slobodan Milosevic trial and as recently you made a

13    ruling that the entire transcript of my testimony at that trial be entered

14    into evidence, and I did not oppose that.  There's no need for me to

15    repeat it.  You have it.  But I would like to refer to the construction

16    itself.  The construction of participating in a joint criminal enterprise

17    as a form of executing a crime, a criminal act, has seem to become

18    practice in The Hague Tribunal in practically all the trials of the

19    accused Serbs, although there is no statutory grounds for that.  The

20    Statute of the International Tribunal for the former Yugoslavia knows of

21    no such provision.  Those people in The Hague who constructed it and

22    promoted it in order to introduce through the JCE are the principle of

23    objective responsibility which has long been rejected in criminal law in

24    the civilised world.  In addition to this, it serves as grounds to,

25    through the proceedings, quite by chance, try an individual and a whole

Page 1867

 1    group.  So through the trial of an individual, you are in fact trying a

 2    whole group.  And the group does not have firm members and a firm

 3    framework.

 4            If you look at the -- it's all arbitrary.  So if you look at the

 5    joint criminal enterprise in my indictment, in Martic's, Babic's, and

 6    Milosevic's indictment, this is not strictly defined because there are

 7    various names that are bandied about.  For a group to be defined, a common

 8    goal is proclaimed or a common undertaking, an enterprise, and then it is

 9    being proved by the consequences of war devastation exclusively, whose

10    tendentious identification is made in a highly selective manner and always

11    to the detriment of the Serbs.  It then appears that it was only the Serbs

12    who committed crimes, that it was only Serbs who pilfered and plundered

13    and destroyed and destroyed religious buildings, but crimes did happen in

14    the war and the crimes were perpetrated by the members of all the warring

15    sides, all the parties to the war.  And all of them committed crimes of

16    the same nature.  So here all we can do is to quantify crimes and not to

17    qualify the crimes.

18            By falsifying historical facts and systematic manipulation with

19    false witnesses from one judgement to another, it -- insistence is made on

20    the fact that the Serbs are the main culprits for the war and everything

21    that the war brought with it.  What was proclaimed was that they

22    intentionally and in a planned manner carried out war crimes in order to

23    realise and further their own political and statehood aims, and this they

24    say was done in such a brutal way that we have a situation in which every

25    Serb, who in any way whatsoever took part in the Serb war effort, can

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 1    quite simply be proclaimed a participant in the joint criminal enterprise.

 2    That's how far they went.  As a member of this joint criminal enterprise,

 3    they can then be tried for every crime committed by the Serb side,

 4    regardless of whether that person ever heard of the crime having been

 5    committed somewhere or regardless of whether the person involved knew the

 6    perpetrators.

 7            So the perpetrators are immaterial or persons who are participants

 8    in crimes or criminal acts.  The only thing that is important is that the

 9    criminals were participants of the Serb war effort even if they were

10    highly detrimental to the Serbs.  Since certain participants in the war

11    efforts committed various crimes, then by the same token it would appear

12    that all the other participants in the war effort are to blame, regardless

13    of the fact that they did not agree with the crimes committed or whether

14    they stood up to those crimes.  And criminal responsibility is introduced

15    for other peoples' conduct and behaviour with which the accused had

16    nothing to do and from that to determining responsibility for the whole of

17    the Serb nation is just one step away.

18            As for this construction of the joint criminal enterprise, there

19    is no grounds for that in international criminal law nor in national

20    jurisdictions either.  The Statute of The Hague Tribunal also does not

21    know of this concept and it was introduced into its practice for the first

22    time only in the Dusko Tadic judgement on the 15th of July, 1999.

23    Afterwards, there was a lot of wavering and wondering in determining the

24    frameworks for this joint criminal enterprise, where it was a joint

25    intention, plan, undertaking, or whatever, which are not synonymous terms

Page 1869

 1    although the Trial Chambers of The Hague Tribunal tried to make them

 2    appear as being synonyms.  And although the statutory norms exclusively

 3    insist on individual criminal responsibility, this artificial construction

 4    of a joint criminal enterprise introduces directly the principle of

 5    collective responsibility by which the statutory jurisdiction of the

 6    Tribunal is being expanded and the framework of the responsibilities for

 7    the accused is being enlarged.  It is not necessary to prove that they,

 8    the co-perpetrators, had allegedly a joint intent by perpetrating the

 9    crime.  All that is sufficient is that one of the actors in the joint

10    criminal enterprise could have committed crimes and a participant had the

11    consciousness of knowing of the consequences willingly took on that risk.

12            Now, since individual criminal responsibility was not treated at

13    the relevant time and in the relevant area, the only applicable law is

14    Yugoslav criminal law.  None of the participants who were perpetrators or

15    collaborated in these events need not have known that there was a criminal

16    act afoot.  They did not have the consciousness of an act that was a

17    crime.  So nullum crimen sine lege is being overridden and the accused are

18    being judged without any -- without having committed a crime.  So to take

19    on criminal proceedings and to bring people to trial depends on arbitrary

20    choice and political needs.  So with this kind of construction, instead of

21    the rule of law, the Tribunal has demonstrated the rule of lawyers,

22    alleged professionals who have no conscience and have allowed themselves

23    during a criminal trial to create legal norms having the force of law, and

24    their arbitrariness has put justice on a second level.

25            Now, delayed justice is justice denied, and The Hague trials have

Page 1870

 1    been going on for a long time.  Whether accused are waiting for the start

 2    of trial or for evidence or for the appeals process.  The Hague judges at

 3    their own initiative expanded the notion of command responsibility, but also

 4    their own jurisdiction. They were very arrogant in explaining these actions,

 5    publicly going against their critics. And this in the face of all the

 6    criticisms.  For this concept of the joint criminal enterprise to be as

 7    believable as possible, they accepted obvious falsifications and

 8    forgeries, things that have been conjured up and overexaggerated crimes.

 9    Their unilateral selection in order to cover up crimes of the war-time enemies

10    of the Serbs and the intentions to further certain goals or reach certain

11    goals, and this criminal adjective has been appended is seen by subsequent

12    events.  With The Hague judgements, in a premeditated and systematic and

13    conscious manner, historical facts are being distorted and the truth, too,

14    the truth in inverted commas, the truth is created according to the

15    protagonist of a new world order.  The historical context of the Balkan

16    Wars and the cause and effect is something that nobody is interested in in

17    The Hague Tribunal.  The Hague judges are implementing American dictates

18    because they are very well paid to listen and not to think or to deal with

19    ethical problems.

20            All the American crimes perpetrated during several military

21    interventions by using a sophisticated air force and uranium depleted

22    bombs are collateral damage and humanitarian realisation of supreme justice,

23    whereas the adversaries of Americans are generic and genetic criminals.

24    The Hague Tribunal even investigated crimes committed by the American

25    aggression against Serbia and then they gave up the job, stating that

Page 1871

 1    there were not sufficient elements for criminal proceedings to be

 2    initiated.  So that is proof of this Hague justice, and for this

 3    construction of the joint criminal enterprise to be applied to the Serbs,

 4    the participants in the war, systematic distortion of cause and effect in

 5    the war was carried out.  Anti-Serb prejudice and stereotypes were put

 6    forward and inaugurated as a starting point of The Hague Tribunal's

 7    policies and practice and the preliminary conclusion that the Serbs are

 8    the main culprits for everything that took place.

 9            THE INTERPRETER:  Could the speaker please speak more slowly.

10    Thank you.

11            THE ACCUSED: [Interpretation] Since relevant facts are usually

12    lacking, shameless falsification comes into play if real historical facts

13    are in contradiction --

14            JUDGE ANTONETTI: [Interpretation] Mr. Seselj, could you speak more

15    slowly, please.  The interpreters have difficulty keeping up with you.

16            THE ACCUSED: [Interpretation] I will try, Judge.

17            JUDGE LATTANZI: [Interpretation] Mr. Seselj, I would also like to

18    ask you to lower your voice.  I understand full well, I understand that

19    you have a voice that carries, I also have a voice that carries, but we

20    cannot hear the translation properly in our headsets because your voice is

21    very loud.  Thank you very much.

22            THE ACCUSED: [Interpretation] I will try to speak slower and less

23    loudly, but you have to understand, Mrs. Judge, that adrenaline has been

24    rising in me for five years and now is the day when all that pent-up

25    adrenaline is venting.  I will try, but sometimes I will forget and then

Page 1872

 1    you will again find me too loud.

 2    If real historical facts are in contradiction with the ideological conceptions of

 3    the creators of the new world order, then tant pis for the facts. These courts -

 4    this court does not rely either on historical facts or principles. Rules are

 5   created during trials themselves, and that reminds us of summary and special courts.

 6   This is the most striking indicator of the totalitarian pattern of legal thought

 7    dominating the overall activity of the Hague Tribunal. Although the burden of

 8    proving one’s guilt should be on the Prosecution, in practice, it is the accused

 9    who has to prove his innocence, whereas it is proclaimed that there was a joint

10    criminal enterprise on the Serbian side and the accused is a participant in the

11    JCE, nothing else needs to be proven.

12    The concept of the joint criminal enterprise far overreaches the individualization

13    of culpability and establishes the collective responsibility of the identified,

14    quote unquote, criminal enterprise, which invariably includes the Serbian state.

15    Every citizen of Republika Srpska or the Republic of Serbian Krajina may be

16    indicted and convicted as a participant in the joint criminal enterprise if he had

17    in any way, whatsoever, participated in the war effort of his own people.  If

18    he was not a traitor and if he did not serve Western secret services and

19    their subversive activities, the legal uncertainty of accused Serbs is

20    complete.  They frequently do not know what they are accused of, nor are

21    they capable of effectively refuting the charges.  Instead of individual

22    responsibility being established in a fully legal proceeding with equality

23    of arms, the Hague Tribunal introduces three new forms of liability, inadmissible

24    in modern criminal law. Objective criminal responsibility, liability by

25    analogy, and liability based on assumed guilt.

Page 1873

 1       By arbitrary choice, in the selection of those who are going to be accused,

 2    the basic motives are the politial interests of the Office of the Prosecutor

 3    and its superior international factors who like to present themselves as

 4    vehicles of preserving and establishing peace.  The founders of The Hague

 5    Tribunal intentionally refused to accuse or lay any charges against those

 6    who actually caused the break-up of Yugoslavia, although that was the

 7    primordial crime from which all other crimes arose.  The joint criminal

 8    enterprise could only have been in the break-up of the Yugoslav state, whose

 9    international borders were guaranteed by the final act -- by the final Helsinki

10    Act of the OSCE.  Without determining the responsibility for the beginning of the

11    civil war and without trying not only domestic perpetrators but also international

12    ones, such as German and Vatican supporters, it is out of place to try those who

13    opposed the unilateral breaking up of the Yugoslav state along the seams of the

14    borders of federal units drawn at one point in time by the Communists, arbitrarily

15    and without any legitimate legal document. The Hague Prosecutors very meticulously

16    tried with their indictments, documents, and judgements not to interfere with the

17    foreign policy interests of Western powers or, God forbid, their involvement in the

18    crimes.  With premeditated malice, criminal acts of groups and individuals on the

19    Serb side are exaggerated and hypertrophied in order to lay the guilt on them from

20    the highest political and military authorities.

21            I prepared this to explain as clearly as I can my views on the

22    joint criminal enterprise, as an artificial edifice.  And now I will try

23    to show you what the application of this edifice looks in practice. Mrs. Dahl spoke

24    for slightly less than three hours, accusing me of being virtually the main culprit

25    for the outbreak of the war because I made inflammatory speeches. But the person

Page 1874

 1    who is actually responsible for the beginning of the war basically

 2    participated in the joint criminal enterprise.  Who is responsible for the

 3    beginning of the war?  The one who tried to break up a state that had

 4    existed for almost a hundred years and that was internationally

 5    recognised.  Or was it perhaps the one who tried to prevent unilateral

 6    secession by individual Yugoslav states?  Which one of the two?

 7            The basic joint criminal enterprise was on the side of those who

 8    tried to break up Yugoslavia, primarily Germany and the Vatican, later

 9    joined by the USA.  Yugoslavia could not have been broken up on the

10    borders -- along the borders of federal units, those borders were

11    installed by the communist regime.  That decision, when it was made on

12    administrative borders, it had no legitimacy, legal legitimacy.  You know

13    in the modern world legitimacy can only be established in elections, through the

14    people’s vote, free vote, it was the communist dictatorship that

15    established those federal units after the Second World War.

16            Yugoslavia did not always exist from time immemorial.  From the

17    Second World War in the Balkans there were Serbia, Montenegro, the

18    Austro-Hungarian empire and down in the south, Greece, Albania, and in the

19    east Bulgaria and Romania.  Before the First World War there was no

20    Croatia, no Slovenia, no Bosnia and Herzegovina, no Kosovo and Metohija,

21    no Vojvodina, and so on and so forth.  Victorious Serbia, after the First

22    World War, had within its composition Macedonia, Montenegro, and

23    Vojvodina.  And then the Serb regent Aleksandar Karadjordjevic accepted

24    the request of the popular representation of the state of Slovenes,

25    Croats, and Serbs to join Serbia.  When Croatia was breaking up, Serb,

Page 1875

 1    Croat and Slovene popular representatives met in Zagreb in 1918, they

 2    declared the state of Slovenes, Croats, and Serbs, and its joining to

 3    Serbia.  That state was never recognised anywhere and it lasted for a very

 4    short time, but it is a proof that Serbia existed on one side, including

 5    Macedonia and Vojvodina and Kosovo and Metohija, and on the other hand

 6    there was that state of Croats, Slovenes, and Serbs.

 7            Yugoslavia, if it was breaking up, ripping on the seams, it could

 8    not have ripped on communist borders, it could not have split again into

 9    the pre-war Serbia and the state of Croats, Slovenes, and Serbs because

10    even in that latter one Serbs were one of the constituent state-making

11    peoples.  Serbs were united with one another and along came Croats and

12    Slovenes.  That state was proclaimed as the Kingdom of Serbs, Croats, and

13    Slovenes.  And then in 1920 -- rather, 1929, after the 6th of January

14    coup, King Aleksandar who disbanded the parliament and political parties

15    proclaimed the change of name to Yugoslavia.  Yugoslavia was composed of

16    nine administrative areas, not autonomous regions.  Two of them were Croat,

17    bits and pieces of others were joined in order to create the Banovina of

18    Croatia, but they never had time enough to actually put it into a legal

19    framework.

20            Hitler committed an aggression against the unitary Yugoslav state.

21    He first tried in a peaceful way to get that state to join the tripartite

22    pact and the coalition government of the time who was made up of some Serbian

23    and Croatian political representatives first signed that agreement, but the

24    Serbian people came out into the street and toppled that.  There was a

25    political -- there was a coup and Hitler occupied Yugoslavia.

Page 1876

 1            Having occupied Yugoslavia, Hitler split its territory almost

 2    along the same borders that the Americans are dividing Yugoslavia along

 3    nowadays.  The so-called Independent State of Croatia was proclaimed on

 4    the territory of today's Croatia, Bosnia and Herzegovina, and Srem; Serbia

 5    was directly under German occupation; the rest of Vojvodina was split

 6    between -- divided between Hungary and Germany.  Kosovo and Metohija were

 7    joined to the greater Albania, and Macedonia was given to Bulgaria.  But

 8    the seams are the same, they coincide; they are anti-Serbian.  Within the

 9    Serbian people there were in the war two anti-fascist movements, one was a

10    nationalist, the former king's army, and the other was the partisans.  The

11    Western allies supported the communist partisans, and it was only for that

12    reason that they came out on top.  And what did the Croats do? In 1941, Croats,

13    almost down to the last man, were supporting Hitler.  German papers wrote that

14    the German army was met in Zagreb with such relish that that can only be

15    matched by the welcome given Hitler in his birthplace in Austria.

16            Croats were throughout the war family with Hitler, and there was

17    even a Croat legion with 200.000 soldiers who fought for Hitler before

18    Stalingrad and got killed almost all of them.  That is the essence of the

19    current wars of ours, our conflicts.

20            The communists, following the tradition of the communist

21    international agreement, formed a new project.  First of all, they

22    invented new nations to reduce the ratio of Serbs in the total population,

23    and they found fertile ground for that in Macedonia, in which there was not

24    particular national consciousness, the Macedonian population is something

25    between Bulgarians and Serbs, in the east it is closer to Serbs -- sorry,

Page 1877

 1    in the west it was closer to Serbs, in the west [as interpreted] it was

 2    closer to Bulgarians, but there was no particular political awareness.

 3    They speak a modern Stokavian dialect which is close to Serbian.  In the

 4    beginning, there was no problem with that, but the communists invented,

 5    made up, the Montenegrin nation and the Montenegrin government made people

 6    declare themselves Montenegrin.

 7            20 years after the Second World War, the Muslim nation was

 8    invented, and Muslims were supposedly Serbs who converted to Islam during

 9    the rule of the Ottoman Empire.  They took that religion and they loved

10    it, and why wouldn't they love it because it was close to their heart.

11    However, religion, faith, is not national identity.  That's what the

12    communists invented.

13            Towards the end of the Second World War, the communists carried

14    out federalisation of Yugoslavia.  Since a genocide was committed against

15    Serbs, more than a million Serbs were killed, and the most Serbs were

16    killed by Croat fascists, clerical fascists, called Ustashas, guided by

17    the Roman Catholic church.  Roman Catholic clerics in huge numbers

18    personally with their own hands participated in the slaughter of the

19    Serbian people.  Endless testimony exists of that.  Volumes and volumes of

20    books exist on it, and volumes and volumes of documents.  I hope it is not

21    necessary for me to give you evidence about that here.

22            After this genocide happened, the communists tried through a

23    policy of national reconciliation within the framework of a totalitarian

24    regime to smooth out everything that happened in the Second World War and

25    to form a unified state in which there would be some sort of balance

Page 1878

 1    between six federal units.  That is how, among others, the Croatian

 2    federal unit was created, the Republic of Croatia, the Socialist Republic

 3    of Croatia, but it was constituted in such a way that Serb and Croat

 4    political leaders from that area met and agreed that the Croat federal

 5    unit should exist, but in it the Serb and Croat people would be equal and

 6    they would be constituent people.  What does this status of a constituent

 7    people mean in the Yugoslav theory?  That means that nobody but that

 8    people can decide on its status without the consent of that people, even

 9    if the other people is numerous, which means that the Croatians never had

10    the constitutional right to change the status of the Croatian federal unit

11    or the status of the Serbs within it.  Maybe you never encountered in your

12    career, in your practice so far with this problem, but I'll try to give

13    you an example.

14            Imagine that Mrs. Christine Dahl and I belonged to one and the

15    same social community, and in that social community there is a prescribed

16    way of conduct, obligations, rights, and so on.  We abide by that and this

17    community is working.  Fine.  At -- a disruptive factor appears, and

18    somebody tries to change the status of the members of this community.

19    Imagine me, I weigh 120 kilos, Mrs. Dahl, imagine, weighs 90 kilos, and

20    imagine me saying I have then 120 votes because I have 120 kilos, and you

21    correspondingly have 90 votes, and I thereby out-vote you and I change

22    your status, your status is no longer the same, now you are in the

23    minority.  That is what happened in Croatia when Tudjman took power,

24    through a unilateral act Tudjman changed the Croatian constitution, and

25    under that new constitution Serbs were no longer a constituent nation.

Page 1879

 1    They were, instead, a national minority.  The Serbs could not take that,

 2    and that is the cause of the war in the Croatian federal unit.

 3            Under the constitution of the former federal Yugoslavia, not a

 4    single federal unit had the right to secede.  It was considered that the

 5    right to secede and to determine one's fate was exercised, used up, at the

 6    time the Federation was formed after the Second World War.  It could not

 7    happen anymore.  But, on the other hand, it could.  Slovenia was able to

 8    secede from Yugoslavia because Slovenia does not have any unresolved

 9    internal issues, it does not have considerable ethnic groups within it.

10    It only had to resolve the financial issues brought up by the break-up;

11    however, Croatia could not secede from Yugoslavia and change its status

12    without the consent of both the Croats and the Serbs living in Croatia.

13            Had the Serbs who lived in Croatia agreed to the secession of

14    Croatia from Yugoslavia, Croatia could have succeeded; however, without

15    the consent of the Serbs it could not because that is how the Croatian

16    constituent unit had been established.  The Republic of Croatia, when it

17    was established after the Second World War, was based on that principle,

18    and that cannot be changed in a one-sided fashion by anyone.  The example

19    of Bosnia and Herzegovina is even more drastic.  First of all, the

20    communists thought that in Bosnia and Herzegovina there was a Serb

21    majority despite of the genocide that had been carried out that Bosnia and

22    Herzegovina should be within Serbia.  And then they thought that

23    territorially this would lead to too big a Serbia, so it's better to have

24    a separate territorial unit.  Then Bosnia and Herzegovina was constituted

25    as a federal unit in which three peoples were equal:  Serbs, Croats, and

Page 1880

 1    Muslims.  The Muslims were not considered to be a people, a nation; they

 2    were considered to be a special ethnic group, a separate ethnic group,

 3    because as they professed the Islamic faith they had a collective

 4    awareness of their own, and that is indubitable, I am not challenging that

 5    to the present day, there is this collective consciousness based on the

 6    Islamic faith.  It is not a nation, a people, but it is a separate ethnic

 7    group based on religion.

 8            These were three constituent peoples, and in the constitution it

 9    was also written that these three peoples were constituent peoples of the

10    republic.  Now, what does that mean?  When their status-related issues

11    were being resolved it was not possible to have any kind of out-voting.

12    Bosnia and Herzegovina could secede from Yugoslavia only if the political

13    representatives of the Serbs, Croats, and Muslims were to agree on that.

14    From a legal point of view it was impossible for the Muslims and the

15    Croats to reach an agreement to out-vote the Serbs and to secede in this

16    way.  Legally that was quite untenable, so that was done unlawfully and

17    that is why the Serbs had to react.

18            If Bosnia-Herzegovina was seceding from Yugoslavia, then the Serbs

19    were seceding from Bosnia-Herzegovina.  Why not?  On the basis of what

20    could the Muslims and Croats secede from Yugoslavia and the Serbs who

21    lived there for centuries could not secede from Bosnia-Herzegovina,

22    where's the logic of that?  Foreign factors intervened as well.  Vatican

23    and Germany rushed in already in January 1991, as soon as the Vance plan

24    was adopted for the Serb Krajina.  They rushed into recognising the

25    independence of Croatia.  Judges, I do not have to teach you that there is

Page 1881

 1    a principle in international law that has been applied for a long time now

 2    when the independence of newly established states is being recognised,

 3    independence and sovereignty can be recognised only on that territory that

 4    is under the control of a central government.  When the independence of

 5    Croatia was established, that recognition of independence could only apply

 6    to the territory that was under the control at that moment of the central

 7    government from Zagreb; it could not apply to other territories.  Also in

 8    the case of Bosnia-Herzegovina.  Independence could be recognised as well

 9    as sovereignty only in that part of the territory that was controlled by

10    Izetbegovic's government from Sarajevo.

11            The United Nations, according to the diktat of America trampled

12    upon international law and they recognised states that could not have been

13    recognised.  That is what led to the bloody civil war that ensued.  That

14    civil war ended to the detriment of the Serbs then, and historically

15    speaking that cannot last for a long time.

16            Joint criminal enterprise, a joint criminal enterprise was

17    organized by those who were breaking up Yugoslavia, not by us who opposed

18    the break-up of Yugoslavia, who opposed one-sided secession.

19            The indictment abounds in fragments stating that I advocated a

20    Greater Serbia, that I insisted upon a Greater Serbia.  And then they

21    bring that in connection with concrete crimes.  This just shows that the

22    Prosecution does not understand the concept of a Greater Serbia.  They

23    don't know what this is all about.  Judges, so far you could have assured

24    yourselves that no one else who is accused here could have been accused of

25    a Greater Serbia except for me.  No one in the Serbian public has

Page 1882

 1    advocated a Greater Serbia except for the Serb Radical Party, that is our

 2    party ideology.  I am the modern creator of that ideology, but that is not

 3    a new ideology, this ideology is a deeply rooted one.  It's been there for

 4    over 300 years now.  This ideology means that there is a unity among all

 5    Serbs.

 6            Yesterday Mrs. Dahl alleged falsely that I advocated a homogenous

 7    Greater Serbia; now, that is a lie.  Intentionally when she mentioned the

 8    countries that were to be included in Greater Serbia on the basis of my

 9    speeches and our programme, she omitted intentionally when mentioning this

10    Greater Serbia that would include Kosovo and Metohija and Vojvodina and

11    Macedonia, Bosnia-Herzegovina, Dubrovnik, Dalmatia, Lika, Banja, Kordun,

12    Slavonia, and Baranja.  That we would have brotherly concord among orthodox

13    Serbs, catholic Serbs, protestant Serbs and atheist Serbs.  One cannot go

14    without the other.  Greater Serbia is our long-term objective.  In order

15    to attain that objective, it never crossed our mind to expel 1 million or

16    2 million or 3 million people, we just wanted them to become nationally

17    aware.  We wanted to convince them that they were Serbs, we wanted to

18    prove to them that they were Serbs and others made them represent

19    themselves in a false manner.  We all speak the same language.

20            Over here you call that language inappropriately, B/C/S, that is

21    just the Serbian language.  There is no other language in our part of the

22    world except for the Serbian language.  It is not the Croatian language.

23    The Croatian language did exist, its traces are there to the present day

24    but it's called the Cakavian whereas the Serbian language is the

25    Stokavian.  This is Slavic linguists.  We are Serbs, all of us who speak

Page 1883

 1    Stokavian.  The Ikavians are Slovenes, the Cakavian are Croats.  In the

 2    7th century only two clear identified Slav peoples came to the Balkans;

 3    Serbs and the Croats.  There is no third group.  Well, there's the

 4    Slovenians too.  The Slovenes were within the greater Moravian state

 5    before the Avarians came in and then the Czechs and the Slovaks were split

 6    up too, eventually.  However it is only the Serbs and the Croats that came

 7    to the Balkans.

 8            The Christian schism happened in the Serbian ethnic area in 1054.

 9    Until then, two-thirds of the Serbs belonged to the Western Roman Catholic

10    church and one-third belonged to the Patriarchate of Constantinople, to

11    the Eastern church.  And then in the beginning of the 13th century, the

12    Serbs established their own national church, the Serb Orthodox church and

13    it became equal to other Orthodox churches.  Then most of the Serb

14    Catholics also joined this national church, except for the Serb Catholics

15    on the seacoast and in the islands from northern Albania to Omis, close to

16    Split.  In this entire territory, it was Serb Catholics who lived there.

17    When the Serbs became Turkish slaves, this happened gradually.  We were

18    defeated in the battle of Kosovo in 1389.  It wasn't all of Serbia that

19    was occupied straight away.  The Turkish sultan was killed there too. The

20    Serb state became a vassal state within the Turkish empire.  That is why

21    this taking of Serbia by the Turks was more gradual than in the case of

22    Turkish penetration into Hungary and other European countries.  The Serbs

23    remained living in this area.  As a matter of fact, they had a high agree

24    of autonomy even once Serbia had been occupied, because the Turks in

25    peacetime tried to portray themselves as being religiously tolerant.

Page 1884

 1            The Roman Catholic Church saw the collapse of the Serb state as

 2    its chance to move east, and they made every effort to Catholicise as many

 3    Serbs as possible and was assisted by Austria, Hungary, and by Venice.

 4    Whenever there was famine in Dalmatia, large quantities of wheat were

 5    brought in and Serbs were told that their children would not go hungry if

 6    they became Catholics.  You would get wheat, that is what they told them.

 7    Serb literature abounds in such examples.  In the Austrian Empire, a Serb

 8    could not become a high-ranking officer unless he converted to

 9    Catholicism, the same happened in the Republic of Venice.  So that is how

10    systematically, over the centuries, Serbs were Catholicised.

11            In the beginning of the 19th century, there was no Croatian

12    people.  There was a certain autonomy in Austria, but it was reduced to

13    three districts:  Zagreb, Varazdin, Krizevci, so that is present-day

14    Zagreb and its outskirts, but even that is not the real Croatia, the real

15    Croatia was between Cetina, Gvozd, and Sava.  Under the Turks, it

16    collapsed, it disappeared.  Croats moved to Austria, today they live in

17    the so-called Gradiste region near Vienna.  The present-day president of

18    Slovakia is a Croat originally.  There are villages where there are traces

19    of this Croatian language and where we know that Croats moved in the 16th

20    and 17th centuries.  They moved to Europe because they fled from the

21    Turks.  As the Turks engaged in looting expeditions in those territories

22    that they did not manage to occupy, so they looted these areas and they

23    captured people.  The Croats simply disappeared.

24            The Croatian nobility was moved from Hungary to the area around

25    Zagreb.  The Slovenes happened to be here but then the Croatian nobility

Page 1885

 1    was imposed on them.  People to this day speak Kajkavian to this day and

 2    they imposed the name of Croats on them, on these Slovenes.  In the time

 3    of growing national awareness in Europe in the beginning of the 19th

 4    centuries, the Croats were not there.  There is no Croatian movement in

 5    the first half of the 19th century.  There's the Ilirian movement that was

 6    headed by Ljudevit Gaj, a German.  With the assistance of the Vienna court

 7    he wanted to rally together in a single national movement as many Serbs as

 8    possible; however, the name of Serbian movement was not right because of

 9    the newly established Serbian state.  So he took out of the distant past

10    the Ilirian name although we Slavs have nothing to do with the Ilirians

11    because the Ilirians went extinct long before Christ.  So this term did

12    not really live among the people.

13            Their first publications came out in the Kajkavian language, that

14    is to say in Slovenian, and it was reduced to Zagreb, Varazdin, and

15    Krizevci, those areas.  Then there was a new initiative, the Yugoslavia

16    idea.  The protagonist was Bishop Strossmayer again originally a German,

17    on the instructions of the Austrian court.  We are going to bring all

18    Serbs together, the Orthodox and the Catholic; however, under this

19    Yugoslav name in order to have a differentiation vis-a-vis the state of

20    Serbia which later turned into the Kingdom of Serbia.  The Croats didn't

21    really have a real national movement in the 19th century.  It's only

22    towards the end of the 19th century that what started was a more intensive

23    Croatisation under the leadership of the Roman Catholic clergy and the

24    first Catholic Croatian congress was held in Zagreb in 1900.  They

25    proclaimed that all of those who speak the Serbian language and who are

Page 1886

 1    Catholic by religion are Croats, or rather, that in the Balkans all

 2    Catholics were Croats.  That is when this artificial Croatisation started

 3    and this led to a big problem.  All of this was done artificially, I

 4    explained all of this and documented all of this in my book and supported

 5    each and every one of these theses with argumentation.

 6            What should be borne in mind in this context is that the first

 7    project of the Serb lands already in 1683 was offered by Count Djordje

 8    Brankovic to the Austrian empire.  This is after the great Vienna war when

 9    the Austrian army got all the way to Skopje in the south when all of

10    Hungary was liberated.  The Austrian empire agreed to that and he even

11    appointed Count Brankovic the Serb despot.  According to Byzantine

12    tradition, it was the position of viceroy when compared to Western

13    tradition.  However, since Austria did not manage to carry through all of

14    its ambitions and after General Piccolomini's death they had to withdraw

15    and Djordje Brankovic was isolated in the town of Heb in the Czech lands.

16    Arsenije Gagovic, the leader of the Piva monastery, presented to the

17    representatives of the Russian state the project that he would call a

18    Greater Serbia that would encompass all the Serbs in the Balkans.  A

19    similar plan was sent by the Serb metropolitan priest Stevan Stanimirovic

20    in 1804 to the Russian empire.

21            The Prosecution made an effort to link up Garasanin to the

22    Nacertanije of Ilija Garasanin -- although it advocates the Serb people

23    but it only pertains to Serb lands under Turkish occupation, whereas the

24    project of a Greater Serbia insists on Serb territories that were under

25    Turkey and under Austria and under Hungary and under Venetian occupation

Page 1887

 1    while the Republic of Venice was still there.  So that's the difference.

 2    I am going to slow down again.  I am being cautioned.  I get carried away

 3    by telling this story, but I didn't want to write down everything that I

 4    am going to tell you about today.  I thought that perhaps in this way you

 5    would be in a position to listen to me more carefully, if I tell you about

 6    this in my own words.

 7            As for the project of Greater Serbia Svetozar Miletic gave it

 8    thought; then Serb radicals in Vojvodina, Bosnia-Herzegovina, Croatia, and

 9    Slavonia; Stevan and Vladislav Kacanski published a newspaper called

10    Velika Srbija, Greater Serbia, in the 1880s and 1890s; then Dragutin Ilic,

11    the brother of Vojislav Ilic, one of Serbia's greatest poets published a

12    daily newspaper, Greater Serbia, in 1903.

13            For three years, this daily newspaper was published at the

14    Salonika front as well in 1916 and 1917 and 1918.  And in the 1920s the

15    Serb Radical Party in Belgrade published Velika Srbija for a number of

16    years.  A Greater Serbia was also advocated by intellectuals around the

17    Serbian Intellectual Club and also some members of the Ravna Gora movement

18    were supporters of Greater Serbia, but this was never the official policy

19    of the movement as a whole because the Ravna Gora movement insisted on the

20    renewal of a comprehensive Yugoslavia and its leadership General Dragoljub

21    Mihaljovic headed the royal army in the homeland.  The people popularly

22    called them the Chetniks, this army, because their military operations in

23    the beginning of the Second World War were based on the Chetnik guerilla

24    warfare.

25            Therefore, the concept of a Greater Serbia has nothing to do with

Page 1888

 1    either Slobodan Milosevic or any other personage who is named in this

 2    indictment as a participant in the joint criminal enterprise linked with

 3    me.  The concept of a Greater Serbia in 1990 was renewed by us as the Serb

 4    Chetnik Movement, as the Serb Radical Movement and started printing the

 5    paper Velika Srbija, Greater Serbia, and there have been 3.000 issues and

 6    it has been published for the last 17 years.  It has many readers, perhaps

 7    because we hand it out free of charge to the people.

 8            I'd like to clarify one other point before the break so that I

 9    could move on to the Prosecution's pre-trial brief after the break.  I

10    have been accused of the fact that most of my crimes I carried out through

11    hate speech.  The incrimination of hate speech has no precedent in

12    international criminal law.  The Prosecution is not even able to define

13    what hate speech actually is.  The Council of Europe has been dealing with

14    hate speech since 2001 onwards, and several recommendations were made, the

15    essence of which is that hate speech should be avoided in the media, along

16    with insistence that in suppressing hate speech what should not be

17    resorted to were prison sentences for it, but other forms of ensuring that

18    hate speech is stopped and repressed.  And the construct of hate speech

19    itself, the concept itself, is based on certain examples of the prevention

20    of expansion of racial hatred in Anglo-Saxon law.

21            When they attempted in England to expand the concept of racial

22    hatred and intolerance to religious hatred they came across difficulties

23    and the House of Lords did not pass the law project because it was

24    considered that it was an attack on free speech.

25            The Prosecution says that the concept of hate speech was applied

Page 1889

 1    in the International Court for Rwanda.  Yes, it was in several judgements

 2    although I never received the judgements and they should have sent me the

 3    judgements, everything that was quoted, they should have provided me in

 4    the Serbian language so that I could deal with that, but they failed to do

 5    this.  So in Rwanda, the genocide was established, and that is not

 6    challenged.  800.000 people were killed, almost an entire national group

 7    was killed.

 8            Genocide is different from any other war crime.  It is different

 9    in that with genocide you have to prove the dolus specialis in other

10    crimes you can use dolus eventualis but with genocide that is strict. You

11    have to have the dolus specialis proved.  For somebody to be accused of

12    genocide, you must prove the genocidal intent directly, whether we're

13    dealing with people who killed directly or who issued orders that others

14    be killed.  And people were sentenced there because they called over the radio

15    for the killing of the Tutsis.  Or for example a mayor of a town from all the

16    Tutsis had been killed and exterminated, he incited people to these

17    killings.  And so on and so forth.  So people in power who called for the

18    liquidation of an ethnic group of its own citizens.

19            That did not happen in the Balkans, there was none of that.  There

20    was no genocide, and you cannot ascribe to me any direct incitement to the

21    commission of war crimes, never, nowhere.  You have to incite it directly,

22    immediately, because after the incitement you come to action.  There must

23    be action.  It must be acted upon, and not several months later and

24    several years later and so on and so forth.  And the most important point

25    is this:  The genocide in Rwanda took place in 1994.  So you cannot rely

Page 1890

 1    on the practice of the International Tribunal for Rwanda who tried war

 2    crimes that happened after my alleged crimes.  The Prosecution has to

 3    refer and rely to something that happened earlier.  The Prosecution cannot

 4    find an example of that.  It's doing its best, it's trying to, and it

 5    refers to the Nuremberg trial.  For example, in the Nuremberg trial, it

 6    was not an international trial in the proper sense, it was a military

 7    court by the victory powers, and only four powers there, Russia, or

 8    rather, the Soviet Union; America; France; and England.  Some states that

 9    were participants in the anti-Hitler coalition ask that their judges take

10    part but that was rejected.  Yugoslavia also asked but its proposal was

11    rejected.

12            Now, of course, I say that it wasn't a court in the true sense of

13    the word because there was no appeals.  There was just the judgement and

14    liquidation followed.  However, I agree that all those convicted deserved

15    their sentence, so from the moral standpoint these crimes were indeed

16    proved.  A man called Julius Streicher was tried, for instance, and he was

17    the Obergruppenfuhrer of the SA, that is to say, a high-ranking

18    functionary of the paramilitaries of the Nazi party, and he was proclaimed

19    the number one persecutor of the Jews, the main persecutor of the Jews,

20    and he kept calling for the liquidation of the Jews, the Holocaust.  He

21    personally took part in toppling and destroying the synagogues.  He used a

22    riding crop to beat the Jews that had been taken prisoner.

23            He destroyed the synagogue in Nuremberg personally and was one of

24    the main organizers of what was called Crystal Night.  So Julius Streicher

25    was not sentenced for a verbal crime, but for the extermination of the

Page 1891

 1    Jews when genocide was not a term in international law.  The convention on

 2    genocide was enacted only after World War II, but what was spoken about at

 3    the time was the extermination of the Jews.  So how can the Prosecution

 4    compare me to him?  However, the Prosecution intentionally seems to be

 5    forgetting that somebody else was tried there, and that was Hans Fritzsche

 6    who was one of the main chiefs of propaganda, Goebbels's right-hand man of

 7    the German Reich.  Hans Fritzsche was the head of the radio department of

 8    the Ministry of Propaganda, and he directly supervised 2.300 journalists,

 9    all the papers published in Germany at that time under the Nazi

10    authorities was supervised by him.  Hans Fritzsche after Goebbels was the

11    principal protagonist of the Reich, and he was freed, although he

12    advocated Reich policy in all the media and the racial policy and

13    totalitarian policy and all the rest, the policy to conquer.  How then can

14    the Nuremberg judgement be a fulcrum point for the Prosecution?

15            What also happened is this:  A Soviet member of the International

16    Criminal Tribunal Major Nikitchenko had as a dissenting opinion, he did

17    not agree, he expressed his disagreement with the freeing of Fritzsche and

18    it's very interesting to note and to look at the arguments he put forward

19    in his dissenting opinion against the freeing of Fritzsche.  American,

20    French, and the other judge rejected these arguments and Fritzsche was

21    acquitted.  I'm not sure that I'm going to have time to go through all

22    this and present it to you here because I would like to speak about

23    something that I think is far more important, but if there is time left

24    over at the end, I would like to go back to this and I have certain

25    excerpts from the dissenting opinions and arguments put forward by Judge

Page 1892

 1    Nikitchenko which is three and a half pages of dense text.  So I see that

 2    we're nearing the break.  We've been going for an hour and a half, so I

 3    don't want that to reduce my time for other matters too much.

 4            However, as regards hate speech, I would have something to add

 5    after the break.  I hope that that makes it exactly an hour and a half.

 6    Is that right?

 7            JUDGE ANTONETTI: [Interpretation] It is now 10.30.  As a rule, we

 8    have a 20-minute break, but I think we shall have a 15-minute break from

 9    now on.  As you have the floor, how much time do you need to have a rest?

10            THE ACCUSED: [Interpretation] Well, ten minutes is enough for me,

11    Judge.

12            JUDGE ANTONETTI: [Interpretation] In that case, we will have a

13    15-minute break.

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

15                          --- On resuming at 10.52 a.m.

16            JUDGE ANTONETTI: [Interpretation] We are resuming our hearing.

17            Mr. Seselj, you have the floor.

18            THE ACCUSED: [Interpretation] I'm going to serve you more words,

19    Judges, about the incrimination of speech hate.

20            THE INTERPRETER:  Hate speech, interpreter's correction.

21            THE ACCUSED: [Interpretation] Because it's a new crime just

22    conjured up which never existed before in international customary law and

23    it cannot exist, or rather, physical perpetration through hate speech does

24    not exist.  I'm going to quote two cases drawn from American legal

25    practice, court practice:  Brandenberg versus Ohio.  The Supreme Court of

Page 1893

 1    the United States of America on the 9th of June, 1969, drew the following

 2    conclusion that inciting conduct contrary to the law is not a crime but

 3    direct incitement to commit a crime is and Chaplinsky versus New Hampshire

 4    says a speech which is directly or must immediately result in violence for

 5    it to be considered.

 6            Now, attempting to accuse me of using hate speech to perpetrate a

 7    crime, the representative of the indictment relies on quotations from my

 8    speeches taken out of context, and I'd like to remind you of the famous

 9    statement made by the French cardinal, Cardinal Richelieu, "Just give me

10    one sentence," he said, "taken out of any text and I will find in its

11    sufficient reason to send the author thereof to the guillotine."  I'm

12    paraphrasing maybe it's not word for word what the Cardinal said, but

13    anyway.  But the inciter must know the individual who he is inciting.

14    Incitement must be premeditated.  There is no chance incitement or

15    inducement without premeditation.

16            Now, in the indictment and in the pre-trial brief, not only do we

17    lack a definition of hate speech, but also we lack concrete crimes

18    committed through hate speech.  Various crimes are enumerated here,

19    perpetrated by who knows whom in who knows what location, but there's not

20    a single crime, a single criminal act perpetrated by my hate speech which

21    represents direct incitement to commit a crime.

22            Furthermore, there is no objective or subjective link between the

23    associates, accomplices.  Very often there is no direct perpetrator

24    either, despite the fact that there is no concrete incitement to a set

25    crime, there's no assistance and help in carrying it out.  There's no

Page 1894

 1    joint criminal enterprise, there's none of that there.  And criminal law

 2    cannot be interpreted by analogy to the detriment of the accused.

 3            I now like to refer to the last portion of the pre-trial brief of

 4    the Prosecution which is a broader version of the indictment itself, I

 5    don't want to waste time looking at the indictment first and then this.

 6    So I'll go through it point by point to show you how this does not

 7    correspond to the facts, to the truth, and that it is not founded or

 8    grounded on any rightful premise.  In the first point, it says that at the

 9    relevant time I was one of the most prominent politicians in the former

10    Yugoslavia and wielded considerable political power and influence.  That

11    is absolutely untrue.  My political party was not registered at all in

12    1990.  In 1990 I was imprisoned three times for demonstrating,

13    demonstrations, because those demonstrations and rallies were not -- did

14    not suit the regime and for some other reasons, too, but of an exclusively

15    political nature.

16            Now, how someone who has no parliamentary political party can have

17    significant political power and influence I don't know.  In 1991, the

18    Serbian Radical Party was registered; however, right up until the month of

19    July that same year, we were a party outside parliament.  At some

20    additional elections that were held in Belgrade district at the end of

21    June 1991 I was elected as deputy, national deputy, and throughout that

22    same year, 1991, and throughout 1992, I was the sole deputy of the Serb

23    Radical Party in parliament, which numbers 250 members.  So my political

24    influence and power could be expressed in the ratio of 1:250.

25            I'm saying all this just to illustrate how much seriousness the

Page 1895

 1    Prosecution lacks, and this applies to me and the joint criminal

 2    enterprise.  How could I have taken part in the formulation, planning, and

 3    execution of the JCE?  I suppose while Milosevic held me in prison; is

 4    that it?  Well, I did plan various enterprises, but none of them with him

 5    at the time.  I planned toppling him from power.  And had the aim been of

 6    that enterprise to expel forcibly thousands of non-Serbs from their homes,

 7    that is quite untrue.  Throughout 1990, 1991, and 1992 in all my political

 8    speeches, in striving for a Greater Serbia, and mentioning the territories

 9    that Greater Serbia should comprise, I speak about brotherhood and unity

10    of the Serbs, the Orthodox Serbs, Serb Catholics, Serb Muslims, and Serb

11    Protestants, and that is what I was doing and am doing as a member of the

12    opposition, not as a man belonging to the regime right up until 1988, I

13    was never a man of the regime.

14            It is nebulous to read in point 2 that under my leadership and the

15    leadership of my co-perpetrators, civilian and paramilitary organs

16    participated in the taking over of power throughout Croatia and Bosnia and

17    Herzegovina.  It means that the JNA and the army and the police were under

18    my direction, if I had that much influence and power over the army and the

19    police, I would have taken over power back in 1991.  What would I have

20    been waiting for?  If under all that was under my direction, I wouldn't

21    have needed elections in the first place.

22            The secret arming of Serb civilians.  Who did that?  Where would I

23    get the arms to secretly arm Serbian civilians?  The proclamation of

24    autonomous regions in Croatia and the Bosnia and Herzegovina

25    administrative unit.  The people spontaneously did that.  Who would have

Page 1896

 1    been able to force such a mass of people to a certain political conduct if that

 2    people had not felt under threat for various reasons?  When Tudjman came to

 3    power, immediately the iconography of Ustashas was renewed all over

 4    Croatia, and it was well-known, that iconography, to the Serbian people.

 5    In Croatian parliament a speaker comes to the floor and makes the Ustasha

 6    salute.  In the middle of Croatian parliament.  What else could Serbs

 7    expect?

 8            Back in 1941 Serbs waited to be genocide, sitting on their hands.

 9    Who could have expected Roman Catholic clerics to take up arms and start

10    slaughtering them?  Nobody could have been known that and nobody could

11    after the Second World War, none among the Serbs could wait silently for

12    that to happen to them again.

13    There is a reference to the systematic cleansing of the Muslim, Croatian and

14    other non-Serb population in Croatia and Bosnia and Herzegovina.  Where was this

15    systematic cleansing?  I don't rule out the possibility that there were

16    criminal acts of persecution in these territories, but it was a civil war.

17    The civil war happened between Orthodox Serbs, Catholic Serbs, and Muslim

18    Serbs and the very fact that this war happened, that fact in itself led to

19    huge movements of population, people left to go to places where they would

20    feel safer.  Like in every civil war crimes happened, but every crime has

21    a name, a qualification.  There is not a single crime for which we would

22    not be able to find the name of the perpetrator and the name of his

23    accomplices on any grounds.

24            What are the restrictive measures and discriminatory measures that

25    I introduced in those territories against the non-Serb population and

Page 1897

 1    where would I have taken the power?  If I didn't have power in a place, I

 2    couldn't do anything but speak.

 3            As far as my specific elements of responsibility are concerned, it

 4    is said first that I led to the perpetration of crimes by systematic and

 5    public propaganda of crimes in territories which are better known as

 6    Greater Serbia, delineated by the line

 7    Karlobag-Ogulin-Karlovac-Virovitica, and it comprised large parts of

 8    Croatia.  If Yugoslavia was able to break up, it could have broken up into

 9    its integral parts, the Serb territory on the one hand and the Croat and

10    Slovene territory on the other hand.  What other territories would be

11    involved?  Why would it break up along the lines of internal borders of

12    administrative units?  Those borders were never formulated by any internal

13    law.  They were not internationally recognised.  Internationally

14    recognised borders belonged only to Yugoslavia.  Those were guaranteed by

15    the OSCE conference, and that right of Yugoslavia was trampled.

16            It's not possible to simply promote new borders instead of those

17    real ones, instead of the internationally recognised ones, that is

18    contrary to the basic principles of international law.  It is said that by

19    public and systematic causing of fear among Serbs, I made Serbs believe

20    that Serbs -- that Croats, Muslims, and other non-Serbs were their

21    enemies, which led to violence and incitement of crimes cited in the

22    indictment.  Why would I be causing fear and hatred when all that was

23    already happening?  The very fact that the first Croatian official

24    pronounced that Croatia would secede from Yugoslavia caused both fear and

25    hatred.  If Tudjman had not moved to secede with Croatia, there would have

Page 1898

 1    been no war.  Tudjman said himself that there would have been no war had

 2    Croats not wanted it.  That statement of Tudjman's was quoted many times.

 3    If there had been no Croatian separatism, there would have been no war.

 4    There would have been great trouble, political trouble, within the state

 5    in order to settle all the interrelationships for all interests to be

 6    satisfied, but that is a matter of political process.  Those who wanted to

 7    secede with Croatia, they caused war; those who wanted to secede with

 8    Bosnia and Herzegovina, they caused war.

 9            As for the naming of Serb enemies, I was only speaking of

10    historical facts.  It is a historical fact that Croats were very pliable

11    and susceptible to manipulation by the Roman Catholic church.  In the

12    Second World War Croats were loyal and sincere supporters of Hitler until

13    1943. They started turning coat only when they realised Hitler would lose the

14    war and then they started joining partisan detachments. Very few Croats were

15    genuine antifascists in 1941. The uprising against Hitler and his allies

16    happened only in territories populated by Orthodox Serbs.

17            In the Second World War, the Muslims were instrumentalised by

18    Croats, and to a large extent they participated in Croat crimes, but not

19    all Muslims.  There were also Muslims partisans and Muslim Chetniks.

20    There was a Chetnik Vojvoda, a Muslim, Ismet Pupovac, he had a detachment

21    of 2.000 Muslim Chetniks, and the vice-president of the national committee

22    of the Ravna Gora Movement of Draza Mihajlovic, was another Muslim,

23    Mustafa Mulalic.  After the war, the Communists tried him together with

24    Draza Mijhajlovic.  I only presented the historical truth; that historical

25    truth must not be concealed.  It must be repeated over and over again, it

Page 1899

 1    must be explained, and further researched in order to serve as a lesson

 2    for the future.

 3            Wherever historical truth is concealed, peoples and nations are

 4    condemned to having history repeat itself.

 5            By recruiting, organizing, financing, supporting, directing,

 6    encouraging, instigating Serb volunteers, that's what they say.  I really

 7    organized and rallied Serb volunteers and as the president of the Serb

 8    Radical Party, I did that.  The Serbian Chetnik Movement was part of the

 9    party and I did send them to the front line; they participated in the

10    fighting.  However, some things need to be clearly distinguished here.

11    The volunteers of the Serb Radical Party were called Serb Chetniks, but

12    they were not the only Serb Chetniks in this war.  Serb opponents called

13    all Serb enemies Chetniks.  They called Chetniks members of the Serbian

14    Renewal Party, the SDS, and God knows what other political parties.  There

15    was a huge identification of Serbs with Chetniks on a large scale.  Nobody

16    wanted to identify them with the victorious partisans from the Second

17    World War.  I can have at least moral responsibility for what might have

18    been done by the volunteers of the Serb Radical Party during the war.

19    Those who were rallied by the Serb Radical Party in Belgrade and who were

20    sent by the Serb Radical Party to the front.

21            But that formulation must be limited only to that, not to all

22    Chetniks.  Whenever somebody is named as a Chetnik somewhere, he

23    automatically is a Seselj's man.  What does that mean?  After this --

24    after this trial is over, the Judges and everybody who works here might

25    become Seselj's men, and I will even try to achieve that, but what does

Page 1900

 1    that really mean?  The volunteers of the Serb Radical Party participated

 2    in the war exclusively within the units of the Yugoslav People's Army, and

 3    later the Serb army of the Republic of Serbian Krajina and the Serb army

 4    of Republika Srpska.  An insignificant number was in the police of the

 5    Republic of Serbian Krajina and in the police of Republika Srpska.

 6            Only up to July 1991 the volunteers of the Serb Radical Party went

 7    to the front line in circumvention of the JNA. I’m proud of their great victory

 8    on 2 May 1991 in Borovo Selo, over the Croatian police which had launched a

 9    sudden attack on the village.  Since Croatia entered the war in

10    July 1991, nowhere was there a single volunteer of the Serb Radical Party

11    who participated in the war outside of a JNA unit.  The army designated

12    one barracks for the volunteers of the Serb Radical Party in Bubanj Potok

13    near Belgrade.  We rallied volunteers and sent them there.  They passed

14    basic training there, they received uniforms.  Every volunteer of the Serb

15    Radical Party had years of service written into his military service book.

16    Nowhere ever was there a volunteer of the Serb Radical Party identified as

17    a direct perpetrator of a war crime, and I will show that.  Never a single

18    one.  I repeat that.

19            Now, it is also said in the pre-trial brief that I encouraged and

20    incited and instigated volunteers and groups and individuals within the

21    Serb forces, the Territorial Defence, the Army of Republika Srpska, the

22    Army of the Serbian Krajina, the State Security Service, Martic's police

23    force, militias, et cetera, and that I encouraged and incited them.  To

24    what?  That I encouraged and incited them to commit crimes?  How?  If I

25    encouraged them, then I encouraged them to win the war.  I never

Page 1901

 1    encouraged anyone to commit crimes.  There are abundant examples of my

 2    speeches and addresses to the troops, where I said how they should be

 3    chivalrous in the war, how they should treat prisoners, women, children,

 4    et cetera, and the Prosecution has that, I submitted it to them back in

 5    2003, it's even translated into English, but they don't care.  They could

 6    care less that they have it.  It says that I coordinated the activities of

 7    volunteers and other Serb institutions who committed crimes.  Now, look,

 8    the Serb Radical Party had its own Crisis Staff which was later renamed

 9    War Staff and the Prosecutor keeps referring and invoking that War Staff.

10    What did that War Staff do?  You will best know that if you look at its

11    composition.  Those were 10 to 15 men, among them four to five women, only

12    one officer - and even he was a reserve officer, a retired pilot,

13    Zoran Drazilovic - whereas all the other men had only completed the

14    regular military service and none of them was commissioned.  What was that

15    War Staff able to do, to command?

16            No.  They organized the rallying of volunteers throughout Serbia,

17    their transportation to Belgrade, to the barracks in Bubanj Potok.  That

18    War Staff made efforts to sometimes find a necessary supply of cigarettes

19    and other supplies.  That War Staff made sure that years of service are

20    counted for every member to organize funerals, aid to the family of the

21    fallen one, et cetera.  That War Staff sometimes tried, if there were

22    occasions of lack of discipline, to use political and moral measures to

23    help solve problems.  That War Staff did not have power.  The only

24    sanction they could mete out was to exclude the person from the Serb

25    Radical Party; there was no other punishment available.  But there were no

Page 1902

 1    significant breaches of discipline.  We excluded that person from the

 2    Serb Radical Party, and anybody who stole something somewhere, who was a

 3    drunk, who was indisciplined would be excluded from the party and would

 4    never be able to go to a front line again as a volunteer.  We were never

 5    officially informed that a serious crime had been committed, and the

 6    Prosecution has no evidence of that.

 7            Now, since the Prosecution is short of evidence for these two

 8    first years concerning specific crimes, persecution, et cetera, they

 9    introduced the case of Hrtkovci from Vojvodina into the indictment for

10    political reasons, and they say that I publicly called for the expulsion

11    of Croat residents from parts of Vojvodina.  It didn't exactly happen that

12    way.  I did not publicly call for their expulsion.  I promised their

13    expulsion once I get to power.  I promised measures of reciprocity because

14    Tudjman had already expelled 200.000 Serbs from the territory under his

15    control, and on behalf of my party in the election campaign I launched as

16    one of my electoral promises the application of measures of reciprocity.

17    If I called on someone to apply a reciprocity, I called upon the

18    then-regime, and Milosevic's MP, MPs opposed me in parliament when I made

19    that demand.  The Prosecution would like to show here that I directly

20    called on people to start persecuting other people.  Now, that is the kind

21    of falsifying that the Prosecution engages in.  I will deal with that in

22    greater detail later.

23            You see on page 5 that they quote from one of my speeches, where I

24    said what this Greater Serbia should encompass, and then they omit the

25    unity and harmony among Serbs, Orthodox Serbs, Catholic Serbs, Muslim

Page 1903

 1    Serbs, and atheist Serbs, and they go on to present a bit of one of my

 2    speeches from end 1990, a warning I issued.  "And as far as Croatia is

 3    concerned, we the Serb Chetniks are constantly telling the new Ustasha

 4    leader Franjo Tudjman and the new Ustasha authorities in Croatia not to

 5    play games with the Serbian people living in the area of the present

 6    improvised Croatian state community, that is, the Serb territory."  That

 7    is on page 5 of the pre-trial brief of the Prosecution, I'm saying this

 8    for the interpreters because they are cautioning me for my speed.  You

 9    have that in English and in French.

10            In this way I seem to have committed yet another crime.  When did

11    that happen?  In late 1990.  At the end of 1990, through a single speech

12    of mine, I made someone act in a particular way in 1991, 1992, 1993, and

13    commit a war crime?  That defies sanity.  In 1990 I cautioned Tudjman not

14    to play games with the Serb people and that we will not allow territories

15    where the Serb people lived to secede from the mainstream, Yugoslavia.  I

16    am giving him a timely warning not to play with weapons.  I want him to

17    prevent a war.  I'm warning him -- I'm even threatening him, hoping that

18    he will give up on that idea of his.

19            Furthermore, another speech of mine from that period of time is

20    quoted.  "The most important thing is that the Croats and Slovenes do not

21    leave the Yugoslav Federation.  First the Slovenes should leave and then

22    those who are in authority in Belgrade will carry out an amputation along

23    the Karlobag-Ogulin-Karlovac-Virovitica."

24            THE INTERPRETER:  Could the interpreters please have a page

25    reference to the text that is read out.

Page 1904

 1            THE ACCUSED: [Interpretation] So we are talking about 1990.  I see

 2    that it is hard to preserve Yugoslavia and then I have this clever idea.

 3    If the Slovenes and Croats have to leave, let the Slovenes leave first but

 4    there are no unresolved, unsettled matters between us.  First I oppose the

 5    army intervention in Slovenia.  The army intervention and bloodshed in

 6    Slovenia were caused by the then-minister of defence Veljko Kadijevic and

 7    Ante Markovic, the then-federal prime minister, a Croat, they wanted to

 8    keep Slovenia in Yugoslavia by force.  I was opposed to that.  As a

 9    democrat, I though that if the Slovenian people wanted to leave, that they

10    should leave as soon as possible.  However, the Western powers did not

11    allow that, they wanted the Slovenes, and the Croats to leave together, as

12    a package deal, in order to attain the criminal objective of Germany and

13    Vatican that Croatia lives within the boundaries imposed by the communist

14    regime.  Now, that could not happen.  If the Croats did not want to live

15    in Yugoslavia, then only an amputation could be carried out.  Amputation

16    was not my idea.  Even King Aleksandar Karadjordjevic gave thought to that

17    in 1929.  He then believed that if the Croats didn't want Yugoslavia,

18    Yugoslavia can do without them, an amputation can be carried out.  Why

19    would this idea be illegitimate, why would this idea be a criminal one?

20    Especially if uttered in 1990.

21            Again a quotation of mine that I'm proud of to this day.  "The

22    Croats can, as far as we are concerned, leave Yugoslavia as they please,

23    whenever they want."  So I am not forcing Croats to leave Yugoslavia.  If

24    they want to leave," why would they keep them in Yugoslavia by force?  And

25    then I say here:  "Whenever they want, but we are openly letting them know

Page 1905

 1    that they will not take away a foot of Serbian territory, not one piece of

 2    land where there are Serb villages, destroyed Serb churches, Serbian mass

 3    graves, Serbian camps, Serbian Jasenovac.  If we allowed that, we would be

 4    unworthy of our glorious ancestors, and we would have to be ashamed in

 5    front of our descendents.  The Croats can create their own state but only

 6    west of the Karlobag-Ogulin-Karlovac-Virovitica line.  Everything east of

 7    that line is Serbian."

 8            That's what I think to this day.  Unfortunately, we did not have

 9    the right kind of political and military leverage to achieve that because

10    there were two great powers against us.  If I were in charge of the army,

11    I would have ordered the army to leave Slovenia on time, to withdraw from

12    the territories of Croatia wherein Serbs did not leave, and then I would

13    say to the Croats, If you want to go on living in Yugoslavia, we're going

14    to build Yugoslavia together as a democratic state with full civil rights

15    and equality of rights.  If you want to secede, you can secede with that

16    territory.  What was more logical than that at that point in time?  There

17    is just one single problem.  Destiny, history did not allow me to come to

18    power on time.  That is the only power -- the only problem involved.  Had

19    I come to power on time, everything would have been different.  I was even

20    persuading the Slovenians to leave as soon as possible and the Prosecutor

21    quotes that.  To you Slovenians, Serbia is a very serious unbeatable power

22    because the Slovenes were pretending to be heroes, they said that they

23    were warriors, whatever. They would never have had a state had Serbia not

24    liberated them in the First World War.  Before 1918 Slovenia never had

25    statehood of its own as Slovenia.  They were only Austrian dukedoms until

Page 1906

 1    then.

 2            You see that Serbs are still showing goodwill.  After that you

 3    won't be able to.  After that we are going to create Serboslavia out of

 4    Yugoslavia.  I am convincing the Slovenians to leave as early as possible

 5    for a simple, rational reason.  If the Slovenes leave it's going to be

 6    easier for us to agree on how Yugoslavia will remain because the political

 7    elite, the political leadership of Slovenia in the 1980s was the main

 8    disruptive factor of Yugoslavia.  They wanted Yugoslavia to grow into a

 9    confederation, they wanted all sorts of things that were unacceptable.

10            From this year, 1990, the Prosecutor gives some other quotations

11    about my threats, about cause for punishment and so on, all of my threats

12    are conditional, though.  If such and such a thing happens, then another

13    thing will happen.  So these are words of warning, not of instigation,

14    because if it had to do with instigation then it led to events that

15    happened years after that or months after that.  I say that quite clearly

16    at one particular point.  That is when I spoke on state television in

17    December 1990.

18            I explain here how Croats have to be punished from crimes from the

19    Second World War if they opt for separatism.  They should be punished in a

20    manner in which nations and states are punished in a civilised world for

21    crimes committed by their regimes during wars, that being the loss of

22    territories.  There are many other things I say there, but the Prosecution

23    omits that.  "We Serbs are a chivalrous people.  We do not take revenge

24    against women and children, we do not carry out genocide.  We do not kill.

25    If we take revenge, we take revenge by having our enemies lose their

Page 1907

 1    territories by vanquishing them in a war if they impose war on us."

 2            But we did not want that war.  In 1990 and 1991 no one among the

 3    Serb people wanted war, not a single person.  War is what those who wanted

 4    to secede from Yugoslavia wanted.

 5            "Now they say that I underestimated the Serb -- the Croatian

 6    people when I as I say that Franjo Tudjman nowadays has 80.000 Ustasha

 7    specials armed to the teeth.  That is no force to match for us Serbs.

 8    Well, it is no match for us, no match whatsoever."  Even today the Serb

 9    Krajina should be free if the Americans had not taken part in the

10    aggression in 1995.  Even now Kosovo would be under Serb control had it

11    not been for an American aggression.  Even today Bosnia-Herzegovina would

12    have been within our joint state regardless of whether it was called a

13    Greater Yugoslavia, Serbia, whatever, had there not been for outside

14    interference of Americans, Germans, Vatican, and so on and so forth.

15            Then I caution as follows:  "Bosnian pan-Islamists," page 7, all

16    of this within paragraph 7, "could the Bosnian pan-Islamists fight a war

17    against us Serbs?  Recently we told them, do not let the Muslim majority

18    become a tool of Croatia like it did in the First World War and the Second

19    World War.  Beware and do not interfere in the Serbo-Croat conflict.  If

20    the Croats use you again Serbian revenge will be terrible and you will end

21    up farther than Anatolia.  You will not even stop there."

22            This is a warning from 1991 when there was no war in

23    Bosnia-Herzegovina.  I am giving this warning on time, and I am saying to

24    the Bosnian pan-Islamists, not Muslims as a whole, that they will not even

25    stop in Anatolia.

Page 1908

 1            I was the first one to indicate what the danger of pan-Islamist

 2    tendencies in Bosnia-Herzegovina was as early as the beginning of the

 3    1980s, but you will never find me anywhere humiliating the Islamic faith,

 4    underrating the Islamic faith.  I am full of respect for the Islamic

 5    faith, but I am a bitter opponent to all kinds of fundamentalism.  At the

 6    moment it is Islamic fundamentalism that is the most dangerous but if

 7    there were to be Christian fundamentalism somewhere I would be bitterly

 8    opposed to that too.  Here I am talking about pan-Islamists, and I talk

 9    about fundamentalists and so on.

10            Most importantly, a year before the war in Bosnia, I am warning

11    that that war should not take place.  I am acting as a peace-maker.

12    Unfortunately, they did not listen to me.  Why did they not listen to me?

13    Not because I was powerful and strong at that time, but at that time they

14    did not consider me to be serious enough to be listened to.  They were

15    underrating me, they were saying communist dissident, spending all this

16    time in prison, and so on and so forth.  Quite a bit of time had to go by

17    before I became politically influential and powerful, but not then.  I

18    needed to prove myself for a long time before that happened.

19            Then another warning.  All of those who have an unclear conscience

20    should fear us Serbs.  To this day people with an unclear conscience

21    should fear us Serbs, they have reason to fear us.  We Serbs have

22    forgotten and forgiven too much in history.  We have told the Croats,

23    should they ever again resort to genocidal activities against the Serbian

24    people, not only shall we avenge every victim but we shall also settle

25    scores for the victims from World War II and World War I.  If we are not

Page 1909

 1    present in some villages or we are unable to defend them we shall take

 2    revenge wherever the Croats are the weakest.  Quite simply, we speak the

 3    language of force, the language of power.

 4            It's a warning, it's not a call for the Serbs to kill Croats, I'm

 5    not saying kill women and children, kill Croats, no, it's a warning.

 6    There were even some warnings that I said by way of a joke.  Once I made

 7    an interview to some newspapers saying that we have river submarines, we

 8    the Chetniks, and that we are going to take one of those and go all the

 9    way to Zagreb, but all of that was by way of a warning because of this

10    danger against a new genocide against the Serbs.  It was a very real one.

11    All factors were on the political scene, all of those that have carried

12    out genocide during the Second World War.  The Roman Catholic Church with

13    the same kind of policy, the Ustasha ideology, the Ustasha regime of

14    Franjo Tudjman in Zagreb.  Well, he even brought in the most hardened

15    Ustasha émigrés as soon as he came to power in Zagreb.  Susak,

16    one of them, was his minister of defence, the leader of the Ustasha

17    emigres in Canada.

18            So my words were strong, but adequate in terms of the historical

19    context in which they were uttered.  It was not possible to issue a milder

20    warning at that time because it wouldn't have had the right effect.

21    Unfortunately, this did not have an effect either.  This proved to be in

22    vain as well.  Yet again, I issue a threat.  "Should they attempt a new

23    genocide against the Serb people" - I'm referring to paragraph 8 - "we

24    shall take revenge for each Serbian life and we shall also ask to pay up

25    for crimes" et cetera.  But I also said what our revenge would consist of.

Page 1910

 1    It's not that we're going to do the same things the Ustashas did to the

 2    Serbs.

 3     And I threaten, for example, the Chetniks are going to strike at Zagreb

 4    using their full strength if there is a massacre of Serbian civilian

 5    population. So there was this real threat against the Serbs.

 6     It is not in vain that 200.000 Serbs immediately fled

 7    from Croatia as soon as Tudjman came to power.  Repressive measures

 8    against the Serbs started immediately, layouts, mistreatment, et cetera.

 9    The question in this war is who started the killing.  It's the Croats who

10    started killing the Serbs, it's the Muslims in Bosnia who started killing

11    the Serbs.  They killed a bride-groom's father before the old Serb church

12    in Sarajevo during the wedding.  A Muslim criminal walked up and killed

13    the bride-groom's father.  That is what caused bloodshed and the conflict.

14      He remained unpunished.  They only tried to bring him to court a few

15    months ago, a year ago, I don't know exactly, and I don't think he was

16    actually convicted.  I didn't really follow the case.

17            Every Serb move, political or military, was always provoked from

18    the other side.  Tudjman abolished the status of Serbs as a constituent

19    people, the Serbs asked for autonomy.  Tudjman wants secession from

20    Yugoslavia, the Serbs ask to remain in Yugoslavia or to join Serbia,

21    that's what happened in Bosnia-Herzegovina too.  As the separatist moves

22    of the Muslims and the Croats became more intensive, the Serbs made more

23    direct moves to dissociate themselves from that kind of separatist

24    government.  When I say that "Bosnia is undoubtedly Serbian and if any

25    Muslim fundamentalists do not like that they will have to pack their suit

Page 1911

 1    cases and leave on time," fundamentalists I say, never Muslims, whereas

 2    the Prosecution has in its documentation my appeal to the Serbs of the

 3    Islamic faith.  It starts with the words "Brother Serbs ..."  From 1990,

 4    that was published in Greater Serbia, in my books, and so on and so forth

 5    several times, where with great warmth and love I address the Muslims.

 6    And I refer to the great names of great Muslim Serbs throughout history

 7    who were aware of their ethnic identity.  To this day all the noble

 8    families among the Bosnian Muslims are aware of their origins, even

 9    Alija Izetbegovic said he was a Serb in the 1950s and 1960s before the

10    Muslim nation was invented.  His origins are from the town of Sabac near

11    Belgrade.  One does not have to prove basic facts.  You don't have to

12    prove -- now you're trying to prove to me that in addition to the Serbian

13    language, there is a Croatian language, there is a Bosnian language?  That

14    is nebulous.

15            "The loyal population always enjoys all rights and human

16    freedoms."  Where's the problem there?  Then I issue another caution.  I

17    say that the Croatian hordes are attacking Croatian villages.  All this is

18    a true.  In Osijek the chief of the Croatian police was killed because he

19    was opposed to the bestial conduct against the Serbs.  They killed him

20    too.  Who was the person there, who was the main person there, Glavas or

21    whoever?  It's no longer important.  That was the mood that prevailed, an

22    atmosphere of great fear and unrest, and my threats were in the sense of

23    warnings, cautions.

24            Of course throughout the time - and the army didn't want to listen

25    to me - to have the army withdraw on time from areas that were purely

Page 1912

 1    Croatian and Slovenian and everything would have been much better had the

 2    army withdrawn.

 3            But the generals dreamt of something else, of preserving

 4    Yugoslavia and their political power and influence.  They even formed

 5    their party along those lines, the League of Communists, the Movement for

 6    Yugoslavia, the generals' party.  All officers had to be members of that

 7    party.

 8            Now the Prosecution speaks about my propaganda techniques.  It's

 9    all ludicrous, but as we're going to have their alleged expert witness

10    come in already in December, then it will be a cherry on the cake to

11    cross-examine him and to show him up as being no expert witness at all.

12            Now, the application of national stereotypes is what I'd like to

13    address next.  It says the use of the concepts of Ustasha and Bosnian

14    pan-Islamists.  They're no stereotypes, they're not stereotypes; it's

15    reality.  The Ustasha ideology is very strong today and it will remain

16    strong until the Roman Catholic Church leads an intensive action against

17    the Serb people.  Had we Serbs given up a hundred years ago and agreed to

18    be Catholics, the Croats today wouldn't exist at all.  So 2 or 300 years

19    ago the Roman Catholic church sent Juraj Krizanic, a Serb of Catholic

20    faith, to Russia.  He lived in Russia and the court there for 10 or 15

21    years and his assignment was to make the Russian court convert to

22    Catholicism and for the Russian church to recognise the authority of the

23    pope of Rome and then they would enable them to have power of all the

24    Slavs, and the Vatican was even ready to give up Poland and hand over the

25    whole of Poland to Russia just in order to have the Russian church convert

Page 1913

 1    and come under its sovereignty.

 2            So these are all very serious matters.  In science it has been

 3    proved, they have been proved, long since and they're not stereotypes at

 4    all.  This Ustasha ideology is active today as well.  It's a little more

 5    covert than it was in 1990 and 1991, but it's very strong today too.

 6            As I spent a little more time on these matters of principle, I'll

 7    have to speed up to get to the more concrete and specific issues which I'm

 8    sure you might be more interested in, but let me just mention before I do

 9    that this:  The Prosecution says that in disseminating propaganda I had

10    the help of the public information media, which was controlled by another

11    participant in the joint criminal enterprise and that was

12    Slobodan Milosevic, the President of Serbia, that he enabled me access to

13    the information media.

14            In Belgrade there's a weekly called Vreme which began to be

15    published in the 1990s, and its journalists are CIA agents, agents of the

16    American intelligence service and as well as some other Western

17    intelligence services as well, and they are still published just because

18    they are funded from Soros and from abroad and similar anti-Serb

19    foundations.  This magazine, Vreme, at the end of 1992 or 1993 published a

20    book.  One of the authors was Jasminka Milivojevic, I can't remember the

21    other, but anyway, the book was called "The Screening of the Elections,"

22    and they performed an analysis of how far political parties were

23    represented in that year of 1992 on our screens, and they showed that of

24    the relevant political parties, the Serb Radical Party had the least

25    publicity in the media, especially in the state media, the media under the

Page 1914

 1    control of the regime, the least.  And those are exact facts.  It's scholarly

 2    investigation that led to these facts.  In a hostile publication published there.

 3    And the prosecution says that I basically had a privileged position in the media.

 4            So I said -- as I said, I had the least presence in the media, as

 5    did my party.  But I was most effective in using the time placed at my

 6    disposal by the media.  Other people didn't know how to do that, to make

 7    the best use of time, but what can I do if they don't know how to do that.

 8      Each of those leaders, the pro-Western political parties, I always beat

 9    them in a television duel.  Every representative of the regime I got the

10    better of.  I was never beaten in a television duel.  I have not been

11    beaten to date.  And so there you get the impression that the man is doing

12    wonders in the media and I'm very proud of that, because my thoughts are

13    clear, they're fairly concise, they are based on history and scholarly

14    investigation.  I am well-known for never saying stupid things.

15            So what can I do?  Nobody can match me.  Djindjic, Kostunica,

16    Tadic, or anybody else, they're just not up to me, not even up to my

17    knees.  I was blocked mostly by the regime media, it was Milosevic who

18    blocked me in the media my access to the media the most, especially during

19    the periods of time when I attacked him most.  And I did attack him and I

20    always attacked him when he gave way to the Western forces.  He gave way

21    to the Americans and then I get out the big guns and attack him and his

22    party and his regime and so on.

23            The Prosecution says that I was fully conscious of my ability to

24    influence people through my speech.  Well, of course, every politician

25    does that, every politician tries to wield influence and influence people.

Page 1915

 1      The success of a politician is measured by his ability to influence

 2    people.  Now, what was it that I influenced people with?  By what I said.

 3    Well, you can't use empty phrases alone, because people listened to

 4    something humourous or a turn of phrase and then they've had enough.  But

 5    what a politician says must be relevant, intelligent, logical,

 6    well-founded, and developed.  That is the only way you can wield influence

 7    on people.  Mrs. Dahl yesterday held some sort of speech here and even

 8    used some emotional notes, heart-rending stories.  Can she influence

 9    people?  No, she cannot.  Because she wasn't convincing.  She didn't seem

10    intelligent to the broad masses of the population.

11            The people can differentiate between who is telling the truth and

12    who isn't, because truth comes out of someone's eyes.  You can tell it in

13    their eyes, just as you can tell somebody when they're lying by looking

14    into their eyes.  That's something you can do very frequently because a

15    person who is lying fidgets, touches his nose, looks down.  There are

16    various forms of gesture that can tell you that a person is lying.  But

17    they don't seem to like it that I have influence over the people.  I'm

18    guilty for influencing people.

19            Furthermore it says that I said to my volunteers that they should

20    kill the Ustashas or Turks.  They found some idiot among the witnesses, I

21    don't know who it is yet, but perhaps we'll see him appear in court, who

22    probably signed a statement for them to the effect that I called Muslims

23    or referred to the Muslims as the Turks.  Never in my life did I call the

24    Bosnia-Herzegovinian Serb Muslims Turks, never ever.  And there's not a

25    single shred of evidence to prove that, except perhaps some false witness

Page 1916

 1    that the Prosecution might be bringing in.  And if I heard any other

 2    member of my party to say Turks, and that would happen from time to time,

 3    I would put them right on that score straight away.  So you have not a

 4    shred of evidence to prove that.

 5            Only somebody very primitive who knows nothing can refer to the

 6    Bosnian Muslims as Turks.  It is true that at times during history they

 7    identified themselves with the Turks when the Turks ruled over Bosnia,

 8    however the Turks have not been in power in Bosnia for a long time and the

 9    Muslims have retained the Serbian language.  They never managed to learn

10    Turkish, some of them might, one or another, but they left a long time ago

11    and their descendents live in Turkey today.  But most of these people

12    never learned Turkish and most of the Muslims have kept alive the old Serb

13    traditions, songs, and all the rest.

14            The Prosecution also criticises me for having not only the

15    position of political authority but moral authority as well, that is

16    paragraph 21 that I am referring to now.  Well, I assume that somebody

17    must be proud if they're considered to be a moral authority.  Now, how did

18    I become a moral authority in the first place?  Because I didn't give way

19    to injustice, the force of injustice, I never stole anything, did

20    anything, did anything that was amoral, that's how you become a moral

21    authority.  You can't pretend you're a moral authority if you're not.

22    Moral authority is something that is built up over the years and decades

23    and I have been here in The Hague here and raised my moral authority

24    boundlessly while here in The Hague.  And today even my greatest political

25    adversaries respect me for that, and so I'm very grateful to The Hague

Page 1917

 1    Prosecutors for that, for raising my moral authority which is

 2    indestructible now.

 3            And now the Prosecution says, "Seselj knew or had reason to know

 4    that his incitement and public speeches on the battleground will incite

 5    and instigate volunteers and soldiers to commit crimes."  That's very

 6    shrewd at first glance on the part of the Prosecution.  Well, violence

 7    there's violence in every war.  By definition, war is violence.  Why did

 8    not they write here to commit crimes, then that would have been clearer.

 9            Yes, I did encourage Serb soldiers on all the fronts to fight

10    courageously and bravely, but there is not a single shred of evidence that

11    I incited crimes, incited them to crimes, and there is a lot of proof to

12    show that I was horrified over every crime and that I would criticise

13    other units for having committed -- if they committed crimes, I'm not

14    going to attack so-and-so because the Serb public opinion is full of proof

15    now.  I'm not going to shift the blame on others now and name names,

16    people who were living or dead, except if some of them are great friends

17    like Vuk Draskovic or Carla del Ponte in Belgrade.  On the one hand, his

18    crimes are ascribed to me and on the other hand, Vuk Draskovic seems to be

19    Carla del Ponte's best friend.  So we'll go into all those details in due

20    course to see what the role of Carla del Ponte's role was in masking war

21    crimes.  Why she tried to mask what the Serb guards did who were sent to

22    the front by Vuk Draskovic himself.  There were no such atrocious crimes

23    that could be ascribed to the volunteers of the Serb Radical Party and

24    since there are no crimes on the part of our volunteers, we'll blame it on

25    others because they're all Serb forces because I seem to be held

Page 1918

 1    responsible for everyone, Arkan's men, Mauzer's men, or Djindjic's men, or

 2    the Yellow Wasps, or whatever, all the formations.

 3            Furthermore, the Prosecution is going to bring forth witnesses to

 4    claim that I advocated killing all children from mixed marriages, that at

 5    a rally in Subotica I publicly said that all children from mixed marriages

 6    should be slaughtered.  Well, I'm not going to defend myself from

 7    accusations like that at all.  I would like you to find me guilty and then

 8    in the judgement one of the main points be that I am found guilty because

 9    I strove to have children from mixed marriages killed.  5.000 people

10    attended that rally in Subotica and they know full well that that is just

11    not true, as does the whole of Serbia.  Well, you couldn't do me a greater

12    service than to convict me for saying something like that when all Serbs

13    know I didn't say anything like that nor could I ever have said something

14    like that.  So please go ahead, I invite you to convict me for that.  It

15    would be a historical service that you would be doing me.

16            Next, it says that "many volunteers of the Serb Radical Party and

17    Serbian Chetnik Movement were well-known criminals."  Now, there's a

18    footnote there saying witness, the code is witness.  Well, why don't you

19    list these well-known alleged criminals among the Serb Radical Party and

20    volunteers?  Name me one name.  Such and such was a notorious criminal, he

21    was in prison because of that, and then became a member of the Serbian

22    Radical Party, go on.  Nobody made a better selection of volunteers than

23    did the Serbian Radical Party, but in our party a volunteer could be

24    exclusively somebody who had done his military service, regular military

25    service, with the exception of women because there are a fair number of

Page 1919

 1    women volunteers as well.  It was only our party that we tried to check

 2    out the fact that to see whether people weren't drug addicts, alcoholics,

 3    criminals, and so on.

 4            And now you give this overall assessment of saying they were

 5    well-known criminals.  Well if they're well-known criminals, give us a

 6    name.  If they were well-known, then the public knows their names.  That's

 7    what would make them well-known.

 8            It is a problem for the Prosecution that I attended the Sabor or

 9    Assembly of the Serbian People in Srb, where the leaders of the Serbian

10    Democratic Party were picked on the 25th of July, 1990.  That seems to be

11    a problem for the Prosecution as well.  Amazing.  I'm proud of having been

12    there.

13            I am also being accused of forming all Serb autonomous regions

14    here.  Well, I supported the formation of the Serb autonomous regions, I'm

15    proud of that.

16            I'd like now, so as to have enough time, to move to specific

17    incriminations and charges.  Of course I could say a lot more today about

18    matters of principle, the structure of the Serbian Radical Party and so on

19    and so forth, but I'm sure I'm not going to have enough time to do all

20    that.  So I'd like to move to the charges.  I think we have quite a long

21    time to the break; is that right?

22            Vukovar, November 1991.  The volunteers of the Serbian Radical

23    Party 14 Vukovar, that is indisputable, and the Serbian Radical Party to

24    this day is proud of the war role.  The volunteers of the Serbian Radical

25    Party first of all fought in Borovo Selo, and the Prosecution criticises

Page 1920

 1    me about that.  They defended Serb civilians.  A truce was signed at the

 2    time, some kind of cease-fire, and a certain agreement was reached with

 3    the local Croat authorities.  There were barracks set up on the roads,

 4    those barracks were dismantled --

 5            THE INTERPRETER:  Blockades, sorry.  Interpreter's correction.

 6            THE ACCUSED: [Interpretation] Blockades were set up and

 7    dismantled.  The situation was more lax and then the Croats in buses with

 8    a lot of policemen stormed Borovo Selo and opened fire immediately.  It

 9    was not the Croats who were attacked in Borovo Selo.  They attacked.  They

10    died first.  The first casualty fell on the Croat side which was

11    Vojislav Milic from the surrounds of Valjevo.  He was a volunteer of

12    Dusan Silni, or rather, the White Eagles --

13            THE INTERPRETER:  Interpreter's correction:  On the Serb side.

14            THE ACCUSED: [Interpretation] He was the only volunteer of Serbian

15    Renewal.  There was 16 volunteers of the Serb Radical Party, and he was

16    found in front of the building where the volunteers were sleeping without

17    any weapons and he was killed.  The others heard the shooting, they took

18    up arms, and they beat the Croatian policemen.  16 of them managed to beat

19    the 100 or so policemen or however many there were because they were brave

20    young men and I'm proud of them.

21            It is further said that on 12 November or around that date I

22    arrived in Vukovar to visit the volunteers and boost their morale, and

23    that that same night a meeting was held in a house on Nova Street 81,

24    housing the command post of the JNA and the Territorial Defence of the

25    local Serbs.  That I attended that meeting along with other leaders of the

Page 1921

 1    Serb Radical Party and officers of the JNA who are named, including

 2    Sljivancanin, Captain Radic, and other people.  That meeting never

 3    happened.  The command post of the 1st Guards Brigade was in a tent

 4    outside Vukovar, and it was there that the commander of the Guards

 5    Brigade, then Colonel Mile Mrksic organized a dinner for me when I came.

 6    At that dinner party there were his most prominent officers,

 7    Lieutenant-Colonel Panic, Chief of Staff of the 1st Guards Brigade, and he

 8    offered me his helmet as a gift because I had come with a small helmet --

 9    in fact, it's not the helmet that was small it was my head that was big,

10    and the helmet didn't really -- how shall I put it?  It just didn't look

11    good on my head.

12            So Lieutenant-Colonel Panic gave me his helmet as a gift.  A large

13    number of officers attended that dinner party and this alleged meeting is

14    a complete fabrication.  They found a liar who is working for the CIA and

15    who is claiming that he had overheard that conversation because the door

16    was ajar and he took notes in his writing pad.  Well, these are the kind

17    of liars that the indictment relies on, and that I said some rubbish,

18    among other things, not a single Ustasha should be allowed to leave

19    Vukovar alive.  And then the Prosecutor also incited some witnesses to say

20    that I made a speech to the troops.  I didn't make any speeches to troops,

21    I didn't make any speeches to troops, I didn't visit any soldiers in

22    Vukovar because it was impossible.  All the groupings of more than two or

23    three men were prohibited because the Croats were shelling with mortars

24    all the time.  There were no rallies, no speeches, nothing of the kind.

25    I'm not really trying to respond to this allegation that I said not a

Page 1922

 1    single Ustasha must leave Vukovar alive.  Just as you might say death to

 2    the Nazis, I -- you could say death to the Ustashas.  It's not impossible

 3    that at somewhere, sometime I said something like that.  It's not the same

 4    thing as saying, go on and shoot all prisoners of war.

 5            And now it is said that the volunteers of the Serb Radical Party

 6    participated in the liquidation of prisoners of war in Ovcara and in the

 7    building of Velepromet.  I have statements by six bus drivers who

 8    testified that they personally took volunteers of Serb Radical Party to

 9    Serbia as soon as Vukovar was liberated.  Those people were in a hurry to

10    get home, to get a change of clothes, to have a bath, to rest.  Maybe some

11    of them were left over in Vukovar, to have a bath, to rest.  Maybe some of

12    them were left over in Vukovar.  Maybe some of them remained, but if they

13    did, they did so of their own accord.  A very high profile trial is

14    underway in Belgrade for the Ovcara case.  There's only one SRS volunteer,

15    Slobodan Katic, among them.  And the trial judgement acquitted him.  Look at

16    that judgement of the Special Court in Belgrade.

17            Now, the Prosecution goes on to say that Milan Lancuzanin, a.k.a.

18    Kameni, Chetnik Vojvoda was convicted, yes, he was convicted, but he was

19    the first casualty of my trial here.  This pro-Western traitorous regime

20    in Belgrade is doing the bidding of The Hague OTP to convict

21    Milan Lancuzanin, Kameni, at any cost, although he is not responsible for

22    any crimes.  I don't know which of the other accused are really

23    responsible and which are not.  I claim that not a single SRS volunteer

24    participated in the killings in Ovcara or Velepromet, and I assert that

25    not even Kameni did.  When I asked him several years later, he swore to me

Page 1923

 1    by all that was sacred to him that he didn't and I believe him, he's a

 2    very honourable man.  But he was not a volunteer of the Serb Radical Party

 3    who was sent to Vukovar, he was born in Vukovar.  He was the commander of

 4    the detachment of the Territorial Defence in Vukovar, Leva Supoderica, as

 5    a reserve captain first class of the JNA, and he commanded his own fellow

 6    citizens over there, whereas the commander of the Guards Brigade later

 7    decided that volunteers of the Serb Radical Party from the barracks in

 8    Bubanj Potok should be attached to that detachment, and that detachment

 9    came under the command of the 1st Guards Brigade.

10    Well, at that time Milan Lancuzanin, Kameni, indeed joined the Serb Radical Party

11    after having seen our volunteers and members of our party. I made him a Vojvoda

12    because he was brave, a valiant fighter. In that order making him Vojvoda, there

13    is no mention of anything but his bravery in combat. But he is not the man I sent

14    from Serbia to the front, so it is pointless to talk about him. That’s what I want

15    to say. In order for me to have at least moral responsibility for the

16    crimes in Ovcara, you would have to prove that this was indeed done by

17    volunteers of the Serb Radical Party.  If they had returned to Serbia

18    before the crime happened, then I have no moral responsibility either.  I

19    learned of the crime itself more than a year later, maybe even two years

20    at the time when it happened I didn't even know.  Somebody called Topola

21    is mentioned here as participating in that crime.  I don't remember that

22    Topola man.  It's not impossible that somebody with that nickname was

23    among the volunteers, but if he had remained in Vukovar after Vukovar was

24    liberated, he could only have done so of his own accord.  And I'm not his

25    nanny to go after him and look after him and see what he went on to do

Page 1924

 1    after completing his assignment in the organization of the Serb Radical

 2    Party.

 3            And the Prosecution says that I again later sent the same Topola

 4    to the war in Bosnia-Herzegovina.  Well, that is not true.  Anyone who was

 5    guilty of any breach of discipline in Slavonia was excluded from the

 6    Serbian Radical Party and was never sent there anywhere again, that was

 7    the case of Vojin Vuckovic, Zuca, he was undisciplined in Slavonia and he

 8    said himself that he left the Serb Radical Party, you gave me his

 9    statements, because he didn't like the policy.  Of course everybody will

10    try to find a pretext like that.

11            Now, regarding Vocin, there were no crimes there, no crimes

12    committed by volunteers of the Serb Radical Party.  There's only one thing

13    that was true that commander was Radovan Novacic, a good man, an

14    honourable man who lost a leg in the war.  He didn't commit any crime.

15    The volunteers of the Serb Radical Party at the time of the alleged crimes

16    were defending Masic, Sagovina which was the last rampart, the last route

17    of retreat for Serb forces.  11 of our volunteers were killed in one day

18    alone in that place.  Several of them were wounded and several were

19    captured, among them a girl Dusica Nikolic.  They were taken to a Croat

20    prison where they were tortured for months in many ways.  They were really

21    unspeakably treated, but after six months they were let go and none of

22    them were tried.

23            Now, some crimes certainly did happen in Western Slavonia and a

24    crime happened in Vukovar, in Ovcara, in Velepromet.  A group of officers

25    was tried here, the so-called Vukovar troika, the commander was convicted,

Page 1925

 1    the commander of the Guards Brigade, Mile Mrksic.  But his responsibility

 2    was not proven.  Miroslav Radic was acquitted whereas Colonel Sljivancanin

 3    was convicted on a much lesser charge, not this crime in Ovcara, but

 4    mistreatment of prisoners or something.  I haven't seen the judgement and

 5    I don't know the exact formulations.  But that trial did not establish the

 6    key thing:  Who ordered that the prisoners from the Vukovar Hospital

 7    should be turned to the civilian authorities of the Autonomous Region of

 8    Slavonia, Baranja, and Western Srem.  That order could not have been given

 9    by the commander of the Guards Brigade.  It couldn't have been done by the

10    commander of the Kragujevac Brigade either.  He was the one who took over

11    command after Vukovar was liberated.  The court didn't even try to

12    establish that, and I will tell you now.  I'll give you the big secret.

13            The crimes in Vukovar were interlinked.  General Aleksandar

14    Vasiljevic, chief of the military security service of the JNA personally

15    came to organize that crime.  Why?  Because the top leadership of the JNA

16    still believed at that time that it -- an American intervention was

17    possible in such a form that the JNA would be called upon to restore order

18    like it was in the puppet regime of Tito and that order would be like in

19    Tito's Yugoslavia.  In 1990, they formed their own movement, the movement

20    for Yugoslavia.  It was led by the retired General Branko Mamula.

21    Veljko Kadijevic, Blagoje Adzic, Aleksandar Vasiljevic were the key people

22    in that party, as well as Stevan Jerkovic who was formerly the president

23    of that party in 1991 and so on.

24            The army leadership and the military security service needed

25    crimes, both on the Serbian and the Croat side in order to find a good

Page 1926

 1    enough excuse for army intervention that would topple both Milosevic in

 2    Belgrade and Franjo Tudjman in Zagreb.  And the military security service

 3    organized parallel crimes on both sides.  The military security service

 4    organized the explosion in the building of the Jewish municipality in

 5    Zagreb, and they mined the Jewish cemetery in Zagreb in order for the

 6    world public to turn against Tudjman.  And on the other hand some crimes

 7    were provoked on the Serbian side as well so as to create a groundwork for

 8    a settling of scores with Serb nationalists.

 9            Aleksandar Vasiljevic in person brought White Eagles to Western

10    Slavonia.  The White Eagles were brought in circumvention of the official

11    channels used by the volunteers of the Serb Radical Party.  The Bubanj

12    Potok barracks, official buses of the JNA, Western Slavonia.  The

13    commander of the Territorial Defence of Western Slavonia, active-duty

14    Colonel Jovan Trbojevic.  That was the official channel for sending

15    volunteers, but Vasiljevic had his own channel.  Aleksandar Vasiljevic

16    took away from the Vukovar bank several million German marks.  If it was

17    war booty than under regulations he was duty-bound to turn it over to the

18    so-called military service of the National Bank of Yugoslavia.  He never

19    did that.  All trace of that money was lost.

20            Aleksandar Vasiljevic had come here to testify as a public witness

21    in the Milosevic trial.  One part of his testimony was in private session,

22    but he testified mostly in public.  But the Prosecution never invited him

23    to testify in the Vukovar troika trial.  Why?  Why don't they invite him

24    to testify against me?  I would relish that.  They didn't because they're

25    not interested in the truth, the Prosecution isn't.  They are prosecuting

Page 1927

 1    me for political and other reasons.  They couldn't care less who organized

 2    crimes in Ovcara and in Western Slavonia.

 3            In May 1993 there was a very, very strong possibility and threat

 4    of the military putsch.  Veljko Kadijevic proved that, promoting his book

 5    in Moscow.  That was confirmed by Borisav Jovic and other people, too.

 6    The mobilisation in Serbia was unsuccessful in 1991 because Milosevic was

 7    afraid of the military putsch, that's why his regime did not work to

 8    mobilise citizenry.  He preferred only volunteers to go to the JNA because

 9    he knew that the military leadership cannot instrumentalise volunteers to

10    organize a military coup, as was their ambition.  The response to

11    mobilisation in Serbia was only a couple of per cents, and in Montenegro

12    it was 100 per cent.  That was not because Serbs were cowards.  It's

13    because the regime in Serbia didn't want that mobilisation drive to be

14    successful, and of course various political parties worked against the

15    mobilisation for their own various interests.  However, when the danger of

16    military coup was removed in 1998, we had more than 100 per cent response

17    to mobilisation call-up in Serbia because Serbs are a brave people, a

18    heroic people, and they are prepared to defend their country.  They were

19    not cowards like the Prosecution wanted to present them in 1991.

20            Aleksandar Vasiljevic was tried in Belgrade because of that

21    scandal in Zagreb, but he received a very mild sentence and the whole

22    thing was covered up and shoved under the rug.  Those were famous scandals

23    Opera and Labrador affairs.  Those who know the military security service

24    of the JNA know that it was much more dangerous than the State Security

25    Service.

Page 1928

 1            Now, Bijeljina.  There had never been any volunteers of the Serb

 2    Radical Party in Bijeljina.  In the conflict between Serbs and Muslims in

 3    Bijeljina, sometime in April 1992 or maybe end March, local members of the

 4    Serb Radical Party participated, such as Mirko Blagojevic from Bijeljina.

 5    He did participate in that conflict, but he never committed a crime.  And

 6    what Arkan's men did and Mauzer's men did, please don't describe that to

 7    me.  Not a single volunteer of the Serb Radical Party from Serbia was sent

 8    to Bijeljina, not a single one, therefore it's out of place for me to even

 9    discuss Bijeljina.

10            The same goes for Brcko.  In the fighting for Brcko there were no

11    volunteers of the Serb Radical Party.  In places where there were many

12    volunteers of the Serb Radical Party, it's interesting that you didn't

13    level any charges.  Skelani and other places, Niksic Heights, and others,

14    not a single charge.  But you used places, localities, where there were no

15    volunteers from the Serb Radical Party.

16            Then it says:  "Seselj's volunteers and Arkan's Tigers."  Rubbish.

17    There was never any joint or coordinated action between our volunteers and

18    Arkan's Tigers.  The volunteers of the Serb Radical Party always had

19    strict instructions never to mix with Arkan's men anywhere, never to mix

20    with Yellow Wasps, with Mauzer's men, with White Eagles, with the Serb

21    guard, and all the varieties of Red Berets.  Those were the strict

22    political instructions volunteers of the Serb Radical Party received.  For

23    what reasons?  We had important reasons, but I don't want to discuss them

24    because I'm simply not obliged.  I don't owe you that.  I'm talking about

25    the charges that you levelled against me, as far as the crimes of other

Page 1929

 1    people are concerned, it's up to you to establish that.

 2            In Bosanski Samac there were some members of the Serb Radical

 3    Party.  It is correct that Srecko Radovanovic, nicknamed Debeli, was one

 4    of them.

 5            JUDGE ANTONETTI: [Interpretation] Mr. Seselj, we'll have to have a

 6    break soon.  I think we have to have at least 20 minutes because of the

 7    time needed to replace the tape.  After the break we'll resume at 12.40

 8    and I believe that by quarter to 2.00 you will have had your four hours.

 9    So roughly you have an hour to finish.

10            We'll resume in 20 minutes' time.

11            JUDGE LATTANZI: [Interpretation] I wanted to ask Mr. Seselj

12    whether he will be so kind as to finish 10 minutes or 15 minutes earlier

13    because we have another hearing after this morning at least for two of the

14    Judges.  So if he could be so kind as to finish by 1.30, 1.35, I would be

15    extremely grateful to him.

16            JUDGE ANTONETTI: [Interpretation] We'll be back in 20 minutes.

17                          --- Recess taken at 12.21 p.m.

18                          --- On resuming at 12.40 p.m.

19            JUDGE ANTONETTI: [Interpretation] The hearing is resumed.  It is

20    12.40.  You have the floor, Mr. Seselj.

21            THE ACCUSED: [Interpretation] May I proceed?

22            I'm going to conclude my statement of the accused by 1.30 in order

23    to meet the needs of Madam Lattanzi.  However, I hope that some other time

24    when I particularly care to go on for 20 minutes longer with somebody's

25    cross-examination, that you are going to accommodate me as well.  Thank

Page 1930

 1    you very much.

 2            I started talking about what happened in Bosanski Samac.  Indeed

 3    there were a few people there who had been volunteers of the Serb Radical

 4    Party among them was Srecko Radovanovic, nicknamed Debeli.  He was such a

 5    capable soldier that he even became a brigade commander or the deputy

 6    commander of the 2nd Semberija Brigade, I cannot remember exactly now.

 7    However, how did they find themselves there?  After Vukovar was liberated

 8    Srecko Radovanovic was a volunteer in Slavonia.  The army selected a few

 9    of the most capable volunteers and suggested to them that they go for

10    special training.  I cannot remember exactly where the training camp was.

11    Srecko Radovanovic talked to me and asked me what I thought about that.  I

12    agree that he go for that training, and he indeed went and after this

13    training this entire group that did not only consist of members of the

14    Serb Radical Party was sent by JNA helicopters to Samac, that is to say

15    that it was quite regular within the JNA.  I don't know whether there were

16    any crimes in Samac or not, but I certainly know that Srecko Radovanovic

17    never committed a single war crime.

18            Although I did clash with him over some other matters later on in

19    the Serb Radical Party and he had to leave the party and so on and so

20    forth, but at any rate he is no war criminal.  Now, this Dragan Djordjevic

21    nicknamed Crni and some others who they are I have no idea.  It says here

22    that Slobodan Miljkovic nicknamed Lugar is from the Serbian DB.  I don't

23    know about that either.  I know that at one point he joined the Serb

24    Radical Party in Kragujevac and was soon thrown out of it and later on he

25    was killed in a clash with some member of the DB.  What happened there, I

Page 1931

 1    really don't know and in this particular case I'm not really interested.

 2            As for Zvornik, first of all the Prosecution refers to a meeting

 3    in Zvornik in March 1992, where I allegedly made a speech saying:  "Dear

 4    Chetnik brothers, especially you on the other side of the Drina, you are

 5    the bravest of all and we are going to clean up Bosnia from the infidels

 6    and we are going to show them the road, as is right."  The indictment

 7    doesn't say infidels, it says pagans.  First of all, I know that I have

 8    convinced you so far that I'm not capable of expressing myself in such a

 9    primitive way.  My speeches are fiery, they may be war-mongering, but

10    they're not this stupid and primitive.  Even when I went to elementary

11    school, I could not speak in such a primitive way.  I mean to say

12    infidels, pagans.  First of all, I never considered the Muslims to be

13    infidels or pagans or is that possible and am I not educated enough to

14    know that that is impossible?

15            Islam is a religion that is directly based on Judaism and

16    Christianity and it recognises the Old Testament and the New Testament,

17    and although it does not recognise Christ to be God, he is recognised as

18    the envoy of God and he -- they even refer to the day of judgement when

19    the dead and the living will be judged.  Only a primitive person can put

20    these words in my mouth or a Prosecutor that has no general education, no

21    knowledge, nothing.  As for pan-Islamists and fundamentalists, I wouldn't

22    have called them pagans.  I could have called them "pogani", but that's a

23    different problem, that's the problem of your translators.  From the

24    moment when this Tribunal was founded, an enormous number of Croats found

25    jobs here.  As for the territory of the former Yugoslavia there's an

Page 1932

 1    enormous number of Croats employed here, a lot more than Serbs, Macedonians,

 2    Albanians, everybody else put together -- well, this is the policy of the Tribunal,

 3    it's an anti-Serb Tribunal so I'm not surprised. But there is a problem when it

 4   comes to translation. Because according to the Vienna Agreement reached in 1850 at

 5    a meeting held between Serbian and Croatian intellectuals, they accepted that

 6    Serbian was their official language, not Croatian, because their language remained

 7    neglected because they used Latin and other languages. So they took over Serbian

 8    and they immediately started spoiling Serbian with some kind of artificial words.

 9    To this day they have been inventing new words and sometimes people have to make

10    a major effort to understand what it is they are talking about.  You have

11    detained Croats here.  A few years after they leave the Hague Tribunal

12    they cannot speak this new Croat language.  In the Serbian language there is

13    a precise difference between pagans and pogani. Pagans are polytheists, and pogan

14    means excrement, not to use a more vulgar expression.  I could have said

15    fundamentalist filth or excrement, but I certainly would not have said

16    pagan; I know that much.  That's impossible.

17            It is possible for the Prosecutor and it's possible for these

18    translators who have spoiled the Serbian language and who are inventing

19    new words every day.  Volunteers of the Serb Radical Party in the

20    beginning of April 1992 did take part in the liberation of Zvornik.

21    Before that, Zvornik was taken by Muslim paramilitary formations.  In

22    March and April 1992, everything that was not JNA was paramilitary.  The

23    Serbs had to flee from Zvornik, and then in their counter-offensive the

24    Serbs took Zvornik and volunteers of the Serb Radical Party took part in

25    that under the command of the JNA.  There were two groups of volunteers,

Page 1933

 1    one was sent from Belgrade, from this War Staff of ours, and the other

 2    group was established by our municipal committee in Loznica.  And they

 3    were in Zvornik from the 8th of April until the fall of the city fortress.

 4    It was very well-fortified, it's above Zvornik, and it fell on the 23rd of

 5    April.  That's when the volunteers came back and there was a small group

 6    left there to secure the front line facing Tuzla, but even that group

 7    returned in the first half of May.

 8            When the JNA withdrew from Bosnia-Herzegovina on the 19th of May,

 9    in Zvornik, there weren't any volunteers of the Serb Radical Party left at

10    all.  Volunteers only took part in combat.  Volunteers of the Serb Radical

11    Party, not in Zvornik or in other places, never had detention centres,

12    prisoners, they did not capture anyone, keep them in custody, no one.  And

13    here it says that Serb forces including volunteers.  They cannot identify

14    the members of the Serb Radical Party as perpetrators of crimes, and then

15    they're using the broader notion of Serb forces and they included

16    volunteers.  That is ridiculous.  Volunteers of the Serb Radical Party

17    that were sent from Belgrade were commanded by Vukovic Cele, in May he

18    left Zvornik, the end of May 1992 he was with me in Podgorica, and he was

19    wounded, too.  There was an assassination attempt, a hand-grenade was

20    thrown at me.  One of the volunteers was there as my security detail at a

21    rally, and he -- this particular man kicked this hand-grenade.  There was

22    this other man from Pancevo who said that he was the one who did that, but

23    Miroslav Vukovic said that he is the one who did that, so we said, all

24    right, it was him.  He was wounded with a lot of shrapnel from that

25    hand-grenade, but I was wounded only with one.  But he was wounded in the

Page 1934

 1    lower part of the abdomen and the legs.  I'm telling you that in May, in

 2    the second half of May, he was not in Zvornik.

 3            What happened there after that, I mean really, don't trouble me

 4    with that.  We won in the battle for Zvornik.  If someone violated laws

 5    after that, then that person should be tried.  Strategically Zvornik was

 6    very important for Republika Srpska, and that is why we had to take

 7    Zvornik and we had to take it from the Muslim paramilitary formations.

 8    What happened after that, well, those who committed crimes are

 9    responsible, whether crimes were committed or not, that is what you have

10    to establish, but I really don't see how you you're going to link them to

11    me.  On the basis of JCE?  No way.

12            Then the broader area of Sarajevo, basically three persons are

13    involved, or rather, three localities.  Ilijas, I am going to try to cut

14    this as short as possible, I am going to try to be as brief as possible

15    and as we hear Prosecution witnesses we're going to deal with that.

16    Vasilije Vidovic, nicknamed Vaske, was a volunteer of the Serb Radical

17    Party in Benkovac in Dalmatia in 1991.  He fought heroically.

18            When the war was over with the Vance Plan, he returned to Ilijas

19    where he was born.  It wasn't the Serb Radical Party that sent him to

20    Ilijas.  At the beginning of the war in Ilijas, a unit was established and

21    he was the commander of that unit.  The Serb Radical Party from Belgrade

22    never sent volunteers to that unit, and during the course of the war I

23    visited Ilijas twice.  That is correct, I visited his unit too.  I have

24    such unlimited confidence in Vasilije Vidovic that after the war when the

25    Serbs had to leave Ilijas after the Dayton accords, I brought him to

Page 1935

 1    Belgrade and appointed him head of my personal security detail.  That is

 2    the kind of impeccable morality that this man has as far as I'm concerned.

 3            I don't believe that he never [as interpreted] committed any

 4    crimes and even if he had, what does that have to do with me?  You say

 5    that he had a skull on his car.  Did you establish whether it was a human

 6    skull or a plastic skull?  And if it's a real skull, where was it found?

 7    It dates back to when?  You're trying to say it's the skull that belonged

 8    to a Muslim person, well, then there would have to be a Muslim helmet on

 9    the bonnet of that car.  Well, you kept silent about that.  A blue helmet

10    of the UN was on that car, and if Vaske Vidovic was trying to intimidate

11    someone with that skull, it wasn't the Muslims, there weren't any around

12    him, it was the forces of the United Nations.  Now, if intimidation of UN

13    forces is a war crime, then call that a crime too.

14            About him committing crimes against civilians or prisoners, that

15    is totally out of place.  These are pure fabrications.  As for volunteers

16    of the Serb Radical Party in the beginning of Sarajevo, there were some in

17    Grbavica.  Volunteers came there under the command of Branislav

18    Gavrilovic, Brne, he personally came on a JNA helicopter.  The volunteers

19    fought for Grbavica against the Serb -- against the Muslim paramilitary

20    forces.

21            In Hrasno, a group of prisoners was taken and that is an extension

22    of Grbavica.  There was a major danger and they would all get killed.  So

23    Gavrilovic called me in Belgrade to intervene in Pale and ask for help and

24    I did that.  You have intercepts of telephone conversations when Grbavica

25    was reverted in Serb hands then the volunteers returned to Belgrade to

Page 1936

 1    Serbia and Branislav Gavrilovic, since he was born in Sarajevo, remained

 2    in his native town.  After that he went to Ilidza and was within the

 3    Ilidza Brigade of the Army of Republika Srpska.

 4            You say that over there there were some four prisoners of war that

 5    he mistreated, killed.  It is pointless for me to discuss that.  I believe

 6    that that was not the case.  And even if it was the case, so what?  Why

 7    would I go into all of that?  Maybe he had some personal reasons for that

 8    from before the war.  Who knows what that was all about?  You know, you

 9    are ascribing all sorts of things to me from here and there and everywhere

10    and I'm supposed to go into all these things as to happened.  Nothing

11    happened as far as I'm concerned because he at that time was not a

12    volunteer of the Serb Radical Party.

13            Slavko Aleksic at the beginning of the war was a member of the

14    Serbian Democratic Party and an official of that party in the Novo Sarajevo

15    municipality.  When the war broke out, he proved to be a hero, a

16    commander.  Soon he became an officer of Republika Srpska.  He held the

17    most sensitive section of the Sarajevo front, the so-called Jewish

18    cemetery, where there was heavy fighting every day.  The Serb Radical

19    Party is proud of his valour, but he was not a volunteer who we sent from

20    Belgrade to the front line.  He's a man from Sarajevo.  In 1992 he became

21    a member of the Serb Radical Party.  In his unit there weren't any

22    volunteers from the Serb Radical Party that we had sent from Serbia.  He

23    had volunteers, but from different countries; Russians, Bulgarians,

24    Romanians, Greeks, even a Japanese person.  I personally met this Japanese

25    man.

Page 1937

 1            As for all these crimes that you ascribe to Slavko Aleksic, you

 2    invented all of that, you are falsely accusing him, although I really have

 3    no reason to protect him now because when Biljana Plavsic betrayed

 4    Republika Srpska, he followed Biljana Plavsic, and that's when I stopped

 5    all contact with him.  He disappointed me on a political level, but in the

 6    war he was a valiant warrior.

 7            Mostar.  First of all, let's get one thing clear.  In Herzegovina

 8    there were two groups of volunteers.  One was in 1991 in Mostar under the

 9    command of Oliver Dennis Barrett, who's an ethnic Albanian.  Mujo Bunjaku

10    [phoen] is his real name.  I didn't make him change his name.  I respected

11    him as an honourable man, but he for some reason changed his name on his

12    own, and he took the name of the hero of this movie called "The Love

13    Story," I think you remember that movie from the 1960s, it was a movie and

14    a book.  He was there until 1992.  He was with me at the rally in

15    Podgorica in May 1992.  When this hand-grenade was thrown at me he was

16    seriously wounded too.  He had a lot of shrapnel wounds on the abdomen and

17    on his legs.  He returned to Belgrade.  The commander -- it was Branislav

18    Vakic who became commander of the voluntaries.  You're not ascribing a

19    single crime to Oliver Dennis Barrett or Vakic.  You are charging people

20    who had nothing to do with the Serb Radical Party and then you say these

21    are my men.

22            You are also referring to this Arsen Grahovac in the context of

23    me, and you say that he spread the ideology of the Serb Chetnik Movement,

24    that he had a cafe called Ravna Gora, and the volunteers of the Serb

25    Radical Party came there.  As for this Arsen Grahovac, I never saw him in

Page 1938

 1    my life.  I never met him, but my associates studied his entire biography.

 2      He was a member of the Serb Renewal Movement and he was also a Municipal

 3    Assemblyman on manufacture of the Serb Renewal Movement.  He got killed in

 4    1993.  In Nevesinje there was a considerable stronghold of the Serb

 5    Renewal Movement.  They had three times more MPs than the Serb Democratic

 6    Party.

 7            You are saying here that he committed some crimes.  I don't know

 8    whether he committed these crimes at all.  However, as far as Ubarak and

 9    Sutina are concerned as crime sites, the OTP itself gave me documents from

10    the cantonal court of Mostar showing that the cantonal court in Mostar

11    issued an indictment against 30 Serbs for the crime in Ubarak and Sutina.

12    All 30 are from Mostar, Nevesinje, or the surrounding villages.  There's

13    not a single one from Serbia.  They are inventing some rally that I held

14    in Nevesinje which actually never took place in 1991 or 1992.  I never

15    held a rally there.

16            Then also they mentioned some Zdravko Kandic, that he commanded

17    the volunteers of the Serb Radical Party and the Serb Chetnik Movement.  I

18    never met that man.  He's a local person there.  He's not a volunteer from

19    Serbia.  You interviewed him.  Yesterday they tried to hand over to me

20    four CDs with suspect interviews, including Zdravko Kandic's interview.

21    The Prosecution knows that he's not from Serbia.  The Prosecution knows

22    that I did not send him from Serbia.  What do I have to do with him then?

23            Also as far as Teleca Lastva is concerned it has nothing to do

24    with volunteers of the Serb Radical Party.  Now I'm not going into whether

25    crimes were committed there or not.  Then Lipovaca, what does that have to

Page 1939

 1    do with volunteers of the Serb Radical Party?  You are mentioning these

 2    people who are volunteers from Draskovic's party.  Why?  Because it seems

 3    that even a few babies were murdered there, and then it suits you that I

 4    should be the criminal whose volunteers killed young babies.  That is how

 5    perfidious the OTP is in its endeavours.  I've never heard of crimes that

 6    took place there until the indictment was amended.

 7            Finally let's look at Hrtkovci because I have a few things to say.

 8    I am going to deal with Hrtkovci very quickly.  There is just one thing

 9    that is correct, that is that in the first half of 1992 I publicly said in

10    Serbia within my election campaign that there should be retorsion.  Over

11    200.000 refugees fled from Tudjman's regime, they came to Serbia, Serbia

12    was in a terrible condition, these refugees had nothing to eat, they did

13    not have a roof over their heads, this seemed to be a rational solution as

14    far as I'm concerned, and that was therefore the stand of the Serb Radical

15    Party in the elections that were held in 1992.

16            However, I also made a speech in Hrtkovci on the 6th of May.  We

17    have the speech on tape.  It's recorded and it was published in my books

18    twice, once a number of years ago and now in my latest book, "The Devil's

19    Apprentice, Pope John Paul II," and we can see that this is a speech

20    advocating the programme.  It's not true that I read out lists of names.

21    One of our activists read out the lists of names of Croats who had left

22    Hrtkovci for Croatia a long time ago and joined up with the Croatian

23    National Guards of Tudjman, so that's what this list refers to.  In

24    Vojvodina there was no attack on the civilian population anywhere.  There

25    was sporadic incidents before this meeting and after the meeting.  But the

Page 1940

 1    police investigated and threw light on those incidents during the rally.

 2            A killing did take place but it has nothing to do with this one

 3    here and you know for something to be dealt with at this Tribunal the

 4    crime must have been committed within the frameworks of an armed conflict,

 5    that's the first point; and secondly, there must be an attack, widespread

 6    or systematic.  There's no attack here.  That's the point, whereas

 7    incidents that take place in the streets and other public places are

 8    unavoidable when you have a large number of refugees from Croatia, Serbs

 9    that were expelled by the Tudjman regime.  So what is that to do with me?

10    I sent here a report on almost 400 pages prepared by my associates.  I

11    handed that in as a contribution to the objections to the indictment.  You

12    can study it, you need not -- a book of documents will appear recently

13    that we prepared on that document, but the most important thing is this:

14    That not a single Croat was deported from Serbia, nobody was expelled from

15    Serbia.  Their property was not seized.  It was only Croats who left and

16    exchanged their property with Serbs and the Roman Catholic Church always

17    acted as mediator and no agreement was reached until the Roman Catholic

18    Church in Vojvodina through its channels checked to see whether the Serb

19    property was left behind in Croatia, and when they found out that the

20    Serbs fleeing had left their property which consists of such and such,

21    then an exchange took place and it was always the Croats that fared much

22    better in that exchange than the Serbs did.

23            I've already said what I think about being accused of saying that

24    children from mixed marriages should be killed and there was another

25    shoehorn incident mentioned, and that was brought up by Minimax a

Page 1941

 1    comedian, a Serb comedian in a program called Minimaxovizija.  Because of

 2    the communist prejudice, part of the public thought that Serb Chetniks

 3    were traditional slaughterers, cutters of throats and that's how the

 4    communists portrayed them in World War II.  In this humouristic programme,

 5    he asks me, "You Chetniks, are you still cutting throats?"  And my answer

 6    was a very quick one.  "Of course we slaughter but we no longer slaughter

 7    with knives, we slaughter with shoe-horns which had gone rusty, rusty

 8    shoe-horns in actual fact so you can't know whether the victims succumbed

 9    to tetanus or to throat cutting."  Well, black humour, perhaps you don't

10    like that kind of humour, I myself do, and that programme was televised

11    two years ago when Minimax died, the comedian Minimax died, and I write

12    about all this in my book and now the Prosecution has found a false

13    witness who said at the rally in Subotica I said we are going to gouge

14    Croats, their eyes, with rusty shoe-horns.  When I mentioned shoe-horns, I

15    never mentioned Croats at all in the same context.

16            Now, gentlemen, Judges, I have a few more words to say in the 22

17    remaining minutes.  Four years in detention for me was a systematic

18    violation of my rights, which is so evident that it hampered the public

19    interests and the credibility and moral and legal integrity of the

20    International Tribunal even if it were legitimate and lawful.  And it also

21    completely jeopardized the right of that Tribunal to try me as an accused.

22    It is quite obvious an abusive procedure which does not question authority

23    but makes it incumbent on the Trial Chamber to exercise its discretionary

24    right and refuse to try an accused if there has been a violation of the

25    rights of the accused.  Now, you have been almost five years too late, so

Page 1942

 1    it's impossible to ensure a fair trial after that passage of time, and any

 2    request to try me you as the Trial Chamber are asked to violate your own

 3    feelings and sentiments of legality and proper conduct.  The violations of

 4    my rights are very serious so that you cannot keep your own integrity

 5    except by exercising your discretionary right to rescind the indictment --

 6    dismiss the indictment.

 7            Over the past five years I have been subjected to systematic

 8    torture.  Now, what did that torture consist of?  As to the length of

 9    detention, a reasonable period of time was long overstepped.  There's no

10    lawyer in the world that won't confirm that that reasonable amount of time

11    was overstepped a long time ago.  On two occasions I was refused all

12    contact with my immediate family, the first time for seven months, the

13    second time for two months, telephone contacts and all other contacts.

14    Four -- for four years they have tried to impose counsel upon me.  First

15    of all, that created mental disquiet and it was a costly procedure.  Legal

16    proceedings were taken with the Dutch Chamber and so on with respect to

17    persons that wanted to be my Defence counsel.  And for four years I was

18    prevented from communicating with my legal associates in regular fashion.

19    They also refused in the beginning to send me documents in the Serbian

20    language and in hard copy, on paper.  It took four years for them to

21    impose electronic disclosure, and they limited the length of my motions

22    and the Trial Chamber overstepped its authority because it is not a legal

23    act; they can only make recommendations.  So his recommendation is not the

24    same as a Statute or Rules of Procedure and Evidence.

25            With the mention of names of certain members of the Registry and

Page 1943

 1    their criminal acts, let me say that I was prevented from speaking, the

 2    floor was taken away from me, all the transcripts were redacted which is

 3    also against the law.  No member of the Registry can be protected to be

 4    tried by the public.  In June 2005 I was informed that an initiative was

 5    taken to establish a lack of respect of the Tribunal -- contempt of court,

 6    actually, and I don't know why that motion was set in motion because

 7    everything was done secretly.  So I don't know why the Prosecutor

 8    initiated proceedings for contempt of court.  At the end of 1995, the

 9    Trial Chamber issued an order to seize some of my documents which had

10    previously been disclosed to me by the Prosecution.  I don't know to the

11    present day what the contents of those documents are, I didn't have time

12    to read them through all, but they just stormed in with an order to seize

13    the documents in my cell and now allegedly the Registry is storing those

14    documents.  I don't know what they're about, what they contain.

15            Pursuant to Rule 68(i), potentially exculpatory material has not

16    been disclosed to me.  What I received was negligible compared to all the

17    documents that the Prosecution has at their disposal in that regard.  I

18    have been forced over these five years to be witness to systematic and

19    terrible pressure and coercion on other Hague accused to agree to plea

20    agreement with the Prosecution and to testify against other people.  There

21    have been -- there has been a lot of false testimony.  There was also some

22    killing, and a group of officers accused of the crimes in Srebrenica,

23    Lieutenant-Colonel Dragan Jokic was brought out although he has already

24    been judged, he's forced -- he was forced to testify but he did not reach

25    a plea agreement and since he refused to testify, having been under

Page 1944

 1    pressure, proceedings were initiated for contempt of court.

 2            They are prone to use intimidation, pressure, and other forms of

 3    method.  They told people that they are potentially a suspect and that

 4    they would be indicted.  Some people buckled in and agreed to testify

 5    against me, but now when the Hague Tribunal is no longer able to issue

 6    proceedings against them they refused to be false witnesses anymore.  The

 7    Prosecution promised other people that if they falsely testify against me

 8    their entire families would be transferred abroad, they would get a new

 9    house, new job, money, et cetera, and they agreed.  They would sell their

10    soul to the devil and then it turned out The Hague Prosecution office

11    cheated them, they got none of those things and now they don't want to

12    testify anymore.

13            Despite the decision in principle, that you, Mr. Antonetti, took

14    as the Pre-Trial Judge, the issue of financing my Defence has not been

15    resolved yet.  Furthermore, one of the other forms of harassment and

16    torture is the decision of the Trial Chamber to extend proceedings for

17    contempt because of the accusations I made against the previous

18    Prosecutor.  It was said in their decision that that would be dealt with

19    once my trial is over.  It makes no sense then.  That issue had to be

20    dealt with urgently.

21            Administratively, a large number of my submissions were returned

22    to me because of insulting contents.  I admit to some insulting things

23    that I instructed my associates to write at the time of Van der Spoel, who

24    the Court tried to impose on me as counsel, but this cannot be returned to

25    me by administrative decision.  The Trial Chamber has to reject my

Page 1945

 1    submissions, explaining their decisions and the reasons.  Now, the

 2    Registry is here taking over some of the competences of the Trial Chamber.

 3    I was forbidden from mentioning any names at Status Conferences under the

 4    pretext that perhaps these people are protected witnesses, which is

 5    unbelievable nonsense.

 6            There is -- there are too many witnesses enjoying protective

 7    measures.  That is inconceivable for a fair trial, for a regular trial.

 8    It is unlawful to delay the revealing of the identity of witnesses until

 9    30 days before the beginning of the trial on the explanation that the

10    first witness marks the beginning of the trial.  The trial began

11    yesterday.  It is completely unlawful to decide that the identity of some

12    witnesses would be revealed to me 30 days before their testimony.  There

13    is no grounds for that in the rules.  The indictment against me is now

14    reduced.  Now it's not reduced.  Western Slavonia, Bijeljina, Brcko, et

15    cetera were taken out, but the Prosecution did not reduce the number of

16    witnesses and they still intend to present crime base evidence, so I don't

17    know whether to defend myself from that or not.  And one more thing, this

18    trial has begun without all the pre-trial procedural requirements having

19    been met.

20            From yesterday's opening statement of the Prosecution, it was

21    obvious that I am being tried and the indictment against me was raised

22    because of my nationalist ideology and that everything boils down to this

23    nationalist ideology and the speeches I made, spreading that nationalist

24    ideology.  I am proud of that.

25            With this false indictment, the Prosecution helped me make this

Page 1946

 1    ideology even more sophisticated and to use those five years to shape it

 2    even better.  And I am especially grateful to the Prosecution for enabling

 3    me to suffer for my ideology.  With this trial, my ideology of Serb

 4    nationalism cannot be uprooted from the Serbian people.  It will grow even

 5    deeper roots.  My life no longer matters.  My ideology is alive and it

 6    will live for hundreds of years after my death.

 7            But in order for an ideology to be so powerful and so strong, its

 8    architect has to show, to demonstrate, his readiness to suffer for it.

 9    And I am grateful to The Hague Tribunal for giving me the opportunity to

10    suffer for my ideology.  I express my great regret that those who wrote

11    the Statute of the ICTY did not envisage the death penalty so that

12    proudly, with dignity, upright as my friend Saddam Hussein, I could put a

13    final seal on my ideology.  It would become immortal.  Since I am deprived

14    of that opportunity, the only thing left to me is to appeal to you to make

15    sure that your judgement metes out the harshest possible sentence.  The

16    harsher the sentence, the stronger my ideology would be.

17    I lived long enough, but I want immortality for my ideology.  I have already

18    made it immortal by making it ideologically sound, by grounding it firmly

19    in historical fact, by making it anti-globalist, by being an open opponent

20    of the planetary hegemony and dominance of the United States of America,

21    that I am an opponent of the European Union and by being a great enemy of

22    the NATO.  That is why I am being tried in the first place and trying me

23    is a good idea.

24            At the end of this expose I want to remind you of one of the

25    greatest works in literature, the novel "War and Peace" by Tolstoy, Leo

Page 1947

 1    Tolstoy.  In one of the chapters Tolstoy describes the march of Napoleon's

 2    soldiers into Moscow and how Moscow burned and how Napoleon's soldiers

 3    arrested a group of Russian people and took them to be executed.  Among

 4    those arrested Russians was Count Pierre Bezukhov with his hands tied he

 5    was going to the execution site.  And at one point he started laughing out

 6    loud, a loud, sincere laugh and Count Bezukhov says:  "They think they

 7    tied me up.  They think they can tie and bind my mortal soul."  Well, this

 8    Hague Tribunal and the Prosecution think they can convict me, that they

 9    can convict my nationalist ideology, and I have to laugh out loud, ha, ha,

10    ha.  You cannot harm my immortal soul, you cannot harm by nationalist

11    ideology.  I may die soon, but if I do, I'll die of laughter because of

12    this ridiculous laughable indictment, the laughable Tribunal, and the

13    laughable United States and other Western powers that stand behind this

14    ridiculous Tribunal.

15            Thank you for your patience in listening to me.

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

17    what you had to say pursuant to Rule 94 bis.

18            THE ACCUSED: [Interpretation] [Previous translation continues] ...

19    Interpretation.

20            THE INTERPRETER:  84, interpreter's correction.

21            JUDGE ANTONETTI: [Interpretation] Let me start again you have

22    finished, completed your statement pursuant to Rule 84 bis.  I'd like to

23    thank you for having cut down on the time that was allotted to you.  Of

24    course if you ever need some extra time we will give you that extra time.

25    I can only close this hearing on the conclusion you made.  This Tribunal

Page 1948

 1    will neither convict or acquit you on the basis of an ideology, but on the

 2    basis of evidence adduced by the Prosecution who beyond all reasonable

 3    doubt will have to be confirmed.  And your responsibility will be assessed

 4    against all of this evidence at the end of this trial.  And you will also

 5    be providing you -- your evidence as you did and mention in the pre-trial

 6    brief.  I'd like you to know that as far as I'm concerned - and I think I

 7    can speak on behalf of the rest of the Bench - you have before you three

 8    Judges that are wholly independent and that will only try you on the basis

 9    of a case file.  This is what I wish to tell you.  What happened before

10    the beginning of this trial is one thing; this trial will be another.

11            We shall meet again, as you know, on the 11th of December.  The

12    11th of December a witness is going to come to testify, this is Witness

13    Oberschall, who will testify for three days.  We are currently looking

14    into the exact time of the commencement of this hearing.  I believe it

15    will be in the morning, Tuesday, Wednesday, and Thursday, but it may

16    happen that given that other Judges on this Bench are also sitting in

17    other cases, we need at least one hour between one case and another.  In

18    that case, we might have to start our hearings at 8.30 in the morning but

19    we have to deliberate on that matter.

20            Mrs. Dahl, you have the floor.

21            MS. DAHL:  Yes, we have provided notification that we will have a

22    crime base witness available for the third day in the event that

23    Dr. Oberschall's testimony is completed in two trial days.  I think that

24    as we get into the case we will establish a rhythm and I'll be able to

25    predict better how long things will take, but I'm quite parsimonious in my

Page 1949

 1    allocation of court time and want to make sure that we have someone at the

 2    ready in case it goes faster than expected.

 3            JUDGE ANTONETTI: [Interpretation] Very well.

 4            Yes, I have one minute left before 1.30.  I would like to remind

 5    you, Mrs. Dahl, that I would -- this is something I would like to impress

 6    on you.  I would like you to make available to the Bench a folder, and

 7    Mr. Seselj needs to have his own folder of your documents, because the

 8    e-court system is sometimes too difficult to use for somebody representing

 9    himself, and the accused will not be able to look at the documents and

10    check the screen at the same time.  So in this binder you should provide

11    all the documents.  I also like to work on hard-copy documents.

12            It's now 1.30, and I'd like to thank you and see you on the 11th

13    of December.

14                          --- Whereupon the hearing adjourned at 1.29 p.m.,

15                          to be reconvened on Tuesday, the 11th day of

16                          December, 2007