Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12809

 1                           Wednesday, 10 December 2008

 2                           [Open session]

 3                           [The witness entered court]

 4                           --- Upon commencing at 8.31 a.m.

 5                           [The accused entered court]

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

 7     case, please.

 8             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 9     everyone in and around the courtroom.

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

11     Vojislav Seselj.

12             Thank you, Your Honours.

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

14             Today is Wednesday, 10th of December, 2008.  Good morning to

15     everyone.

16             Mr. Registrar, can we move to private session for a few minutes.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 12810

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             THE REGISTRAR:  We're in open session, Your Honours.

 5             JUDGE ANTONETTI: [Interpretation] Let us wait until the blinds

 6     are up.

 7             Sir, please state your first name, last name, and date of birth.

 8             THE WITNESS: [Interpretation] Jovan Glamocanin, born on the 16th

 9     of June, 1940, in Subotica.

10             JUDGE ANTONETTI: [Interpretation] What is your current

11     occupation?

12             THE WITNESS: [Interpretation] I am a retiree, but I have a degree

13     in law.

14             JUDGE ANTONETTI: [Interpretation] Have you had an opportunity to

15     testify before a domestic or international court of law as to the events

16     in the former Yugoslavia or is this going to be the first time you're

17     going to testify?

18             THE WITNESS: [Interpretation] This is the first time I'm

19     testifying.

20             JUDGE ANTONETTI: [Interpretation] Please read out the solemn

21     declaration handed to you by the usher.

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

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

24                           WITNESS: JOVAN GLAMOCANIN

25                           [The witness answered through interpreter]

Page 12811

 1             JUDGE ANTONETTI: [Interpretation] Thank you, sir.  Please be

 2     seated.

 3             THE WITNESS: [Interpretation] Thank you.

 4             JUDGE ANTONETTI: [Interpretation] Before we start asking

 5     questions of you and providing you with information, I believe Mr. Seselj

 6     had a request.

 7             Did you have anything to say, Mr. Seselj?

 8             THE ACCUSED: [Interpretation] No.

 9             JUDGE ANTONETTI: [Interpretation] Very well.

10             So let me explain to you several things.

11             You have been called to testify by the Trial Chamber, therefore

12     at the request of the Judges of the Bench in front of you.  I recall or

13     remind you of some facts, and I know you're a lawyer; and I'm sure,

14     therefore, that you will understand straight away what I'm about to say.

15             It is true that you had not requested any protective measures

16     back then, but on the 15th of February, 2005, the OTP had made an

17     application to another Trial Chamber than this one for protective

18     measures, and in the filings made by the OTP, it was alleged that you had

19     some fear for pressure or harassment.  That's the reason why protective

20     measures had been granted to you.  A pseudonym had also been given,

21     "VS-044."  Later on, you told the OTP that you didn't need any protective

22     measures.  The OTP had taken you out of their 65 ter witness list in 2007

23     because, from the point of view of the procedure, the indictment against

24     Mr. Seselj had been reduced, and therefore there were witnesses that were

25     no longer needed.  That's the reason why you were struck off their list.

Page 12812

 1             Later on, the OTP made another application for your name to be

 2     added to the witness list, and on the 17th of June, 2008, the Trial

 3     Chamber had granted the application.

 4             Why were protective measures applied for?  We'll get to that

 5     later on, but it's also because in your statement you had said that at

 6     some point in time, people close to the Serb Radical Party allegedly

 7     tried to kidnap your wife or your daughter - we're not quite sure about

 8     that - and that you had hired bodyguards, and that was the setting in

 9     which the protective measures had been granted.  And then a series of

10     events took place.  You had some fear.  You feared being assassinated,

11     and you no longer wished to testify.

12             There was quite some spectacular event that took place; namely,

13     that publicly you stated that you were going to be a Defence witness,

14     that is, a witness for Mr. Seselj; and together with Mr. Vujic, on the

15     20th of November, 2007, you took part in a press conference during which

16     you publicly stated that you were going to be a Defence witness.  You

17     even granted an interview after that to 'Pravda,' and you blamed the

18     Prosecution or accused the Prosecution, but I'm not going to go into

19     that.

20             So the Judges were faced with an unheard-of problem so far in the

21     history of the Tribunal, namely, that a Prosecution witness was then

22     saying that he was going to be a Defence witness, and we had to sort it

23     out.  We were of the view that we were able to find a solution by calling

24     you as a witness, by issuing a summons for you to come and testify.  You

25     were then called by a judge in Belgrade, who conveyed this to you.

Page 12813

 1             On the 4th of November, 2008, you sent me a mail in which you

 2     explained that you were a Defence witness, inasmuch as you felt that the

 3     statement you had made over four days in 2003 was not Prosecution

 4     evidence against Mr. Seselj, in your view, and that you wanted to be a

 5     Defence witness, as you were of the view that Mr. Seselj was innocent,

 6     not guilty of the charges against him.  This being so, we maintained the

 7     summons.  This is the reason why you appear here today, and just as well,

 8     because if you had failed to appear, we would have been forced to indict

 9     you for contempt of court, and this would have sent you straight away to

10     jail.  So you were right in meeting our summons.

11             The purpose is this:  We want to have the truth manifested, to

12     know exactly what happened in that period of the years 1992 and 1993.  We

13     want to know what the involvement of the SRS was in certain events, what

14     everybody's part was.  We want to know what your position was within the

15     SRS.  These are questions that can be answered through your presence in a

16     very serene and calm manner, so that this hearing can unfold as smoothly

17     as possible.

18             By way of explanation, I also add that the Judges -- I'll start,

19     but that the Judges have a series of questions for you.  It should take

20     one and a half to two hours.  Thereafter, the parties, that is, the

21     Prosecution and Mr. Seselj, will each have an hour to put questions to

22     you, questions that they deem appropriate.

23             Have you understood everything I said?  You're aware of the

24     climate and spirit in which you're going to testify?

25             THE WITNESS: [Interpretation] Yes, Mr. President.

Page 12814

 1             JUDGE ANTONETTI: [Interpretation] Very well.

 2                           Questioned by the Court:

 3             JUDGE ANTONETTI: [Interpretation]  We are, first of all,

 4     interested in knowing your professional background, your education in

 5     particular.  Could you, in a few words, tell us what your university

 6     background is?

 7        A.   First of all, I studied at the Higher School for State

 8     Administration.  Then I went to the Law Faculty, and I held high

 9     positions in the business community and in the state administration.  I

10     was secretary of two companies:  One was an agricultural farm and the

11     other one was a construction company.  I was general manager of a big

12     factory, the Utva aircraft factory.  I was a member of the board in

13     charge of general and legal matters, and of course I was a federal MP

14     too.

15             After leaving the Serb Radical Party, I became rather passive,

16     politically speaking, but so far I've completed about ten serious papers,

17     namely, seven papers and eight books pertaining to the state system, the

18     political system.

19             I'm preoccupied with the fate of the Serbian people.

20             THE INTERPRETER:  Interpreters note, we could not hear the

21     witness due to background noise.

22             THE WITNESS: [Interpretation] We have been dealing with the --

23     rather, I have been dealing with the history of the Serbian people, and I

24     became, therefore, a member of the Academy of Spiritual Work.  It is --

25     its seat is in Crimea, in Russia, but then it is also in other countries.

Page 12815

 1             JUDGE ANTONETTI: [Interpretation] I shall return to several of

 2     these points, but let's focus on your university background.

 3             You studied at the law school in the Belgrade University.  I

 4     guess that you graduated, you got a license, or a BA, or a doctorate.

 5     What is the exact title?

 6        A.   No.  On the basis of these papers and books I've written, I

 7     became a member of this academy, a regular member.  It's not a state

 8     academy.  It was established by creative people from different walks of

 9     life.

10             JUDGE ANTONETTI: [Interpretation] One moment.  There must have

11     been a hitch in the translation.  I was asking you this:  You studied at

12     the university, and I wanted to know whether, when you were studying at

13     the law school, you eventually graduated, and you graduated with a PhD in

14     law, or a Master's, or a BA; what is the actual degree that you got?

15        A.   I got my law degree in Belgrade.  I have a diploma, a BA as a

16     jurist.  As for these other scholarly works that I engaged in --

17             THE INTERPRETER:  The interpreters could no longer hear the

18     witness.

19             JUDGE ANTONETTI: [Interpretation] I'm not interested in the

20     books, but you said that you are -- you graduated in law.  What was your

21     specialty in law, because I noticed that you wrote papers --

22        A.   The stream that I studied at was commercial law.

23             JUDGE ANTONETTI: [Interpretation] In commercial law, I see.

24        A.   Matters pertaining to procedural law.

25             JUDGE ANTONETTI: [Interpretation] As to your career, your

Page 12816

 1     professional background, you said that you had various occupations, you

 2     worked in many companies.

 3        A.   I was secretary of the municipality, too.

 4             JUDGE ANTONETTI: [Interpretation] Yes, but let's wait until we

 5     get to the political side of things.  I'm still with the administrative

 6     matters.

 7             In the various posts that you occupied, I think that the common

 8     denominator was that they basically focused on administrative matters,

 9     logistical and organisational matters.  Was that your primary skill, when

10     it came to those positions?

11        A.   Yes, yes, but I also worked in the business community.  I was a

12     member of the collective general manager, as it were.  I was a member of

13     a board of a big company, big in terms of our country, on that scale.

14             JUDGE ANTONETTI: [Interpretation] Let me now deal with the

15     political part.  I was under the impression that after doing your

16     military service in the JNA, just like any other citizen, you then, in

17     1963, joined the League of Communists of Yugoslavia.  Can you confirm

18     that?

19        A.   That is correct.  I joined the League of Communists of

20     Yugoslavia.  I was a member of the municipal committee and the district

21     committee of the League of Youth of Subotica.

22             JUDGE ANTONETTI: [Interpretation] Very well.  Were you then a

23     firm believer of communism or did you join the League of Communists

24     because it was the only way to get anywhere in high positions?

25        A.   Well, you know what, at that time lawyers didn't have much of a

Page 12817

 1     choice.  They had to be involved in the existing political and economic

 2     system.  That was one of the motives.

 3             The second motive was that this self-management socialist

 4     Yugoslavia was a progressive, respectable state, and I think that through

 5     one's knowledge and one's work, one was supposed to help the development

 6     of that country.  It was a successful country, from the point of view of

 7     the economy, from the point of view of foreign policy, in every

 8     conceivable point of view.  Over here, even, in this court, it was often

 9     pointed out that we had a very good and capable army, and in all other

10     fields we were a country that prospered.

11             I believed, as a citizen, that it was my responsibility to give a

12     contribution that even exceeded what my obligation might have been.  I

13     liked that country.

14             JUDGE ANTONETTI: [Interpretation] Very good.  So in order to

15     contribute to the country that you say you loved, you took up positions

16     at municipal level.  What prompted you to enter that sphere of municipal

17     politics.

18        A.   Well, you see, in my career I was never in a position to make

19     requests, to ask for something.  Every time when I would change jobs,

20     people asked me to move on, to take a job that was even more complex,

21     because up until then I had been successful in carrying out my duties.

22             JUDGE ANTONETTI: [Interpretation] This is the reason why you

23     joined the municipal administration?

24        A.   Correct.

25             JUDGE ANTONETTI: [Interpretation] Very well.  Let us now speak

Page 12818

 1     about your political involvement before you joined the Serb

 2     Radical Party.

 3             Could you, in a few words, tell me what you did politically,

 4     knowing that the League of Communists is an organisation that you're

 5     going to leave, that you left in order to move on to political actions by

 6     way of writing articles, et cetera; so could you say some more about it

 7     as to your political involvement before you joined the Serbian Radical

 8     Party?

 9        A.   Mr. President, I was always preoccupied with the fate of my

10     state, especially of my people, the Serb people.  In my family, many

11     people had lost their lives in the most recent wars, and in all the wars

12     in which the Serb people had participated and suffered greatly.  As

13     secretary of the municipality in Banat from 1974 onwards, that is to say

14     from the moment when this Constitution of Yugoslavia was adopted, namely,

15     the Constitution that transformed Yugoslavia partly into a confederacy, I

16     immediately came to the conclusion that that kind of a community, that

17     kind of a setup, was incapable of functioning properly.  Nevertheless,

18     Yugoslavia did function.

19             However, what I found interesting and what I thought was

20     unacceptable was the fact that Serbia was subdivided into three parts.

21     It had two provinces that were completely independent and geared towards

22     the federation, in terms of all its powers.  Vis a vis Serbia, it only

23     had a formal relationship, proof to tell, the Constitution did provide --

24     the Constitution of Yugoslavia and the Constitution of Serbia, that is,

25     did provide for the possibility of transferring some authority to Serbia

Page 12819

 1     itself that basically was given to the provinces by the Constitution.

 2     However, this was not taken advantage of.  On the contrary, separatists

 3     and independents grew in both provinces.

 4             As for Vojvodina, there were no inter-ethnic tensions, none that

 5     I would have noticed, but in Kosmet there were major problems.  These

 6     problems escalated at the time of the crisis faced by Yugoslavia, and as

 7     a person who is primarily engaged in patriotism rather than politics, I

 8     joined this movement to save the Serb people in Kosovo and Metohija and

 9     to have Kosmet and Vojvodina returned within the state structure of the

10     Republic of Serbia.

11             Since that was my option, from an emotional and a rational point

12     of view, vis a vis our people, the Serb people, and the other peoples --

13     of course, I'm not in favour of any kind of mistreatment, or any kind of

14     force, or any kind of discrimination against any people, may I add;

15     however, I joined a movement that we then called the Serb People's

16     Movement, or, rather, the People's Movement for a United Serbia.  And

17     later on, I was one of the top people of that movement for Vojvodina, and

18     it was on the crest of that movement that Kosovo and Metohija and

19     Vojvodina were returned in 1989 to the state structure of Serbia, because

20     the Constitution of Serbia was amended.

21             As an individual, as an intellectual, I took part in that

22     movement.  I made my proposals in newspapers.  I was the first one in

23     Vojvodina to do so, in order to have these amendments passed to the

24     Constitution of Serbia, these amendments that restored the authority of

25     Serbia over both provinces.

Page 12820

 1             Later on, I wrote a study, a paper, about autonomy.  Later on, I

 2     expanded it and wrote a book.  I think that many scholars, including a

 3     lady who testified here, Smilja Avramov, believe this is the best book

 4     written in the territory of the former Yugoslavia about the subject

 5     matter of autonomy.

 6             I was in this movement.  I was arrested four times by the State

 7     Security Service, but of course I persevered because I was convinced that

 8     I was fighting for the right thing, for elementary rights; the right to

 9     life, the right to freedom of the Serbian people and all citizens of

10     Serbia and Yugoslavia.  And this did not lead me to waver.

11             JUDGE ANTONETTI: [Interpretation] Let me stop you, sir, because

12     your answer returns over several pages of the transcript, and this is a

13     complex matter and I have to sum it up.

14             Your approach seems to be connected to the following observation

15     you made:  You realised that Vojvodina and Kosovo-Metohija were, in

16     relation to Serbia, autonomous or quasi-autonomous areas, and your fight

17     was to try and unify all this within the Republic of Serbia.  Based on

18     that, you wrote papers and you tried to make yourself known.  This

19     political fight, the struggle you fought, was basically focused, as I

20     understood you, on the situation in Kosovo-Metohija, and this resulted in

21     you having some political weight in Serbia.

22             Is this the way we can sum up what you did before you met with

23     the Serbian Radical Party?

24        A.   Mr. President, I have to make things clear, clarify one of your

25     questions.

Page 12821

 1             I didn't fight against the autonomy of Vojvodina, Kosmet, within

 2     the frameworks of Serbia, but I fought against the status of both

 3     Vojvodina and Kosmet in which they were completely autonomous and

 4     independent in relation to Serbia, because the provinces had their

 5     constitution, they had their police force, they had their legal organs,

 6     courts.  Serbia only had formal authority over the provinces.

 7             And in addition to that, I also fought to have a realistic status

 8     given to the provinces, because that was one of the conditions for

 9     Yugoslavia, as a state, to be able to function.  So in that struggle of

10     mine, I and all those who took part in this did not question Yugoslavia

11     and the functioning of Yugoslavia.

12             I became well known.  I was at the head of the organisation which

13     was called the Alliance of Solidarity of Yugoslavia or Union of

14     Solidarity, and the Serbian Radical Party had not been established at

15     that time.  I became a member of the Serbian Chetnik Movement.

16             And in this court --

17             JUDGE ANTONETTI: [Interpretation] Just a minute, before we get to

18     the Serbian Chetnik Movement.  I would like us to stay in 1990.

19             It seems that in 1990, you will set up a small party.  Could you

20     tell us exactly which party you set up.

21        A.   The party was not well known.  It was just a contribution to try

22     to force the powers that be to allow us to set up new political parties

23     or, rather, to introduce a multiparty system.  And it was on the basis of

24     that popular movement for a united Serbia, which the regime of

25     Slobodan Milosevic had to accept, was forced to accept, we had

Page 12822

 1     discussions with Slobodan Milosevic which lasted six and a half hours,

 2     and our activists from Kosmet and Vojvodina were there.  And at the

 3     meeting, we managed to convince him that a multiparty system must be

 4     introduced in Serbia.

 5             And it's interesting to note that at that meeting, it was

 6     concluded that new parties should not be established, that we should not

 7     form new parties.  But we persevered and did stand by our decision to set

 8     up a party, and it's interesting that the conclusion of the session was

 9     that parties should not be formed, but we nevertheless went ahead and did

10     form a party.  And a week later, there was a proclamation after the

11     meeting, a statement after it, when they saw that we had set our minds to

12     form the parties and persevere that the citizens of Serbia should be

13     allowed to establish parties.

14             So that was our role.  We put in a lot of effort there, and the

15     State Security did its best to suppress us and our actions, but we never

16     spared any effort because we managed to achieve one of our goals, and

17     that was to introduce democracy into Serbia and a multiparty

18     parliamentary democracy.

19             JUDGE ANTONETTI: [Interpretation] So if I'm not mistaken, this

20     was called the Democratic Party of Freedom in your own language,

21     "Demokratska Stranka Slobode," and I apologise for my pronunciation.  Was

22     that what this party was called?

23        A.   Yes, that's right, that's what it was called, the "Demokratska

24     Stranka Slobode."

25             JUDGE ANTONETTI: [Interpretation] Very well.  So this is an

Page 12823

 1     interesting contribution, because so far this had not been mentioned.

 2             So you were talking to Mr. Milosevic, and you tried to get him to

 3     understand that he had to move the country into a multiparty democracy.

 4     And it's in this framework that you set up your small party, but

 5     obviously he didn't really like the idea.  Is that it?

 6        A.   Well, it was like this:  I was in favour of having Serbia take on

 7     the initiative in restructuring the state in this transition towards a

 8     democratic system, and that we should have the initiative -- take the

 9     initiative within Yugoslavia, because there was a crisis looming in

10     Yugoslavia.  The Croats and Slovenians had taken this initiative, and

11     they got the advantage, which they used with respect to Germany, the

12     Vatican, later on the United States and so on.

13             JUDGE ANTONETTI: [Interpretation] Why didn't you join the

14     Socialist Party of Serbia?

15        A.   I didn't join the Socialist Party of Serbia because it was a

16     party which was formed in an inconsistent way.  The League of Communists

17     of the day and the Socialist Alliance of the Working People of Yugoslavia

18     transformed itself to become the Socialist Party.

19             Now, I respect people with conviction, who act in politics on the

20     basis of their convictions and on the basis of their ideology, and not on

21     the basis of the wish to rule and to take advantages of the existing

22     situation, opportunistically, and that's what happened.  It happened in

23     all countries of transition.  The former Communist parties became

24     Socialist parties.

25             I was in favour of democracy.  Those were my beliefs.  I come

Page 12824

 1     from a family that has those traditions.  My father fought for democracy,

 2     and he emerged from World War II as a Chetnik commander.  And here

 3     Chetniks are spoken about in a derogatory manner.  There's a derogatory

 4     view of them, unfavorable, but I'll explain that in due course later on.

 5             JUDGE ANTONETTI: [Interpretation]  Let's come closer to the very

 6     heart of the matter, which is your joining the Serbian Radical Party.

 7             Could you please tell us whether at the time, February/March

 8     1991, tell us what you -- what was your impression of the Serbian Radical

 9     Party at the time, as well as of its leader, Mr. Seselj?  What was the

10     impact of this party and its leader on the political life at the time,

11     and on what grounds did you decide to join this party?

12        A.   I first met Mr. Seselj as the president of the Serbian

13     Freedom-Loving Movement, which was the first political organisation which

14     he established, and that was a political party with a Yugoslav

15     orientation.

16             And I remember well that one of my co-fighters from Bosnia,

17     Asim Delic, for example, was one of the founding members of that Serbian

18     Freedom-Loving Movement.  It was a movement of distinct Yugoslav

19     orientation.  Asim Delic fought in Bosnia against the bureaucracy that

20     had entrenched itself there and sought greater freedoms for the citizens.

21     They had Galijasevic with them and many others.  And if I can put it this

22     way, the prime political fighters for the new democratic system and the

23     reconstruction of Yugoslav based on democracy went along with Dr. Seselj;

24     and they promoted a programme and policy for the defence of Serb national

25     interests, but within the frameworks of Yugoslavia, of the Yugoslav

Page 12825

 1     community.  And Dr. Vojislav Seselj remained along those lines up until

 2     the formation of the Chetnik Movement and the Serbian Radical Party.  He

 3     remained true to those ideals of adopted the same position.

 4             Of course, when Yugoslavia disintegrated and fell apart, and when

 5     foreign forces -- foreign intelligence services became involved and

 6     meddled, and they destroyed that joint state, we had to think about the

 7     fate of our own people, our own nation, and seek out a programme by which

 8     we would be able to defend the interests and protect the interests of our

 9     people, because on the political arena of Yugoslavia or, rather, Croatia,

10     Slovenia, Bosnia-Herzegovina and Kosmet, we had the burgeoning of

11     destructive forces that came to the fore, which in World War II were on

12     the side of Hitler's Germany, and Mussolini, and they effected genocide

13     over the Serbian and other people.

14             JUDGE ANTONETTI: [Interpretation] You have told us at length what

15     Mr. Seselj might have embodied, but I believe that I understood that you

16     did not join because of Mr. Seselj because of a number of ideas that

17     could have allowed the Yugoslav people, in all its diversity, to face up

18     to the collapse of the country.  So could you tell us, in details,

19     exactly what, in 1990 and 1991, were the values that the Serbian people

20     wanted to obtain and reach?  What could have been the political platform

21     of a party bringing together a number of people that could promote a

22     project?  Could you tell us what the objective of such a political party

23     could be?

24        A.   The objectives were the preservation of Yugoslavia as a stable,

25     multinational community, without bringing into question the interests of

Page 12826

 1     each and every one of the Yugoslav peoples, the national minorities too,

 2     and also to establish a position of equality for the Serbian people,

 3     because it was quite obvious that the Serb people were being expelled

 4     from Kosovo and Metohija.  There were many cases of violence against the

 5     Serb people, and you have the following piece of information, for

 6     example.

 7             In the 1939 census, Serbs and Siptars or, rather, Albanians,

 8     there was an equal number; 10.000 or 15.000 less Serbs.  Now, according

 9     to the census -- well, it wasn't in 1991.  But, anyway, according to the

10     next census, the Serbs dropped to 200.000, to the figure of 200.000 --

11     or, rather, 300.000.  Now, today, there are just about 150.000 Serbs in

12     Kosmet, or even less.  So it wasn't the number of Siptars that decreased

13     in Kosovo and Metohija, with all the authority that Yugoslavia and Serbia

14     had, but it was the number of Serbs that were reduced.  The Siptars had

15     their own movement of independence geared towards a Greater Albania.  It

16     wasn't a movement that was created while the Socialist Federal Republic

17     of Yugoslavia was in existence.  It was formed much earlier than that.

18             I don't want to go into the history of the Serb people and all

19     the suffering from Albanian terrorism, but it was all -- the Turkish

20     empire, under the Turkish empire for 500 years, Hitler's state,

21     Mussolini's state.  During the communist state, it was always the Serbs

22     that suffered, and now we have the domination of the United States of

23     America.  So it's we Serbs who fall casualty and suffer every time, and

24     of course we had to seek a way to resist this or, rather, to return part

25     of the state functions of Serbia and of Yugoslavia to -- to bring it back

Page 12827

 1     to the area of Kosovo and Metohija.

 2             When in 1981 the Presidency of Yugoslavia decided to bring in the

 3     police from all the Yugoslav republics to Kosovo, we Serbs weren't

 4     opposed to that because we didn't see that we were violating any

 5     sovereign rights because we were in favour of Yugoslavia and the Yugoslav

 6     Federation.  And now this movement for a united Serbia, it was a truly

 7     Yugoslav movement, and I joined Mr. Seselj as the president of the

 8     Serbian Chetnik Movement, because the Serbian Chetnik Movement, in its

 9     party programme, had the -- had to preserve Yugoslavia, to preserve the

10     parliamentary system, multiparty parliamentary system, democracy and

11     capitalism, on the foundations of the programme of Draza Mihajlovic, the

12     Chetnik commander from World War II.

13             And as far as Draza Mihajlovic is concerned, much has been said

14     about him, things that are not true.  He was a very well-educated

15     officer.  He graduated from the academy, military academy, with

16     Charles de Gaulle.  He graduated from the military academy in Paris, and

17     his programme was almost identical to the resistance movement of

18     Charles de Gaulle.  And as I say, Draza was a democratic.  However, the

19     unfortunate thing was that we had two movements in World War II.

20             And the other unfortunate thing was that in our Yugoslav

21     Federation, there was always foreign interference in a destructive way,

22     so the centres of those powers were in Germany and in the Vatican, that's

23     where they were to be had.  And I think that Dr. Seselj is the person who

24     studied all this in depth and comprehensively.

25             So it was from those positions that I joined the Serbian Chetnik

Page 12828

 1     Movement, whose president was Dr. Vojislav Seselj.

 2             JUDGE ANTONETTI: [Interpretation] Very well.  You gave us the

 3     reason why you joined this movement led by Mr. Seselj.  Now, from what

 4     you just told us, I would like to highlight two things.

 5             First, the situation in Kosovo-Metohija.  Obviously, for a Serb,

 6     it's a real problem.  According to the figures you just gave us, you felt

 7     that the number of Serbs in this area was decreasing, and this was a

 8     critical problem, nationally.

 9             The second problem you seem to highlight and which motivated your

10     joining the Chetnik Movement is that according to you, there were some

11     intervention from foreigners.  You mentioned two more -- you mentioned

12     two foreign influences, Germany and the Vatican.  And then you tell us

13     that all this was mentioned in Mr. Seselj's books.  Then you joined the

14     Chetnik Movement.

15             Can you tell us what this movement represented at the time within

16     the Serb community?  What did it represent, in terms of man count, and

17     what was its political influence, what was its weight?  What was the

18     importance of the Serbian Chetnik Movement at the time, when we know that

19     we also had Milosevic and the Socialist Party, his Socialist Party?  Tell

20     us about the importance of the Chetnik Movement in the political scene at

21     the time.

22        A.   Well, that movement meant a great deal in the moral sense.  It

23     awakened feelings of Serb solidarity.  It awakened people to the truth.

24     It showed us that we had to look at the situation realistically.  It

25     pointed out the dangers that threatened the joint state and showed the

Page 12829

 1     dangers that threatened the Serb people.

 2             It wasn't the goal of the Chetnik Movement to create a clash with

 3     Milosevic, but we were convinced that Milosevic, too, was in favour of

 4     preserving Yugoslavia, but at the same time we knew that Milosevic wanted

 5     to stay in power and to transform his power in the extent and manner to

 6     which -- which would ensure his positions in future.  So we did not want

 7     to have any conflicts or clashes, we did not want to break up Yugoslavia;

 8     quite the contrary.  It was our aim to preserve Yugoslavia, but we wanted

 9     to awaken the nation's consciousness and to ensure that the Serb people

10     looked at the situation realistically, and also to awaken their readiness

11     for the defence of Yugoslavia and the Serb people.

12             Now, let me tell you this:  The traditions of the Chetnik

13     Movement are, in fact, the traditions of the Serb people, and those

14     traditions emerge from the times of Kosovo, and loyalty to the Chetnik

15     Movement means that you are ready to lay down your -- to give up -- lay

16     down your lives for Serbia and Serb rights, and we had to be ready to

17     defend our religion too, because it was under threat with the advent of

18     the Turks, and today, too.

19             For example, in Montenegro, there's a new religion being imposed

20     upon us, and there's no realistic basis for that, either moral, or

21     religious, or doctrinaire, or any other for some new religion.  So that

22     were our aim, those were our objectives.  And the longstanding tradition

23     of the Chetnik Movement was to fight like a knight, honourably, and when

24     read all the Serb poems and look back to Serb poetry, you can see how the

25     Serbs envisaged warriors fighting for freedom.  And also this includes

Page 12830

 1     nurturing humane qualities and noble qualities in going into battle; that

 2     is to say that you must kill the frail, you must not kill civilians, you

 3     must not kill people you have captured.  The struggle against people who

 4     are out to kill you and kill your people and nation, and people who are

 5     out to kill and abuse people in general, that was who we were fighting

 6     against.

 7             JUDGE ANTONETTI: [Interpretation] Witness, it so happens that we

 8     had a number of witnesses in this Tribunal, not intellectuals -- I'm not

 9     talking about intellectuals, but people who had an average level of

10     education, and they did come and tell us and explain why they joined the

11     Chetnik Movement or the Serbian Radical Party.  And these people, who did

12     not have the excellent education that you had or the high-profile

13     positions that you had, told us that they joined this movement for

14     reasons that had to do with monarchy, because they wanted the king to

15     come back, they wanted monarchy to be re-installed.  We heard this a

16     number of times.

17             So what do you -- could you tell us what you think of this

18     monarchist trend within the Chetnik Movement, because we have a number of

19     witnesses who told us that that was the reason they joined.  And to tell

20     you the truth, we almost feel that they haven't really understood what

21     was the final objective sought by the party, because they just wanted the

22     king to come back.  They wanted to have a king on a throne in Yugoslavia.

23     So what do you think of this?

24        A.   Well, this is what I think; that the king was more a symbol of

25     changing the social system, that is to say, leaving behind communism and

Page 12831

 1     introducing a multiparty democracy and everything else that a new society

 2     would bring with it.  But let me tell you, Aleksandar Karadjordjevic,

 3     when he arrived in Serbia, the heir to the throne, he lost all belief

 4     that the monarchy was the real solution.  Well, he didn't learn his

 5     mother tongue, for instance.  It's not nice to say bad things about one's

 6     king, but he doesn't appear to be too intelligent, he doesn't seem to

 7     have the kind of conduct that European kings have.  He even appeared

 8     funny in certain situations and did not instill respect and did not show

 9     that he could contribute to his nation and his state in any way, so that

10     initial desire that we had to have a king, to have a king who would help

11     us in transforming society, and contribute to saving democracy, well,

12     that bubble burst; and the first person to understand and realised that

13     was Mr. Seselj, and he also had an opportunity of getting to know the

14     heir to the throne more closely.

15             JUDGE ANTONETTI: [Interpretation] It seems Mr. Seselj was

16     inspired by a person called Nikola Pasic.  Can you tell us who this

17     person was?

18        A.   Ah, Nikola Pasic.  Nikola Pasic was the greatest Serbian

19     politician of the 20th century.  That's who he was, he was a consistent

20     fighter, fought for the interests of his country, his nation, but always

21     in favour of democracy.  He was a fervent royalist.  He respected king

22     and country, but he had a lot of problems with everyone, with King Milan

23     and with King Aleksandar Obrenovic, and with that other one,

24     Karadjordjevic -- the Karadjordjevics, both Petar and Aleksandar, and he

25     died after having been to an audience with King Aleksandar, at which

Page 12832

 1     Aleksandar I, Karadjordjevic, was rude to Nikola Pasic and said -- had

 2     some criticisms of his son.

 3             But, anyway, Nikola Pasic has left an indelible trace on the

 4     country and the Serb people, and especially his beliefs in democracy.  He

 5     had a fervent belief in democracy, and Nikola Pasic is the most deserving

 6     politician, most deserving for all the things that the Serb people

 7     achieved in the Balkan wars, in World War I, when we made our

 8     contribution beyond and above the size of our country and the strength of

 9     our country.  And then the Western countries and all the freedom-loving

10     countries acknowledged that and respected him and the country, and our

11     alliance with the French people, for example, and the French state.

12             But unfortunately in this latest war, things have made an

13     about-turn, unfortunately, because the destructive forces in Western

14     Europe and later on in the United States of America did something quite

15     different.

16             JUDGE ANTONETTI: [Interpretation] If I understood you correctly,

17     Nikola Pasic was a politician who was inspiring the idea of democracy.

18     He was a major democrat, a leading democrat, if we had to sum up his

19     personality and his contribution to Mr. Seselj's ideas.

20        A.   Yes, that would be true.  Nikola Pasic made the greatest

21     contribution to further the democratic traditions in Serbia, of course,

22     but also for the defence of state and national sovereignty.  He wielded

23     the greatest influence on politics.  And after the ultimatum that

24     Austria-Hungary made to Serbia, and that ultimatum had the aim of -- it

25     was an ultimatum that Serbia could not accept in July 1914.  He accepted

Page 12833

 1     all the conditions laid down except for one, and that was that

 2     Austro-Hungarian police could enter Serbia to carry out an investigation,

 3     and he demonstrated how the sovereignty of the country should be defended

 4     by doing that.  And now tell me what kind of sovereignty we have in

 5     Serbia today, when the US intelligence service and Javier Solana decide

 6     who's going to be our minister, who's going to lead our government, what

 7     kind of monetary we're going to have, open telephone lines, and so on and

 8     so forth?  So we believed the West --

 9             JUDGE ANTONETTI: [Interpretation]  Witness, you are now dealing

10     with the present politician situation, but we're interested in the past.

11     We're interested in the years 1990-1991, and Pasic.  We're not going to

12     discuss Mr. Solana at the moment.

13             So let's come back to 1991.  You told us about the Serbian

14     Radical Party.  You joined it, and if I'm not mistaken, I believe that

15     you were appointed to a senior post within the leading -- within the

16     leaders of the Serbian Radical Party.  Is that true?

17        A.   Well, at the founding Assembly of the Serb Radical Party, I was

18     elected member of the Main Board.  However, I actively joined the Serb

19     Radical Party activities only in September because I was wrapping up my

20     activities in the People's Movement for a United Serbia.  That movement

21     was still functioning up until mid-1991.  That is when I was given the

22     office of head of the Regional Board for Banat.  That is what the

23     internal setup of the Serb Radical Party was like then, according to

24     regions, with a central organ, of course.

25             JUDGE ANTONETTI: [Interpretation] This Banat area, how far is it

Page 12834

 1     from Belgrade?

 2        A.   No, Banat is right below Belgrade.  Pancevo is the town that I

 3     live in, and it's 12 kilometres away from Belgrade.  Speaking from a

 4     strictly geographic point of view, the area of the city of Belgrade even

 5     includes a small part of Banat.

 6             JUDGE ANTONETTI: [Interpretation] So it's very close to Belgrade.

 7             You mentioned Pancevo, and I understood that you organised the

 8     first visit made by Mr. Seselj to that town.

 9        A.   Mr. Seselj had this public position as head of the Serb Radical

10     Movement, so his voice was heard in the public.  I did things within the

11     scope of the time frame allowed by Mr. Seselj's schedule.

12             JUDGE ANTONETTI: [Interpretation] Very well.  So you were

13     present, as I understand it, when Mr. Seselj made a speech in Pancevo.

14     Is that correct?

15             THE INTERPRETER:  Interpreters note, we could not hear the

16     answer.

17             JUDGE ANTONETTI: [Interpretation] Could you tell me how

18     Mr. Seselj, as a politician, made that speech?  How was it organised?

19     Did he have prepared speeches or did he improvise as he was going along?

20     Did he manage to establish a close contact with those who attended a

21     political meeting?  Was he a real public speaker?  Could you, in a few

22     words, tell us how he was as an orator?

23        A.   One cannot say that Mr. Seselj improvises.  He has a great deal

24     of knowledge, and he plans his public appearances.  Mr. Seselj can be

25     inspired by a big gathering of people, but Mr. Seselj never steps out of

Page 12835

 1     the framework of his programme and his convictions.  He knows how to

 2     establish contact.  He knows how to work an audience, how to thrill an

 3     audience, especially consisting of members of our own people, but also

 4     the national minorities.  He does not speak about conflicts among people

 5     and nations.  He does not talk about discrimination.  He doesn't talk

 6     about persecutions, genocide.  He talks about resolving problems.  He

 7     indicates, in realistic terms, what the situation is like.  He does not

 8     talk like most politicians, only from the point of view of daily

 9     political interests.  Rather, he speaks from the point of view of the

10     actual situation as it is, the possible consequences, and he offers

11     solutions.

12             Therefore, Mr. Seselj does not really improvise.  Rather, there

13     is inspiration.  But Mr. Seselj has a very strong will, and he can

14     control himself and the expression of his thoughts.

15             JUDGE ANTONETTI: [Interpretation] Does this mean that when

16     Mr. Seselj makes a speech - and the reason why I'm asking you this is

17     that Mr. Seselj's speeches are very relevant in this case - so when he

18     makes a speech, does that mean that the speech has already been worked

19     up, I mean, prepared by him or his associates; therefore, when he appears

20     publicly, everything he's going to say has been thought through,

21     prepared, and that there is no room for this last-minute improvisation?

22        A.   Well, you know what -- oh, no, no.  What I was trying to say was

23     that Mr. Seselj never goes outside the framework of his principles and

24     convictions, the positions that he holds and the conclusions that he came

25     to through his process of thought.

Page 12836

 1             As for preparations, Seselj did not have any associates who could

 2     help him in preparing his speeches.  Seselj is by far the smartest one,

 3     the one with the greatest body of knowledge and the person with a vision

 4     in the Serb Radical Party at the time when I was there.

 5             JUDGE ANTONETTI: [Interpretation] As I understand it, when

 6     Mr. Seselj would go to hold speeches, would go to rallies, he would get

 7     there, forgive me the expression, with his hands in his pockets, so

 8     rested, but he would launch into a speech that would mirror very

 9     faithfully his thoughts?

10        A.   Exactly, exactly, his convictions and the programme of the Serb

11     Radical Party.  Of course, for the most part, he was the one who wrote

12     the programme.  It is the fruit of his ideas and his thinking.

13             JUDGE ANTONETTI: [Interpretation] Your answer as to the

14     manifesto, the programme of the Serbian Radical Party, makes it possible

15     for me to now delve into the inner workings of the SRS.

16             From what I understood, between the time when you joined and the

17     time when you left the party on the 7th of October, 1994, you were a

18     vice-president in the party, in charge of organisational matters and

19     personnel.  The party also had structures at the level of republics.  I

20     mean to say that the SRS, from what I gather from the system, had people

21     in other republics.  Is that how I am to understand the way the SRS

22     worked?

23        A.   Exactly.  The Serb Radical Party existed for the Republic of the

24     Serb Krajina and for Republika Srpska and for Montenegro.  These parties

25     acted in a united manner.  The presidents of these parties and the

Page 12837

 1     leaderships of these parties discussed things and reached agreement with

 2     Mr. Seselj and the rest of us.  We had a joint programme, but each and

 3     every one of these parties was registered in their respective states on

 4     the basis of the laws of those states.  Coordination was serious, but

 5     they did act independently in the parliaments of these three other Serb

 6     states.

 7             JUDGE ANTONETTI: [Interpretation] Could you tell me who was the

 8     one in charge of the SRS for the Republika Srpska and who was the one

 9     responsible for the party in the Krajina?  Who were the two individuals

10     heading the SRS in those two areas?

11        A.   I remember.  In Republika Srpska, there was Poplasen, Professor

12     Poplasen.  I've forgotten his name.  And in the Republic of Serb Krajina,

13     Rade Leskovac, a well-known journalist.  And in Montenegro, Acim Visnjic

14     [phoen].  Now, was there anyone else?  Radovan --

15             JUDGE ANTONETTI: [Interpretation] So as part of the way the SRS

16     would work, would Mr. Seselj have political working sessions with his

17     close vice-presidents or with the secretary-general?  We had the pleasure

18     of meeting and seeing him a while ago.  Would he have meetings with other

19     people in charge of the SRS in other republics?  Were there high-level

20     meetings with all the players?

21        A.   There were meetings, and Mr. Seselj consulted with us, the

22     vice-presidents.  He maintained the functioning of all the organs of the

23     party in accordance with the statute.  However, there is one thing that

24     is characteristic of the Serb Radical Party; namely, that Mr. Seselj

25     dominated the party, but not on the basis of some kind of threats or some

Page 12838

 1     other undemocratic measures.  Rather, it was on the basis of his

 2     knowledge, on the basis of how well-spoken he was.  He works the most, by

 3     far.  He can make great efforts.  He's a visionary, too.  We all

 4     respected him.

 5             Some people do not understand Mr. Seselj because he tends to

 6     speak in a loud voice.  He sometimes raises his voice, too.  However, a

 7     man who works that hard and is so involved in the creative process

 8     sometimes does get tired, too.

 9             JUDGE ANTONETTI: [Interpretation] You just confirmed that there

10     were meetings which you necessarily attended.  Were there minutes of

11     these meetings or were minutes never taken?

12        A.   Well, there were some working meetings before a session,

13     especially when a big rally was supposed to be attended or, say, a

14     meeting at a municipal committee, or some other assignment, then no

15     minutes were needed.  We discussed who would go where, who would discuss

16     the economy, who would discuss foreign policy, social policy, and so on

17     and so forth.  However, at the Main Board, at the meetings of organs

18     envisioned by the statute, minutes were invariably kept.

19             JUDGE ANTONETTI: [Interpretation] So minutes were always taken,

20     and if these minutes exist, they should be in the archives of the SRS, I

21     guess.

22        A.   The Main Board, the Executive Board, that's for sure, the Central

23     Fatherland, although I really did not concern myself with minutes.

24             JUDGE ANTONETTI: [Interpretation] Fine.  We'll get back to that

25     later on.  But as to the issue of the volunteers of the SRS, I guess that

Page 12839

 1     when the decision was made at SRS level to dispatch volunteers to various

 2     fronts, was there a meeting about it?  If so, were you there?

 3        A.   Well, when I got actively involved in the work of the Serb

 4     Radical Party, that is to say, in the month of September, what I found

 5     there was intensive activity in terms of the volunteers going to join JNA

 6     units and Territorial Defence units or, rather, organisation for war.

 7             Of course, there were discussions at sessions concerning the

 8     participation of volunteers.  However -- well, you know what, we did not

 9     have any kind of war staff; in name, yes, but we didn't have a war staff

10     that had some kind of equipment or that was engaged in some kind of

11     command, or that was in charge of some kind of war affairs, no.

12             I organised the departure of volunteers from the area of Banat,

13     and we did that in the following way:  They'd call us from Belgrade, from

14     the War Staff, telling us that the JNA and then later on the army of

15     Republika Srpska or the army of Krajina needed volunteers.  Then we would

16     call these volunteers of ours and we'd send them to Belgrade.  From

17     there, they went to Bubanj Potok or wherever.  What was a specific

18     characteristic in our sending of volunteers was that we would always take

19     our volunteers to the church to take Holy Communion, which was a Serb

20     tradition from the time of the battle of Kosovo.  Before the battle

21     started, the soldiers took Holy Communion.  And then the priests spoke

22     about the need to defend the Serb people, but that they should wage war

23     in a chivalrous manner and in a noble manner.

24             I was present once or twice when a larger number of volunteers

25     were leaving.  That is the same thing that Mr. Seselj said, too.  He

Page 12840

 1     never said, "We are going to go out there to kill the Croats, be

 2     merciless," which would be in the tradition of some of the great European

 3     nations.  On the contrary, he always said, "No, you have to defend the

 4     Serb people, the Serb people have to go on living in these areas, but

 5     fight in a chivalrous manner like your forefathers from the days of

 6     Kosovo onwards, be noble, do not commit any evil."

 7             JUDGE ANTONETTI: [Interpretation] Sir, a question comes straight

 8     to the mind of an outside observer or a judge.  Why, in the defence of

 9     the former Yugoslavia, as it then existed, was defence not to be carried

10     out by the JNA, by the people's army?  Why not resort to, quote/unquote

11     "volunteers" who would, like knights of the Middle Ages go, once they had

12     taken Holy Communion, why would they not go to combat?  Why not choose

13     such individuals, as the very essence of any country, is that armed

14     forces are under the authority of a central state?  Why did you

15     encapsulate, encompass, that notion of volunteers?

16             We've already heard a lot about it, but since you're here before

17     us, I have to put the question as well.

18        A.   Well, you see, Mr. President, Yugoslavia did not collapse within

19     three days.  It was a process, after all.  In this process, there were

20     many forces at play in a destructive fashion.  All of Slovenia was on the

21     move.  They wanted to secede unilaterally without appropriate procedure.

22     They even killed our soldiers.  They did not allow recruits to go to the

23     Yugoslav People's Army.

24             The same thing happened with Croatia.  Even in Serbia, we had

25     destructive activity.  We had a Vuk Draskovic, who called upon recruits

Page 12841

 1     from Central Serbia, Kragujevac, Valjevo, et cetera, not to join the JNA.

 2             Now, these calls, had they been peaceful, would have been

 3     reasonable ones.  However, out there, they were killing Serb people.

 4     There were still these new paramilitary formations.  There was the

 5     Yugoslavia, though, so the Serb people were in jeopardy.  Other people

 6     would be in jeopardy, too.  So the JNA needed additional assistance from

 7     those who wanted to fight.

 8             It is on that basis that volunteers from Serbia, believing in the

 9     Serb Radical Party, believing in Dr. Seselj, went there through the Serb

10     Radical Party.  They could have gone directly through the JNA, too.

11     However, they had this special belief in Dr. Seselj, because he indicated

12     what the times were like and everything that was happening at that point

13     in time.

14             JUDGE ANTONETTI: [Interpretation] You, yourself, said that you

15     personally organised the departure of Serbian volunteers from the Banat

16     area, so you know this area very well.  As far as you know, the

17     volunteers who would leave and had been armed by the JNA, because I

18     suppose that you did not provide them with weapons, is that right; so

19     under whose authority or under whose command were they put?

20        A.   Under the command of the JNA.  The Radical Party did not have any

21     formations, any commanders, any commanding officers, any military

22     structure of units, and it didn't have people who knew how to do that

23     kind of thing, nor did it take part in war operations through its people.

24     We only looked at this civilian aspect of the departure of volunteers

25     going into the war.

Page 12842

 1             Later on, when volunteers would return, we took care of them,

 2     especially those who were wounded or those who got killed.  We collected

 3     aid, and quite a few managers of different companies helped us.  It was

 4     easier for me in Pancevo because I was a colleague of the general

 5     managers of big companies, and they really tried to do what they could

 6     for us.  They even gave apartments to the families of fallen soldiers.

 7     It was the state that resolved other matters, it was the army that

 8     resolved other matters; but, anyway, we worked in helping the volunteers.

 9             JUDGE ANTONETTI: [Interpretation] I could show you documents

10     regarding the logistics and the assistance you provided to volunteers,

11     but there's no need for that.  The documents have been admitted already.

12     I'd rather go to the crux of the matter.

13             As I understand it, the volunteers who would leave, who were

14     under the command of the Territorial Defence or the JNA, nevertheless

15     kept some kind of connection with the Serb Radical Party regarding the

16     situation of the volunteers, be it only if they were wounded, or killed,

17     or had trouble getting money or being paid; can you confirm that?  Can

18     you confirm that there was some kind of link or a follow-up of the

19     volunteers at the level of the Serbian Radical Party?

20        A.   Well, we only followed this up from the point of view of this

21     social welfare, this aid, trying to help these people.  They were on

22     these lists of volunteers that were made even before the war broke out,

23     and we'd call them to come.  Many of them were members of the Serb

24     Radical Party.  Some of them were even members of the leadership of the

25     party.  But you know what?  All of this was done in a situation and an

Page 12843

 1     atmosphere conducive to helping one's people, defending lives and

 2     property of our own people in the war-engulfed areas.

 3             JUDGE ANTONETTI: [Interpretation] Could you describe how the

 4     War Staff worked that was led by Petkovic?  Could you tell us who were

 5     the members of the War Staff?

 6        A.   Well, in addition to Mr. Petkovic, I remember Rankic, but they --

 7     they did not seem like any kind of warriors to me, or officers, or

 8     something like that.  They looked like people who were being engaged, who

 9     were working very hard in assisting volunteers to leave and helping their

10     families to the best of one's ability.

11             Well, it was like a service.  There was this work in terms of

12     organising departures, and then meeting volunteers when they'd come back,

13     but they didn't seem like commanders or officers at all or as any people

14     who were well-versed in warfare.  No, they weren't.  And we in the Serb

15     Radical Party, especially Vojislav Seselj, we did not have any such

16     aspirations, anyway.

17             JUDGE ANTONETTI: [Interpretation] Let me take a very specific

18     example, that of Vukovar.

19             We know, because we've heard witnesses, we saw evidence, that

20     volunteers of the Serbian Radical Party were in a unit in Vukovar.  When

21     SRS volunteers would be in a combat area, as in Vukovar, you were in

22     Belgrade; did you know what was happening in realtime on the ground about

23     combat operations or decisions that were made, or were you not aware of

24     it?  Did you only know that some individuals had been wounded or killed

25     and that there had to be -- the bodies had to be brought back to Belgrade

Page 12844

 1     or that they had to be put into hospital in Belgrade?  Could you tell us

 2     what you knew, based, for instance, on the example of Vukovar?

 3        A.   Mr. President, well, I was one of the closest associates of

 4     Dr. Vojislav Seselj.  I really don't know anything about these

 5     developments in the theatre of war.  I only know about the things that

 6     you referred to during the second part of your question; that some people

 7     got killed, some people returned.  That's the only thing I knew.

 8             So we in the Serb Radical Party, and I'm sure that that goes for

 9     Dr. Vojislav Seselj too, we did not have any insight into these

10     operations; and this didn't really matter to us.  What matters to us was

11     that there was a force at the front-line, and that is the JNA and the

12     Territorial Defence, defending our people, and we were there to help.

13             Dr. Vojislav Seselj is consistent in respecting the setup of the

14     state.  With our volunteers or with any kind of activity of ours, he

15     didn't want us to bring into question at all any of the legal and

16     legitimate functions of the state itself, or any of the levers of state,

17     especially such an important organisation like the JNA.  That wouldn't

18     have been rational, it wouldn't have been useful, but it wouldn't have

19     been in accordance with our beliefs, or our programme, or our efforts to

20     make sure that there is a proper state based on the rule of law, well set

21     up, well established.

22             JUDGE ANTONETTI: [Interpretation] Sir, one last question before

23     the break.

24             We have heard many witnesses, we have seen a lot of evidence,

25     that seems to boil down to this:  Among the volunteers, there were some

Page 12845

 1     offenders who had been in prison, served sentences, and who overnight

 2     were released from jail in unknown circumstances and found themselves

 3     under the label of volunteers on battlefields, and of course they

 4     committed crimes.

 5             As far as you know, I'd like to know whether the SRS volunteers

 6     had been released from jail as part of a pardon or amnesty; and did you

 7     keep getting volunteers from a hard core of criminal offenders who were

 8     serving sentences and had been released in order to increase the number

 9     of men from the JNA or the TO?  Are you aware of that, because it was

10     told us, and we have heard testimony describing the behaviour of such

11     individuals.  Did you know that, did you not know that?

12        A.   Mr. President, I participated in the organisation of the

13     volunteers.  What we checked was something that wasn't very difficult to

14     check.  It was some very -- very basic things; first of all, whether this

15     volunteer had done his military service or had a criminal record, whether

16     it was a person who had a regular sort of life.  And from my area,

17     really, there was no one like that.  I mean, I'm sure that Mr. Seselj

18     would not have allowed such people to go, because otherwise who would

19     Dr. Vojislav Seselj be?  Who would I be in the Serb Radical Party?  We

20     are following the oath of Kosovo, the traditions of the Chetnik Movement.

21     And then I send criminals to loot out there or to slaughter Croats and

22     Muslims, this is a pure fabrication.  I'm deeply convinced of that.  It

23     is totally unacceptable.  It does not belong to our core thinking.

24             Please, we are looking at the destiny of our people, exposed to

25     genocide.  We are doing our best to help them.  Now, would we do that

Page 12846

 1     with criminals?  My brain cannot accept that, let alone my very political

 2     activity.

 3             JUDGE ANTONETTI: [Interpretation] Very well.  You are challenging

 4     any statement of the kind, but you're adding one additional detail.

 5     You're saying that these volunteers were screened, if I could say so,

 6     because first they were checked to see whether they had done their

 7     military service, whether they had a regular sort of life, and whether

 8     they had ever been sanctioned.  So in order to be volunteers, they had to

 9     be screened; is that it?

10        A.   Well, you know what, we were not a recruitment centre.  It's not

11     that we managed people in terms of height or whatever.  We just looked at

12     these basic elements in order to see who it was that was going out there

13     to defend the people.  What else, what else?  We cannot send people to

14     fight for the Serb people if, say, some of these persons are referred to

15     as thieves.

16             JUDGE ANTONETTI: [Interpretation] Very well.  It's time for our

17     20-minute break.

18             I would like the Registrar to tell me how much time I've already

19     spent, and we will meet again -- we'll resume in 20 minutes.  Thank you.

20                           --- Recess taken at 10.04 a.m.

21                           --- On resuming at 10.27 a.m.

22             JUDGE ANTONETTI: [Interpretation] Very well.  Court is resumed.

23             Now, in direct line with my previous question, I would like to

24     return to Vukovar, because I am looking at elements that are in the

25     indictment.  We know that Vukovar fell on November 18th.  We know that

Page 12847

 1     200 people were slaughtered in the -- at Ovcara on November 20, 1991.

 2             Mr. Seselj's case is the following:  He says that the SRS

 3     volunteers left Vukovar before November 20th, and he told us, but so far

 4     he hasn't demonstrated this, he told us that he had testimonies from the

 5     bus drivers who drove the volunteers back before November 20th.  So let's

 6     talk about the repatriation of volunteers after they left the

 7     battleground, repatriation by bus.

 8             I would like to know whether this was part of your mandate.  Were

 9     you in charge of organising the repatriation of volunteers by bus?

10             Mr. Seselj.

11             THE ACCUSED: [Interpretation] Perhaps the problem is in the

12     interpretation, but the interpretation I got was that there was no proof

13     about the return of the volunteers before the 20th of November.  And let

14     me remind you that I showed you and the Prosecutor eight statements from

15     drivers who drove the volunteers.

16             JUDGE ANTONETTI: [Interpretation] Just a minute.  I clearly said

17     the following:  Mr. Seselj told us that we had eight statements from bus

18     drivers, stating that the volunteers had returned before November 20th.

19     This is what Mr. Seselj said.  Mr. Seselj said he had statements in this

20     respect.

21             Let me go back to my previous question.  If volunteers are

22     repatriated on buses, I would like to know whether you were involved in

23     this operation, at least on the logistics side.

24        A.   Mr. President, I personally was not involved, but I do remember a

25     conversation with one of the volunteers from Pancevo.  I remember his

Page 12848

 1     surname.  It was Stojanovic, and he said that there was fierce fighting

 2     going on there, it was so fierce that they couldn't wait to go home, and

 3     that they went home immediately after the fall of Vukovar.

 4             JUDGE ANTONETTI: [Interpretation] If you were not involved in

 5     this, it must have been the War Staff who looked into this repatriation

 6     of these volunteers?

 7        A.   Correct.

 8             JUDGE ANTONETTI: [Interpretation] Now, regarding volunteers, I

 9     would like to know the following:  When a volunteer, sent on the

10     battlefield, committed an offence, whatever the offence, was the Serbian

11     Radical Party informed of this?  And if so, what was the sanction

12     involved?

13        A.   As far as I know, Dr. Vojislav Seselj was very strict when it

14     came to infractions and violations of discipline, and I remember that

15     whenever he sent volunteers off and whenever there was any discussion

16     about the activities of the volunteers, in addition to the principles of

17     chivalrous behaviour and noble behaviour, he would always stress the

18     respect that the Serb volunteers had to demonstrate, and he always

19     insisted upon discipline.

20             JUDGE ANTONETTI: [Interpretation] I will not put any questions to

21     you regarding Mr. Seselj's speech on May 6th, 1992, at Hrtkovci, because

22     you said in your statement that this was the St. Sava and that day you

23     stayed home.  However, I would like to talk about the exchange of flats.

24             We heard a good number of witnesses here who told us that the

25     Serbs had been expelled from Croatia.  Allegedly, there would have been

Page 12849

 1     200.000 of them.  Some went to Vojvodina, and the Croats and Serbs seem

 2     to have exchanged flats.  Now, as far as the leadership of the SRS is

 3     concerned, were you aware of this exchange of flats?

 4        A.   We did know about it, and Dr. Vojislav Seselj insisted on having

 5     this exchange of flats and property and that nobody should be at a

 6     disadvantage and disadvantaged, as far as that was possible.

 7             JUDGE ANTONETTI: [Interpretation] You were aware of it.  Very

 8     well.  Was this a deliberate desire on --

 9        A.   [Previous translation continues]... undertaken by the Serbian --

10             JUDGE ANTONETTI: [Interpretation] You were aware of it.  But did

11     the SRS and Mr. Seselj deliberately decide to ensure that this exchange

12     of flats would actually take -- exist?

13        A.   Correct.  Dr. Seselj insisted on that.  Seselj always looks a

14     long way ahead, and his goal is that the Croats, those who at one time

15     converted to Catholicism and became Croats one day, should understand

16     this and accept this and be part of a joint nation again.  Dr. Seselj was

17     not in favour of any kind of violence or any kind of revenge, especially

18     not persecution or genocide.

19             JUDGE ANTONETTI: [Interpretation] I am now going to move into

20     more sensitive issues.  Of course, all issues are sensitive, but some

21     more so than others, and I'm about to delve into very crucial matters.

22             You made a written statement after you were interviewed for four

23     days in 2003.  Obviously, at the time -- well, not obviously.  I would

24     like to know whether you knew at the time that this statement would be

25     used in the proceedings against Mr. Seselj.

Page 12850

 1        A.   Well, I took it seriously, the statement with the Hague

 2     investigators, but from the beginning of my talks with the investigators,

 3     right up to my conversation with Ms. Christine Dahl, I always stressed

 4     that I did not wish to be a Prosecution witness, or a witness at all, for

 5     that matter, because I did not take part in the war, I was not on the

 6     battle front, I know of no crimes, and I know of no -- well --

 7             JUDGE ANTONETTI: [Interpretation] Sir, when you signed this

 8     statement, you said that you wanted to contribute to the manifestation of

 9     truth, but you did not deliberately say that you wanted to be a Defence

10     witness.  I have the statement here in my hands, and there is no mention

11     of this.

12        A.   My position was this:  Not to go and testify, not to take part in

13     this trial.  But I decided to be a Defence witness after having talked to

14     Ms. Christine Dahl.  I talked to her and the investigator, Paolo Stocchi.

15     I held that discussion last year on the 16th of November.  And I'll tell

16     you why.

17             JUDGE ANTONETTI: [Interpretation] You left the SRS in 1994.

18     Could you tell me why you left this party, and what was the difference of

19     opinion that forced you to leave the party?

20        A.   Two reasons.  The first is this:  The people who surrounded

21     Dr. Seselj, his closest associates, were people without any ideals and

22     visions, ideas, without the capability -- without capabilities, people

23     who had no successful work behind them, either on the political scene or

24     in science or anything else, but were overtly ambitious and narcissistic.

25     And they didn't like me, either.  They had some animosity towards me.

Page 12851

 1     I'm a different man altogether, of different experience and different

 2     structure.  So that was the main reason.  That they were people without

 3     any visions and ideas, well, I can provide ample evidence to show that.

 4             When they left Dr. Seselj, for example, they didn't do

 5     anything -- give anything back to the public.  They engage in politics

 6     with some other political programmes.  It includes some other people,

 7     people who just talk about the European Union, in fact just following the

 8     programme of some other political party.  Boris Tadic's, in fact, to be

 9     specific.  So those are the kind of people I didn't want to associate

10     with.

11             The second reason is Dr. Seselj, when the Serbian Radical Party

12     was under a total media blockade by the Socialist Party and

13     Slobodan Milosevic's regime, Dr. Seselj, in order to be heard publicly,

14     behaved as he did in the Assembly and caused incidents.  He asked me to

15     pour water over Radovan Bozovic.  I couldn't accept that.  He wanted to

16     cause these media effects, and I couldn't do this to Bozovic.  I know

17     him, I know that he gained riches, but not on the basis of what's work;

18     and now the papers are writing and saying that he's the head of the

19     Montenegrin mafia, which is the strongest mafia in Serbia, which is

20     destroying the Serb economy and Serb spiritual being, too.

21             So those are the two reasons.

22             JUDGE ANTONETTI: [Interpretation] Very well.  You gave us your

23     two reasons, and we can now move on to the next topic which I wanted to

24     address.

25             When you were interviewed by the investigators of the OTP, these

Page 12852

 1     investigators were asking questions about the financing and the funding

 2     of the SRS.  Could you tell us how the Serbian Radical Party operated, as

 3     far as funding is concerned and revenues?

 4        A.   What I know is this:  When the Serbian Chetnik Movement was

 5     founded, we were financed from the funds Seselj managed to -- through his

 6     activities in Western countries, in Australia, America, and in Canada,

 7     from those proceedings, as president of the Chetnik Movement and as a

 8     Serbian intellectual.  Later on, when the elections were held in 1992, I

 9     had my own sponsors for my own area, and from Branko Djukic, near

10     Banja Luka, who was in the oil business, we were given a whole truckload

11     of petrol, a 30-tonne truck.  So there were people like that who helped

12     us out with fuel and other things.  Otherwise, it wasn't my field of

13     expertise.  I didn't have any insight into the treasury, or funds, or

14     anything like that.

15             But in one of my books, it says that I said that the Serb Radical

16     Movement of Dr. Vojislav Seselj was given 10 million in cooperation with

17     Milosevic and so on and so forth.  Well, that's just an expression of my

18     impotence, my powerlessness and my response to certain assertions.  Once

19     I left the Serbian Radical Party and when the Serbian Radical Party and

20     Dr. Seselj too, he maligned me and they maligned me; and they said I was

21     an idiot and a traitor, and that I had sold my soul, and things like

22     that.  In addition to all that, they said that I had been given 5 million

23     German marks on Cyprus.  And then I responded with equal measure, and I

24     said that they had been given 10 million.  And that's the kind of thing

25     we do in Serbia in these political conflicts.  We ascribe to the opposite

Page 12853

 1     side certain things that are really not true.  It's not true that I got 5

 2     million marks.  Had I had that money, I would be a big businessman, but I

 3     live in Serbia and retired.  I live off my pension.

 4             JUDGE ANTONETTI: [Interpretation] On paragraph 83 of your

 5     statement, you told the interviewers that Stefanovic had told you that

 6     Milosevic had funded either Seselj or the Serbian Radical Party, had

 7     actually given this party or Mr. Seselj 1 million Deutsche mark for the

 8     support of an election.  Does this mean that Slobodan Milosevic was

 9     actually funding the Serbian Radical Party?  It seems that that's what

10     you hint at in paragraph 83, and you say that you heard this from

11     Stefanovic and this was actually in one of your books.

12        A.   I cannot substantiate that with anything, and it's even difficult

13     to believe.  It's difficult to believe in that, since Slobodan Milosevic

14     blocked the party, incarcerated Dr. Seselj.

15             Now, this piece of information in my book, what I wrote there,

16     well, it's just rumour, I was just rumour-mongering because of my

17     powerlessness, so I wanted to inflict some damage, malign them as

18     retaliation for what they had said about me in the Serbian Radical Party

19     once I had left the party.

20             JUDGE ANTONETTI: [Interpretation] You are saying that the

21     information revealed in your book should be, in fact -- it's just a

22     settlement -- it's just ascribed to a settlement and it's rumours,

23     actually, more than anything; is that it?

24        A.   Yes, that's the truth of it, that's the real truth of the matter.

25             JUDGE LATTANZI: [Interpretation] I apologise, but I would like to

Page 12854

 1     have -- I would like to know something.

 2             Are you saying that what you wrote in your books is not to be

 3     trusted?

 4        A.   It's not credible, that -- and I can't prove it, and I'm not

 5     proud of having written that, of having stooped in a period of my life to

 6     the level of the desire to get my own back.  I shouldn't have done that.

 7     Certainly, it's a bad episode in my life.

 8             JUDGE ANTONETTI: [Interpretation] I would like to shed some light

 9     on something you told the OTP, and let me sum it up.

10             The International Community had placed an embargo on oil imports,

11     and you said that the Serbian Radical Party had a company that made it

12     possible to bypass this embargo and to sell oil in former Yugoslavia, and

13     which helped the Serbian Radical Party obtain revenue at the time by

14     selling this oil.  You said that, but are you challenging this today or

15     do you maintain this?

16        A.   Well, that company was in existence for a very brief period of

17     time.  Dr. Seselj conditionally accepted the work of this company, but

18     when he saw that business dealings like that were not commensurate with

19     the party image, he gave up on it, and it was closed down.

20             Now, later on, through my sponsor, I managed to secure enough

21     fuel for the elections in 1992, but that sponsor imported fuel himself,

22     petrol himself.  He made a lot of money, and he's a very wealthy

23     businessman.  You can find him near Banja Luka, at a petrol pump there.

24     So had it not been this black marketeering through Bulgaria, especially

25     Serbia would have had no fuel, and it would have put a stop to the

Page 12855

 1     economy and life in general; so you had to find a way to get around the

 2     situation.

 3             JUDGE ANTONETTI: [Interpretation] You also involved one of

 4     Mr. Seselj's relatives, his former bodyguard, Petar Panic.  According to

 5     you, he was controlling the black market, notably when it came to

 6     currency exchange.  Is it true or false?

 7        A.   I don't know about that.  Mr. Paolo Stocchi talked about that

 8     during the interview.  I couldn't confirm it then, either.  Now, what he

 9     put on record, I don't know.  The records were kept for four days.  The

10     interview took place for four days.  We had an interpreter.  Mr. Paolo

11     Stocchi has a special way of asking questions.  He asks you a question

12     and then provides the answer; and then he says who he got the information

13     from and so forth.  Now, I gave my answer, and what he put into the

14     statement, into the record, I don't know.  That Petar Panic had worked

15     with foreign current, I can't confirm that, nor do I have any insight in

16     the work of Petar Panic at all.  He was a bodyguard to Mr. Seselj.

17             JUDGE ANTONETTI: [Interpretation] I have one final question on

18     this issue, and it has to do with Mrs. Seselj.

19             Paragraph 92 of your statement, you explain that Mr. Seselj would

20     have received about US $50 million to enter into the government in

21     coalition with the SPS, and then you add that Mrs. Seselj, Jadranka

22     Seselj, owned an import/export company and that since her husband was

23     vice-president of the government of Serbia, that made it possible for her

24     to obtain a competitive advantage for her company.  So do you still

25     maintain this or do you challenge it?

Page 12856

 1        A.   Mr. President, I had absolutely no means of knowing about any

 2     dealings -- business dealings that Mrs. Seselj might have had at the

 3     time, or about Mr. Seselj receiving any money from the Socialist Party.

 4     At that time, I was not involved in politics.  I was engaged in some

 5     other affairs.  I was leading quite a different life.

 6             Now, Paolo Stocchi talked about that, and I assume he recorded

 7     it, too, because he wanted to, because let me repeat, that's his style of

 8     interviewing.  He asked the questions, provides the answers.  Now, what

 9     goes down in the record, I really can't know.

10             JUDGE ANTONETTI: [Interpretation] Yes, but you signed what is

11     written in paragraph 92.  We have your initials on the minutes -- on the

12     statement.

13        A.   I signed on the fourth day, without reading through the minutes,

14     the statement.  And when Mr. Paolo Stocchi told me that he'd be

15     interviewing me some more if I refused to sign, I did refuse to sign.

16             However, he sort of prevailed upon me and forced me to sign in

17     that way.  And his way of conducting an interview, well, does not accord

18     with the rules of procedure or is not according to legal provisions.  He

19     has a cowboy way of interrogating, interviewing.

20             JUDGE ANTONETTI: [Interpretation] Apparently after you left the

21     SRS, you were accused of being a traitor, and that is what is stated.

22     And then we get the impression that at one point in time, people around

23     Mr. Seselj tried to kidnap either your wife or your daughter, which is

24     just something you said.  Now, could you tell us exactly what happened?

25        A.   No, no, that's not what happened.  The truth of the matter is

Page 12857

 1     this:  Near my flat at the time, several men stopped my wife.  They

 2     wanted to get her into their car.  However, afterwards we learnt and

 3     established -- that is to say, my associate called people up from the

 4     Serbian Radical Party to see what was going on, and they said it had

 5     nothing to do with the Serbian Radical Party or with Dr. Seselj.  And I

 6     know full well that Dr. Seselj uses [as interpreted] methods like that,

 7     nor does he need to.  What would he achieve, after all?  He would achieve

 8     a negative effect.  It would have a negative effect, as far as he was

 9     concerned and as far as his party was concerned.  So this was done by

10     people arbitrarily who said that they had links to the Serbian Radical

11     Party.  But we checked this out and found that they had nothing to do

12     with the leadership of the Serbian Radical Party at all, and especially

13     not with Dr. Seselj.

14             JUDGE ANTONETTI: [Interpretation] Sir, at paragraph 129 of your

15     statement made with the investigators of the OTP -- you know, nothing

16     escapes me, and I scrutinised this document for hours, I poured over it

17     for hours.  Well, at paragraph 129, you said the following:  At the

18     beginning of 1995, members of the SRS, led by Zoran Drazilovic, came in

19     front of your apartment in Belgrade, in a number of cars, and surrounded

20     your wife on the street and tried to drag her into the car.  One of your

21     neighbours intervened and defended your wife.  And then you explain this

22     action was done against you because Seselj wanted to punish you for

23     having left the party.  So here you actually named Zoran Drazilovic and

24     incriminated him, so what can you say today regarding this affair?

25        A.   I didn't see Zoran Drazilovic.  My wife assumed that it was him,

Page 12858

 1     but we later learnt that it wasn't Zoran Drazilovic or anybody else from

 2     the leadership of the Serbian Radical Party, nor did anybody from the

 3     Serbian Radical Party issue orders to that effect.  And I know that

 4     Mr. Seselj condemned that kind of behaviour, and they weren't people that

 5     were responsible for politics and the actions of the Serbian Radical

 6     Party.

 7             JUDGE ANTONETTI: [Interpretation] Let me now move to the fact

 8     that at one point in time, you decided to be a Defence witness.  How did

 9     this happen?  Did you suddenly say, "Why be a Prosecution witness when I

10     could be a Defence witness?"  Could you tell us exactly what train of

11     thought you had at the time in order to end up with this decision?

12        A.   Well, the following reasons, Mr. President:  On the 16th of

13     September, 2006, Mr. Dan Saxon came to see me.  We had an hour-long

14     conversation, or a little longer, in fact, in a very pleasant atmosphere;

15     and I managed to convince Mr. Saxon that I could not be a witness that

16     would be of any use to the Prosecution, because I didn't take part in the

17     war, nor do I know about any war crimes, and at the same time I said I

18     believe that Dr. Seselj -- well, Mr. Saxon said:

19             "Very well.  If you cannot testify about war crimes, come and

20     help us to politically liquidate Dr. Vojislav Seselj, because

21     Dr. Vojislav Seselj is the greatest danger to the new authorities in

22     Serbia."

23             And he stressed that we must ensure the kind of authorities --

24     authority and power that would be pro-Western, a pro-Western government.

25     And I said that I wasn't going to take part in that, either, of course.

Page 12859

 1             But what was particularly important, as far as I was concerned,

 2     was something that Mr. Saxon said.  He said:

 3             "Well, if you refuse and if all the others who we thought would

 4     testify against Dr. Seselj refuse, then the question arises, and I don't

 5     personally believe that Dr. Seselj will be convicted and punished."

 6             That's what he said.  That's the -- and I personally have no

 7     evidence against him.  So, well, I got through that, I lived through

 8     that.  They're prosecutors, they prosecute, they have their goals and

 9     tasks.  They seem to be more political than legal, to my mind.

10             But finally I decided, after working with Ms. Dahl, to come in.

11     And when I told Ms. Dahl the same thing I told Mr. Saxon, I said that I

12     cannot be -- could not be a Prosecution witness, Dr. Seselj did not

13     commit any crimes, she was resigned and said, "Well, you're refusing,

14     everybody's refusing, so what am I going to do with the indictment?

15     Seselj will go back, then."

16             And she also said, "You can speak neutrally what you wrote in

17     your statement."  And I don't know what is in the statement.  And then

18     she said, "When you come to The Hague, we'll decide about Ovcara and

19     Vocin."  And then afterwards I saw that they want to convict an innocent

20     man, that they want to convict somebody for ideology and politics which

21     are the ideology and politics that I share.  Well, you're not going to do

22     that, you Western people.  We're not impotent, we Serbs.  So when you're

23     pilfering us and looting us, you say, "Isn't that nice."  When you kill

24     us, we're supposed to say, "Go ahead, kill us some more."  Well, you

25     can't do it that way.

Page 12860

 1             I am going to defend my Serb, Vojislav Seselj.  And nobody from

 2     the Serbian Radical Party initiated any agreement or interview.  I

 3     initiated a talk with Zoran Krasic after words with Petar Jojic, and I

 4     have nothing to hide.

 5             JUDGE ANTONETTI: [Interpretation]  So you took the initiative.  I

 6     am --

 7        A.   Mr. President, believe me, I left Seselj, and you know what my

 8     activity after that was.  It is so obvious that no one can influence my

 9     activity and --

10             THE INTERPRETER:  The interpreter did not hear the end of the

11     sentence.

12             JUDGE ANTONETTI: [Interpretation] I'd like to know this.  Do you

13     have a political activity today or have you stopped altogether?

14        A.   Now, I'm a member of the Serb Radical Party, and I'm a member of

15     the Municipal Assembly of the Town of Pancevo.

16             JUDGE ANTONETTI: [Interpretation] I see.  So you were elected a

17     member of Parliament at the last elections, and you are an SRS member,

18     and you are, as such, a member of Parliament?

19        A.   No, I was on the ticket of the Serb Radical Party as of May.

20     After speaking to Ms. Dahl and after this visit paid by this lady on the

21     28th of February this year, this lady introduced herself as a Slovene,

22     I can describe her, whatever her name was, she came into my apartment,

23     she entered almost by force; and she said that she was a friend of this

24     Court.  And she opened her bag full of foreign currency, and I threw her

25     out.  Well, you know what?  I cannot work in favour of a prosecutor that

Page 12861

 1     is prepared to do all of these things that I've told you about until now.

 2             JUDGE ANTONETTI: [Interpretation] You were elected into

 3     Parliament?

 4        A.   No, no.  After this visit, and I gave this a great deal of

 5     thought, and since I had prepared a new book in which I viewed the

 6     position of the Serb people in global terms, and generally speaking I

 7     look at global relations, this is a rather serious book with rather

 8     serious aspirations, I realised and I am convinced that the only

 9     authentic Serb politician now is Dr. Vojislav Seselj.

10             In Serbia, we have another politician who is prepared to defend

11     the interests of his state and his people, and that is

12     Vojislav Kostunica.  However, Dr. Seselj is closer to me, in terms of his

13     programme and ideology, and I'm prepared to fight for this ideology and

14     this policy until the end of my life.

15             JUDGE ANTONETTI: [Interpretation] So you say that you want to

16     fight for this ideology.  Well, this brings me to a possible link between

17     Milosevic, Seselj, and Karadzic.  As far as you know, did Mr. Seselj meet

18     with Mr. Milosevic ?

19        A.   Well, I don't know about any specific meeting, but Dr. Seselj

20     didn't call me or inform me about that meeting.  However, what I'm sure

21     of is that Milosevic was a bit afraid of Dr. Seselj as a competitor in

22     the field of government.  Dr. Seselj always fully expressed the truth

23     about policies, about mistakes made, about good things done by Milosevic,

24     and he did not, therefore, depend on Milosevic at all, or on anyone else,

25     for that matter.

Page 12862

 1             As for Milosevic, I don't think he's a traitor, but that he does

 2     not have the right format to be able to lead Serbia and the Serbian

 3     people.  He, himself, admitted at the 2nd or 3rd Congress of the

 4     Socialist Party that he had not made the right estimate of the

 5     international factor.  That is impermissible.  It is an impermissible

 6     short coming, as far as a politician is concerned, and also the detriment

 7     is incalculable.

 8             JUDGE ANTONETTI: [Interpretation] As far as you know, what about

 9     links with Radovan Karadzic?  What were they?

10        A.   Well, I don't know of any intensive relations between Dr. Seselj

11     and Dr. Karadzic.  What I do know is that Dr. Karadzic is a politician of

12     a similar mettle like Milosevic.  He did not like competition, and he

13     steered clear of Dr. Vojislav Seselj; and he did not want him to have an

14     influence over the people in Bosnia-Herzegovina.

15             However, as far as the defence of the Serbian people is

16     concerned, sending soldiers to Republika Srpska, there was some

17     cooperation, of course.  Karadzic or Ratko Mladic would not allow Seselj

18     to interfere in their conduct of war, or would Dr. Seselj meddle in that

19     kind of thing.  Like in the case of Croatia, he just wanted to help in

20     the defence of the Serb people, and he did not set up any radical

21     formations of his own.  After all, in Bosnia-Herzegovina there was an

22     independent Serb Radical Party.

23             JUDGE ANTONETTI: [Interpretation] The last topic I'd like to

24     address with you, Greater Serbia.  You mentioned this in paragraph 104 of

25     your statement.

Page 12863

 1             In your view, what was the outlook -- the concept Mr. Seselj had

 2     of the Greater Serbia.

 3        A.   A Greater Serbia is a concept, a concept of the historical and

 4     national rights of the Serb people.  As for this concept and this

 5     ideology, Dr. Seselj elaborated it in a complete fashion, and he proved

 6     how, during the 19th and 20th century, Serbs disassociated themselves

 7     from their own nation, and that process is going on to this day.

 8             According to the information from last year, already 50.000 Serbs

 9     in Croatia do not dare declare themselves as Serbs or as Orthodox

10     Christians.  They don't want to abandon their ethnic and religious

11     background, but as the state organs and the Catholic Church in Croatia

12     that are making them do that.  They were Serbs, they registered them as

13     Croats.  They were Orthodox Christians, they registered them as

14     Catholics.

15             In my studies, I obtained some data, and I could not get a hold

16     of all the data that Dr. Seselj had, that, for example, according to our

17     well-known historian, Dragoljub Zivojinovic, before the Second World War

18     there were 1.900.000 Serbs in Croatia.  How many are there now, about

19     200.000 in Croatia.  Please, if a person is to be serious, if a scholar

20     is to be serious, a doctor, a professor, a doctor of sciences like

21     Dr. Seselj, can he not take that into account when elaborating his

22     concept?

23             These are the historic and national rights of the Serb people.

24     Dr. Seselj insists on that; namely, that that will be achieved through an

25     evolution.  One day, this information is going to be made available to

Page 12864

 1     all Croats, those who used to be Serbs and those who were not Serbs.

 2     Dr. Seselj is counting on that.  He's also counting on stronger Slavism,

 3     that Slavism affirm its strength so that it's a partner to Western

 4     Europe, not to have Slavism curtailed through Poles and Croats.

 5             I think that Dr. Seselj is proceeding from real, proven facts,

 6     and that he basis his concepts and ideology on them.  He does not

 7     advocate, on the basis of his information, his knowledge, his research,

 8     his books, he does not advocate conflict with other peoples.  He does not

 9     advocate genocide or conflict.  He is responsible, in terms of the truth

10     and science.

11             JUDGE ANTONETTI: [Interpretation] As to the concept of

12     pan-Slavism, I read with interest that you are the author of some papers

13     on the Constitution.  As a lawyer, I'm sure you will understand the gist

14     of my question.

15             Is one of the consequences of pan-Slavism that territories,

16     frontiers, can be shifted, or is it just a cultural concept, a humanist

17     concept or a religious one that does not bring with itself any changes in

18     territory, that does not result in borders being changed, territory being

19     given, and is this concept compatible with Yugoslavia's -- former

20     Yugoslavia's administrative structures?  What is your thought, your

21     estimate of the situation?

22        A.   Mr. Antonetti, precisely, we do not advocate any kind of

23     secession, any kind of violent change of borders.  I personally would

24     like it if we had the right kind of situation of renewing Yugoslavia, but

25     certainly not to -- not at the expense of the Serb people or any other

Page 12865

 1     people.  Of course, for the time being, that is impossible.

 2             What I personally advocate, as an academician and as a citizen,

 3     is that Slav countries cooperate to the best of their ability on the

 4     basis of mutual interests of Slavic countries.  In my academy, we do

 5     study this subject matter.  We study the specific characteristics of the

 6     Slav peoples and also what we have in common, in terms of tradition,

 7     language, culture, the economy and politics.  We do offer such solutions;

 8     inter alia, we prepared an agreement on the establishment of a Slavic

 9     community.  Of course, that cannot move ahead fast, but that is our

10     vision.

11             All these capacities should be used, and why not use the

12     experience of Western Europe too, when Western Europe organised itself

13     very nicely and everyone benefits from that?  Why would Slav peoples not

14     do that, too, not on the basis of superiority and inferiority, as is now

15     being imposed through the European Union and NATO?  Why would Serbia be

16     in NATO now, and then they bombed us in 1999.  They say we're friends.

17     Yeah, right, friends, friends who bomb us.  Why would we not create that

18     kind of community, and why would not be -- why would we not be partners

19     very nicely in peace with the West and avail ourselves of all this

20     experience?  Why would we not trade?  Why would we not base relations on

21     that concept?  Why not?  And then this concept of the great de Gaulle,

22     who we Serbs highly respect, Europe from the Atlantic to the Ural

23     Mountains.

24             JUDGE ANTONETTI: [Interpretation] One last question.  I can tell

25     you that, but I guess you know.  You know that in the indictment against

Page 12866

 1     Mr. Seselj, a joint criminal enterprise is alleged, the purpose of which

 2     is to create a Greater Serbia whose western borders would tally with the

 3     Karlobag-Karlovac-Ogulin-Virovitica axis; and that therefore this Greater

 4     Serbia had to take territory from Croatia and Bosnia and Herzegovina for

 5     it to be fulfilled.  This is what the Prosecutor said in the indictment.

 6             What do you think of this theory of a Greater Serbia with the

 7     Karlobag-to-Virovitica line?

 8        A.   Mr. President, this line or axis was not invented by Dr. Seselj.

 9     It was the French and the English who established it in 1915, when Serbia

10     put up a strong resistance against Austria and Germany in the First World

11     War, and when they were the allies of the Serb people and the Serb state,

12     and when they had a realistic view of the interests of the Serb people.

13     They took into account all of these facts and elements that Dr. Seselj

14     explained in his books.  That is the historic right of the Serb people.

15     Of course, I accept that this is a historic and national right of the

16     Serb people, but I also accept the way in which this could perhaps be

17     carried through on the basis of evolution and a long-term process, like

18     Dr. Seselj.

19             Dr. Seselj did not call for a creation of a Greater Serbia

20     through showdowns, war, persecutions, crimes, or genocide.  He pointed

21     this out as rights.  He cautioned the Croatian people, "If you persecute

22     us Serbs, if you kill us, if you kill us for no reason whatsoever, in a

23     groundless fashion, these are our rights."

24             However, during the course of the war, Dr. Seselj never spoke

25     about volunteers, or did he ask the JNA to go out and establish this kind

Page 12867

 1     of a Greater Serbia.  He just indicated this, and he cautioned the Croats

 2     and the rest in Yugoslavia.

 3             Well, we have this historic right, and after all, we advocated

 4     Yugoslavia, and we would not have raised this issue had Yugoslavia still

 5     been in existence.  We only raised this issue in terms of defending the

 6     Serb people from genocide, which they did experience, nevertheless, in

 7     the territory of Croatia.

 8             I don't think that on the basis of this concept or this ideology,

 9     Seselj advocated war, persecutions and genocide.  That is my view, and

10     I'm sure of that.

11             JUDGE ANTONETTI: [Interpretation] I'm now turning to the

12     Prosecution.  You have one hour.

13             Ms. Biersay.

14             MS. BIERSAY:  Thank you, Your Honour.  If I could have one moment

15     just to reorganise.

16                           Cross-examination by Ms. Biersay:

17        Q.   I think it's still morning.  Good morning, Mr. Glamocanin.

18        A.   Good day to you.

19        Q.   My name is Lisa Biersay.  We have not met, have we?

20        A.   We haven't, no, but I've seen you.  I've seen you in TV coverage

21     from these trials, and you seem to be very fair and very professional.

22     Now, whether you're going to be that way remains to be seen now.

23        Q.   I'll try my best.  You described to the Court your first

24     involvement with the SRS.  Do you remember that description you gave for

25     the Court?

Page 12868

 1        A.   Well, I told you I was in the Serb Chetnik Movement, and the Serb

 2     Radical Party came into being when the Serb Chetnik Movement united with

 3     the People's Radical Party.

 4        Q.   Sir, do you need glasses in order to read?

 5        A.   I do.

 6        Q.   I wanted to show you a document on the screen.  And let me know

 7     if it would be easier to see the hard copy, but I think it will work.

 8             If I could have 65 ter number 84, please.

 9             I'd like to direct your attention to February of 1991.  Was that

10     the time of the founding of the SRS, as you described it?  Is that date

11     correct?

12        A.   Yes.  Yes, that is the time of the founding.

13        Q.   And you were -- it was at that founding where you were elected a

14     member of the board of the SRS; is that correct?

15        A.   Correct.

16        Q.   Also, there were members of the -- you describe the Serbian

17     Chetnik Movement; namely Petkovic and Gojkovic and Nikolic; is that

18     correct?

19        A.   Well, Petkovic, yes.  Gojkovic, Nikolic, I think they were from

20     the People's Radical Party.

21        Q.   Were there also representatives from the NRS?

22        A.   NRS meaning "Narodna Radikalna Stranka," People's Radical Party.

23     Well, that's it, Nikolic and Gojkovic, and I can't remember who else.

24        Q.   Could you look at your screen, and are you able to make it out

25     from where you're sitting?  The B/C/S version should be on your left.

Page 12869

 1        A.   Yes, yes, I can see it, yes.  Yes, yes.

 2        Q.   If we could go to the title page.

 3             THE INTERPRETER:  The interpreter cannot hear the speaker.

 4             MS. BIERSAY:

 5        Q.   Now, this is the Statute of the Serbian Chetnik Movement; is that

 6     correct?

 7        A.   Yes.

 8             MS. BIERSAY:  And for the Court, this was published in, I

 9     believe, July -- on July 1st, 1990, in 'Velika Srbija.'

10             At this time, the Prosecution would move for the -- move for the

11     admission of 65 ter number 84, please.

12             JUDGE ANTONETTI: [Interpretation] Are you sure that this has not

13     yet been admitted?

14             MS. BIERSAY:  According to my assessment, Your Honour, it has not

15     been.  I think there was another document with it.

16             JUDGE ANTONETTI: [Interpretation] Very well.  Let's have a

17     number.

18             THE ACCUSED: [Interpretation] Mr. President, as far as I can

19     remember, this has been admitted.  It was admitted during the testimony

20     of Expert Theunens, if my memory serves me correctly.

21             JUDGE ANTONETTI: [Interpretation]  Well, that's what I thought,

22     too.  I thought it had been admitted.

23             Let's have a number.  If there were two numbers, if there were to

24     be two numbers, we'll just erase one.  A number, please.

25             THE REGISTRAR:  Your Honours, this document shall be given

Page 12870

 1     Exhibit number P868.  Thank you, Your Honour.  Excuse me, correction for

 2     the transcript.  This shall be given Exhibit number P686.  Thank you.

 3             MS. BIERSAY:  Thank you.  And if we could please go to

 4     paragraph 12 of that exhibit, please, or Article 12.

 5             THE WITNESS: [Interpretation] I can't see that.

 6             MS. BIERSAY:  It's on the next page.  It's coming.

 7             THE WITNESS: [Interpretation] The print is very small.

 8             MS. BIERSAY:  Is it possible to enlarge on just the B/C/S side

 9     that section 12?

10             THE WITNESS: [Interpretation] I've read it.  It has been

11     enlarged.

12             MS. BIERSAY:

13        Q.   Now, in Article 12, am I correct in saying that is an outline of

14     the organisation of the party, of the movement?

15        A.   Yes, that's what can be seen.  In all of these areas, there are

16     Serbs, but not only Serbs.  There are inhabitants of all other

17     ethnicities living in those areas that were members of this organisation

18     of ours, so it's not an exclusively Serb organisation.

19             Let me remind you of something else.  I --

20        Q.   One minute, one minute.  We'll get to that.  I just wanted to ask

21     you if, in that article, it names several regional administrations,

22     correct, for the Serbian Chetnik Movement?

23        A.   Well, yes, yes.

24        Q.   Thank you.  When you described for the Court your tenure as

25     president of the Regional Board of Banat, the Court asked you where that

Page 12871

 1     was, how many districts did the Banat region cover?

 2        A.   Well, Serbia is not organised on the basis of districts, but

 3     counties, rather; municipalities, counties and provinces.  There are

 4     three counties with centres in Pancevo, Zrenjanin and Kikinda,

 5     respectively.  At the time when I was president of the Regional Board,

 6     there were these three counties.  To this day, actually.

 7        Q.   And for those three districts, there was a president for each

 8     one; is that correct?

 9        A.   Yes.

10             THE ACCUSED: [Interpretation] Objection.  A double objection, at

11     that.

12             First of all, Ms. Biersay intentionally confuses the Serb Chetnik

13     Movement and the Serb Radical Party.

14             Secondly, this is the Statute of the Serb Chetnik Movement from

15     1990, not only during the existence of Yugoslavia, but also during the

16     existence of communist regime, and at that time there was no law on the

17     territorial organisation of Serbia on the basis of counties.  That law

18     was passed, I think, in 1991, if I remember correctly, or perhaps even in

19     1992.  So this is arbitrary, these regions set out here, and they're not

20     supported by any kind of administrative acts on the part of the state.

21             This is intentional confusion that is being created, and I simply

22     had to intervene.

23             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, obviously the

24     document here does not address the Serbian Radical Party, but the Serb

25     Chetnik Movement.  And, secondly, according to Mr. Seselj, this document

Page 12872

 1     dates back to 1990, and as far as the administrative breakdown of Serbia

 2     was concerned, there were no districts at the time, or that's what he's

 3     saying, anyway.  And the witness seems to be nodding and confirming what

 4     Mr. Seselj is saying.

 5             Please proceed with your questions.

 6             MS. BIERSAY:  Thank you, Your Honour.  And --

 7             THE WITNESS: [Interpretation] Yes, Mr. President, I omitted to

 8     take that fact into account.  I was speaking from the aspects of the

 9     internal division of Serbia at the time when I became involved in the --

10     actively in the work of the Serbian Radical Party, and present day

11     conditions.  Yes, Mr. Seselj is actually right.

12             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

13             MS. BIERSAY:  Your Honour, I would respectfully request that to

14     the extent that Mr. Seselj has clarifying questions, that he waits until

15     his opportunity to examination the witness, instead of interrupting me

16     and making his arguments for which the witness is supposed to adapt his

17     statement.

18             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, I fully agree with

19     you, but then if you are going astray, you know, on an erroneous

20     assumption, then everybody is wasting time.  So it's best, you know, to

21     put you back on track immediately, rather than let you waste 15 to 20

22     minutes on a subject, and then afterwards, in about 20 seconds, he can

23     destroy all the arguments you put forth.

24             MS. BIERSAY:  With all due respect, Your Honour, it's not my

25     arguments, it's testimony coming from the witness, and Mr. Glamocanin has

Page 12873

 1     shown he's more than capable of correcting me if I need to be corrected.

 2             JUDGE ANTONETTI: [Interpretation] Very well.  Proceed.

 3             MS. BIERSAY:

 4        Q.   In addition to these -- the districts that you described, and you

 5     also mentioned that there are municipalities as well within the region

 6     over which you had the Presidency -- is that correct?

 7        A.   Madam Prosecutor, I can't tell you much about this.  Yes, I was a

 8     member of the Serbian Chetnik Movement.  However, at that time, right up

 9     until September 1991, I was active in another movement, and I was the

10     head of that movement, and that was the Solidarity Alliance of

11     Yugoslavia.

12        Q.   I understand, I understand.  You, in addition to setting up and

13     taking oversight of this region, you also described how you assembled

14     experts, is that correct, to set up economic programmes, like education

15     and infrastructure and health for your region?  You initiated all of

16     that; is that correct?

17        A.   Along with cooperation -- agreement from Mr. Seselj, we

18     rallied -- I rallied experts, and we made an economic programme for the

19     Serbian Radical Party based on ideas or, rather, ideology, and that

20     programme was added on to later on and modified.

21        Q.   You described for the Court the SRS branches that existed in the

22     other republics.  Was there also an SRS branch of Vojvodina?

23        A.   Madam Prosecutor, Vojvodina is part of Serbia, and I was at the

24     head of the movement which did a great deal and helped a great deal to

25     have Vojvodina back within the composition of Serbia.  We didn't make any

Page 12874

 1     separate organisation for Vojvodina.

 2             MS. BIERSAY:  If I could now have 65 ter number 7427, and I'd

 3     like the last page, please.  Actually, I believe it's 7427A, please.

 4        Q.   While we're waiting for that document, sir, the War Staff, if we

 5     could talk about the War Staff.

 6             You described the War Staff as part of the central structure of

 7     the SRS?

 8        A.   Well, for me, that staff was a service dealing with affairs

 9     related to the departure of volunteers, their accommodation, taking them

10     in; but it wasn't only the War Staff of the Serbian Radical Party that

11     did things like that, but taking in these people as linked to the JNA

12     activities.  The JNA, as has been proved here, brought all the volunteers

13     in buses.  They were brought back to Belgrade.  Some came to the

14     War Staff, others didn't.  Then that War Staff also helped in the

15     following way:  They helped them record their war service, that is to

16     say, the time they had spent on the battle front, and so on and so forth,

17     the benefits and so on.

18        Q.   I believe that you did describe that for the Trial Chamber.  My

19     question to you is:  Was the War Staff one of the bodies of the Serbian

20     Chetnik Movement or was it separate from the Serbian Chetnik Movement?

21        A.   No, the Serbian Chetnik Movement did not exist at that time, at

22     the time when the volunteers went to the battle front.  It was the

23     Serbian Radical Party that existed then.

24        Q.   When did the Serbian Chetnik Movement come into existence?

25        A.   Well, Mr. Seselj has already said that, and you said in 1990,

Page 12875

 1     mid-1990, but there were the so-called Young Chetniks in Serbia before

 2     the Serbian Chetnik Movement.  I know that full well because my own son

 3     was the president of those Young Chetniks.

 4        Q.   On the document before you, which is 65 ter number 7427A, can you

 5     see -- can you see what's on the right side -- the left side of the

 6     screen?

 7        A.   It says "Main Board" there, and then there's some signatures.

 8        Q.   Do you recognise the signature?

 9        A.   Well, Madam, I didn't take part in these affairs, so I can't

10     really tell you anything about that.  All I can do is read out what it

11     says.  But other than that, to say that I remember the document, no.  And

12     to say what it's all about, I really can't do that.  I don't know.

13             MS. BIERSAY:  May I ask that a hard copy of this document be

14     given to the witness, please.

15        Q.   If you could flip to the very back, the last page.

16        A.   Well, my handwriting, but I don't remember this.  I really don't

17     remember.

18        Q.   But you recognise your handwriting; is that correct?

19        A.   Well, yes, but I just can't remember this.

20        Q.   Now, you described to the Trial Chamber that the vice-president

21     for Republika Srpska was a Poplasen, and perhaps I'm not pronouncing that

22     correctly.

23        A.   Yes, I can see here, Nikola Poplasen.

24        Q.   And you also described the vice-president at that time for the

25     SRS in Montenegro?

Page 12876

 1        A.   Yes, Radovan Vucevic.

 2        Q.   At the local level, when we're talking about the coordination of

 3     volunteers at the local level, was that coordination done by Serbian

 4     Chetnik Movement members?

 5        A.   At this level, at the level that I was in the party, we had a man

 6     in charge of working with the volunteers, and I assisted him.  He

 7     organised work with them.  I helped him out.  I thought it was my duty to

 8     do so, and also I had the desire to help.  And he coordinated work with

 9     people who were in charge of the same affairs at party level.

10        Q.   What was his official title, if he had one?

11             The person that you're -- do you know someone by the name of

12     Stefan Grubanov  [phoen]?

13        A.   Stefan Grubanov, yes.  Well, he worked through the volunteers,

14     matters related to the volunteers.  He had his own office, and --

15        Q.   Did he coordinate the volunteers for your area?

16        A.   Yes, he did.  He dealt with all those matters, and he

17     coordinated, but I assisted as president of the Regional Board and later

18     on as president of the County Board, and I was in a position to help him.

19     Of course, I didn't make the lists, I didn't do these administrative

20     things, but the serious matters.  When I say "serious," I mean when the

21     volunteers had to go to a church and take Holy Communion and pledge that

22     they would fight chivalrously in the eyes of God, that they would not

23     commit evil deeds.  And of course when it was necessary to secure some

24     funds from the business community, from the state and so on, I was better

25     placed to do things like that.

Page 12877

 1        Q.   Now, this coordinator of the volunteers, did he report to you or

 2     did he report to the War Staff in Belgrade?

 3        A.   Well, the War Staff, establishment-wise.  But he was a member of

 4     the Serbian Radical Party, so that we cooperated intensively, but I

 5     wasn't interested nor did I have the duty to deal with all the details.

 6        Q.   Am I correct in saying that within each local SRS branch, there

 7     was a local coordinator who would deal with the volunteers in the

 8     capacity like Mr. Grubanov did?

 9        A.   Well, not every municipality had that, but in the Banat area I'm

10     quite sure it did; Pancevo, Zrenjanin, and Kikinda, and that's an area

11     which was the most successful in terms of numbers and in all the other

12     aspects linked to the volunteers' departure to the battle front.

13             And let me also tell you that in Pancevo and everywhere else, we

14     had quite a lot of Hungarian volunteers, there would be a few Romanians,

15     so that the defence both of the Serb people and the desire to defend and

16     protect Yugoslavia, too, was something that was accepted by one and all,

17     all the ethnic groups.  We had Hungarians, for example, who laid down

18     their lives, who were killed in Pancevo.  We had people who were wounded

19     and injured, and there was a general atmosphere of -- well, a very

20     enviable atmosphere with respect to the work of the Serbian Radical Party

21     and its standing up in defence of the Serb people in those war-infested

22     areas.

23        Q.   Let me ask you this:  With respect to the Serbian Chetnik

24     Movement, who was at the head of that movement?

25        A.   While it was functioning, it was Dr. Vojislav Seselj.

Page 12878

 1        Q.   And what role, if any, did those people who were given the title

 2     vojvodas have within the Serbian Chetnik Movement?

 3        A.   Some of the vojvodas were linked to the battle front.  Others

 4     acted politically as members of the Serbian Radical Party.

 5        Q.   Were you ever a vojvoda?

 6        A.   No, I never became a vojvoda.

 7        Q.   And why is that?

 8        A.   I didn't have any pretensions along those lines, either.  Well,

 9     that's why.  I don't have any pretensions as somebody fighting on the

10     front.  I am engaged in other matters.

11        Q.   So the vojvodas were the force behind the armed struggle of the

12     SRS; is that correct?

13        A.   Well, first of all, it's not correct that the SRS was a combat

14     force.  It all functioned in the way in which we've already discussed

15     today.  We would send volunteers, but it wasn't the SRS or the Serbian

16     Chetnik Movement that had its own units.  They were units within the

17     composition of the legal forces; first of all, the JNA, then later on the

18     Territorial Defence, and later on still the army of Republika Srpska

19     Krajina was formed, and then in Bosnia-Herzegovina the army of the -- of

20     Republika Srpska was formed.  And before that -- well, yes, the army of

21     Republika Srpska was formed there straight away, and they had their own

22     Territorial Defence for a short period.

23             THE ACCUSED: [Interpretation] Objection.  I didn't want to

24     interrupt the witness, but I have an objection to make once the witness

25     finishes what he was saying.

Page 12879

 1             THE WITNESS: [Interpretation] Go ahead.

 2             MS. BIERSAY:  Mr. Seselj has lost the opportunity to object to

 3     the question if it's already been answered.

 4             THE ACCUSED: [Interpretation] I do have the right to object to a

 5     question within the frameworks of the general conduct of the Prosecutor.

 6     It's not my intention to control how the Prosecutor's going to use her

 7     time.  It's in my interest if the Prosecutor wastes her time.  But it has

 8     to be conducted properly, because the Prosecutor has the right to trick

 9     questions as well, but he does not have the right to ask questions which

10     will create confusion.

11             MS. BIERSAY:  I submit to the Chamber that Mr. Seselj is now

12     giving cues to the witness on how to answer, and it's inappropriate for

13     him to do that.

14             THE ACCUSED: [Interpretation] No.  I waited for the witness to

15     finish his answer.

16             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I'm trying to

17     understand your objection.

18             Ms. Biersay is putting questions to this witness on vojvodas.  He

19     answers that he never was a vojvoda, and now you're taking the floor for

20     something that I don't understand what your point is.

21             THE ACCUSED: [Interpretation] Mr. President, I intentionally

22     waited for the witness to complete his answer so as not to influence his

23     answer.  I'm intervening because I consider that any examination must, in

24     principle, be conducted properly and correctly.

25             Ms. Biersay asked whether the Chetnik vojvodas were the basic

Page 12880

 1     force in the war, and she knows full well that the first Chetnik vojvodas

 2     on my part were proclaimed in May 1993, and the war had been going on for

 3     two years already.  So that is that improper conduct that permeates her

 4     manner of examination, and I object to that.

 5             JUDGE ANTONETTI: [Interpretation] Very well.

 6             Ms. Biersay, Mr. Seselj is saying that the vojvodas he appointed

 7     were proclaimed in May 1993, and that, therefore, you cannot ask the

 8     witness whether the vojvodas played a role previously.  He says that they

 9     were only proclaimed in 1993.

10             JUDGE LATTANZI: [Interpretation] Mr. Seselj, according to our

11     procedure in this Tribunal, you can ask questions on this, but during

12     your own cross-examination, and you can ask the witness to give details

13     and specific answers on this and maybe correct what he answered to the

14     Prosecutor.

15             JUDGE ANTONETTI: [Interpretation] Continue, Ms. Biersay.

16             THE ACCUSED: [Interpretation] May I be allowed to say something

17     else?

18             It is not my intention to ask the witness to clarify these

19     matters, because this witness can't know everything, but a document has

20     already been admitted into evidence.  It was signed by my hand, about the

21     proclamation of the first Chetnik vojvodas in May 1993, whereas -- so the

22     Prosecutor cannot behave as if there's been none of that, none of those

23     proceedings so far.

24             JUDGE LATTANZI: [Interpretation] I regret, Mr. Seselj, if the

25     witness does not know, during the cross-examination he will just answer

Page 12881

 1     one of your questions by saying, "I don't know."  But you're not allowed

 2     to testify.

 3             JUDGE ANTONETTI: [Interpretation] Continue, Ms. Biersay.

 4             MS. BIERSAY:  And now if we could please --

 5             JUDGE ANTONETTI: [Interpretation] However, I would like to have

 6     my position on the transcript regarding this issue.

 7             The Court's time, the Bench's time, is very precious.  You know

 8     that.  I had two hours, and in these two hours I put all my questions.

 9     The Prosecutor will have one hour and Mr. Seselj will have one hour.  So

10     everyone intervening, be it a Judge, the accused or the Prosecutor, must

11     be absolutely sure of his question when he puts it.  He must be

12     absolutely sure of the basis of his question, because if he makes a

13     mistake, then there are consequences; raises objections and so forth and

14     so on.

15             So as far as this question of vojvodas, which we have already

16     explored at length with many other witnesses, I believe, Ms. Biersay,

17     that if you have elements that may allow you to say that in 1991, there

18     were -- or 1992, there were vojvodas actually acting on the ground, then

19     do so, but you have to be very specific.  You have to be able to back

20     what you say.  Otherwise, we're wasting time.

21             MS. BIERSAY:  Thank you, Your Honour.

22             I'd now like to direct your attention to 65 ter number 92, and

23     hopefully you'll be able to read that.  And while we're retrieving that,

24     it's an article entitled "The Leader of Zvezda's Delijas Has Joined the

25     Serbian Chetnik Movement," and this was published in 'Velika Srbija,'

Page 12882

 1     issued number 2, 1990.  And if we could go to the bottom of the B/C/S.

 2     Could we go to the next page, please, for the B/C/S.  And in the lower

 3     corner, lower right-hand corner, if you could enlarge.

 4        Q.   Actually, do you recognise -- I know it's a grainy picture, but

 5     you discussed your son being in one of the -- in one of the groups?

 6        A.   Yes, my son.

 7        Q.   Do you recognise him?

 8        A.   I do.  Srdjan, I recognise him.

 9             MS. BIERSAY:  And if we could please enlarge that box.  And I

10     believe the corresponding English would be on page -- there we go.

11        Q.   Now, the title of that is "The Vojvoda Dr. Vojislav Seselj's

12     Oath"; is that correct?  Is that correct?

13        A.   I have never seen this oath, but I have no reason to doubt --

14     doubt it, and it is an oath within the frameworks of the traditions of

15     the Serbian people and the traditions of all those who loved their people

16     and who were ready to die for their people.

17        Q.   'Velika Srbija' is a publication associated with what party?

18        A.   Well, that's already been stated.  This 'Velika Srbija' is still

19     published, and it's becoming a better and better newspaper.  It has a lot

20     of scholarly articles and very -- has been successful, and it's far and

21     above the best paper throwing light on all topical issues and the overall

22     problems that face the Serb nation and the Serb state, and also the world

23     situation, world affairs, and all the rest of it, and men of letters and

24     men of science write for the papers, academicians, university professors,

25     and the like.

Page 12883

 1             MS. BIERSAY:  Thank you.

 2             At this time, the Prosecution moves for admission of 65 ter

 3     number 92, please.

 4             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, could we have a

 5     number for this exhibit.

 6             THE ACCUSED: [Interpretation] Objection.  Mr. President,

 7     I think -- I think my objection is in order.  In the previous issue of

 8     'Velika Srbija,' the Prosecutor had at its disposal a whole article about

 9     my taking the oath of the Serbian Chetnik vojvoda in Libertyville

10     Monastery near Chicago in the United States of America.  There was an

11     extensive article about all that.  And in the next issue, they just

12     repeat the oath.  So why doesn't the Prosecutor tender into evidence

13     both, because like this you don't know where the oath was taken, on what

14     occasion, or anything else.  It's just something that's been inserted

15     there.  And they have all the documents, they have all the back issues of

16     'Velika Srbija,' so why don't they tender both?

17             JUDGE ANTONETTI: [Interpretation] We know it now.  You just told

18     us where it was done.

19             Let's have a number for this exhibit, please.

20             THE REGISTRAR:  Your Honours, this document shall be given

21     Exhibit number P687.  Thank you, Your Honours.

22             MS. BIERSAY:  If I may, Your Honour, inquire as to how much time

23     I have left and when the Court would like to take its next break.

24             JUDGE ANTONETTI: [Interpretation]  I'll ask the Registrar,

25     because I don't know.

Page 12884

 1             You have 30 minutes.

 2             I think it's best to break right now, and we'll resume later on.

 3     Is it okay?

 4             MS. BIERSAY:  Absolutely, Your Honour.  Thank you.

 5             JUDGE ANTONETTI: [Interpretation] Very well.  Twenty-minute

 6     break.

 7                           --- Recess taken at 12.00 p.m.

 8                           --- On resuming at 12.29 p.m.

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

10             Before I ask Ms. Biersay to proceed, Witness, I seek a small

11     clarification.

12             You said that you were elected a member of Parliament.  I'd like

13     to know this:  Were you elected at the level of the Pancevo municipality

14     or were you elected a member of the Parliament in Belgrade?

15        A.   I was an MP from 1992 until the end of 1996, but I've been a

16     member of the Municipal Assembly since May this year.  And I returned to

17     the Serb Radical Party, rejoined its ranks, in March this year.

18             JUDGE ANTONETTI: [Interpretation] So you are a regional member of

19     Parliament in the Pancevo municipality to date?

20             THE WITNESS: [Interpretation] Mr. President, I am still a member

21     of the Municipal Assembly from the elections that were held in May this

22     year.

23             JUDGE ANTONETTI: [Interpretation] There may be a problem with the

24     interpretation.  What I want to know is this:  I want to know whether you

25     are a member of Parliament in Belgrade.

Page 12885

 1             THE WITNESS: [Interpretation] No, no.

 2             JUDGE ANTONETTI: [Interpretation] That's all I want to know.  The

 3     rest, you are a local member or elected person, you were elected locally.

 4     That's all I wanted to know.

 5             Ms. Biersay.

 6             MS. BIERSAY:  Thank you, Your Honour.

 7             If we could now have Exhibit P223, please.  And just for planning

 8     purposes, after that I'll also ask for P227, P217, and P25.

 9        Q.   Mr. Glamocanin, you'll need your glasses, because I'll be showing

10     you some documents on that computer screen again.

11        A.   Very well.

12        Q.   So that would be Exhibit P223.

13             Now, isn't it true that the volunteers were deployed as units and

14     not just incorporated into existing JNA units as individuals?  And

15     looking at P223, it reads:

16             "On behalf of SRS volunteer units, Commander Novacic is

17     authorised to coordinate on behalf of the SRS, Podravska Slatina TOS

18     Staff relating to the defence, manpower and other needs.  The commander

19     shall be recalled at the intervention of the SRS War Staff from

20     Belgrade."

21             That's what that document says, doesn't it, and it's dated 24

22     October 1991?

23        A.   I cannot challenge this document, and I cannot confirm it either,

24     but I think that it is not within the setup and function and nature of

25     our War Staff.  As for this Rankic --

Page 12886

 1        Q.   Did I read it correctly, that document?

 2        A.   Well, you read it correctly.  I mean, I think that it is not in

 3     accordance with the nature of the function of the War Staff.

 4             As for this Zoran Rankic, I know that he is a man who is a

 5     craftsman, and he must have worded this clumsily.  He did it just for the

 6     sake of doing it.  He didn't really give any thought to serious matters.

 7     I can claim --

 8        Q.   Well let me show you another document, Exhibit P227.  Now, do you

 9     see in this document, number 3, in which there are conditions for

10     providing assistance, and number 3 is: " ... coordination with our unit

11     command."  Do you see that on this document dated 16 October 1991 from

12     Belgrade?

13        A.   Madam, I can confirm that Mr. Rankic did this clumsily and that

14     this is not in accordance with the powers that he had.  I claim with full

15     responsibility that the Serb Radical Party did not have any military

16     units of its own.

17             Now, this Zoran Rankic, as I said, is a semi-literate person, so

18     how he understood his role, that's his problem.  And after all I know,

19     that he did not stay on the War Staff for very long.  As well as I know

20     him, he is really a man who doesn't understand everything.

21        Q.   Let me direct your attention now to P25, Exhibit P25.  And this

22     document is dated 9 December 1991.  And it's signed by a Chetnik

23     commander of Vukovar, Captain Slobodan Katic.  And it reads:

24             "The Chetnik commander of Vukovar, Slobodan Katic, is proposing

25     the following warriors for promotion."

Page 12887

 1             And one of them listed there is Milan, do you see that one, aka

 2     Kameni, commander.  Did I read that correctly?

 3        A.   Well, you read it correctly, but I'm not the right person to put

 4     these questions to.  I was not at the front.  For example, I never met

 5     Lancuzanin.  Now why they wrote all of this and what this means to them,

 6     I'm not really competent in terms of answering that kind of question.

 7     I can just confirm that we did not have such information.  The Serb

 8     Radical Party did not have any units of its own.  They sent persons there

 9     who were part of the setup of the Serbian army or, rather, the JNA; that

10     is to say, when the composition of the Territorial Defence and later on

11     within the army of the Republic of Serb Krajina, later on the army of

12     Republika Srpska.

13             MS. BIERSAY:  If we could now please see Exhibit P217, and this

14     is order number 124, the proclamation of certain vojvodas.

15             THE ACCUSED: [Interpretation] Objection.  The interpretation was

16     not right.  This is not "naredjenje," this is "naredba."  In the Serbian

17     language, "naredba" and "naredjenje" are two completely different legal

18     documents.  "Naredjenje," "order," is a military term order, whereas

19     "naredba," "order," is a general legal or political act, but at any rate

20     it is at a lower level than a law.

21             JUDGE ANTONETTI: [Interpretation] You've already said this,

22     Mr. Seselj.

23             Witness, you are a literate man.  What can you say about the term

24     to be used in your own language?  Is it a request, a motion, an order?

25     What is it, exactly, in your own language?

Page 12888

 1             THE WITNESS: [Interpretation] "Naredba" is a general act or

 2     enactment regulating a particular matter.  "Naredjenje" cannot be an

 3     individual enactment.

 4             MS. BIERSAY:  If I could direct your attention to number 3 at the

 5     bottom of -- in the B/C/S, it will be page 1.  In the English, it will be

 6     page 2, to the description of Branislav Vakic, second sentence:

 7             "He participated in the liberation of Vukovar as --"

 8        A.   Vakic.

 9        Q.   You recognise that name?

10        A.   The name rings a bell, but I do not know about him being in

11     Vukovar.

12             As for this proclamation of the Chetnik vojvodas, I only watched

13     it on television, like most citizens of Serbia who had occasion to watch

14     this.  Otherwise, I did not take part in this and I do not see any

15     problem in that.

16        Q.   I understand.  Am I reading the last sentence -- the second

17     sentence correctly:

18             "He participated in the liberation of Vukovar as commander of the

19     Leva Supoderica volunteer unit"?

20             And forgive my mangled pronunciation.  Am I reading that

21     correctly?

22        A.   You read it correctly, but I was never at the front-line and I

23     don't know anything --

24             THE ACCUSED: [Interpretation] Objection.  Ms. Biersay did not

25     read it out right.  It says "deputy commander," not "commander."  Perhaps

Page 12889

 1     the witness was not following it carefully.

 2             MS. BIERSAY:  In English, the translation is "commander," and I

 3     read it as "commander."

 4             THE ACCUSED: [Interpretation] Well, this is not the first time

 5     that you have a bad English translation.

 6             JUDGE ANTONETTI: [Interpretation] We know that.  Witness, once

 7     again, you can read, you can write, you can think.  As such, in the

 8     Cyrillic text, is it "deputy commander" or "commander."

 9        A.   "Deputy commander," Mr. President, "deputy commander."

10             JUDGE ANTONETTI: [Interpretation] So "deputy commander."  Very

11     well.

12             Witness, in 1993, some vojvodas were proclaimed.  Back then, were

13     you aware of that or was that an initiative that is solely of

14     Mr. Seselj's account, who did not inform the members of the Serbian

15     Radical Party of it?

16             THE WITNESS: [Interpretation] He provided information.  We knew

17     that that was happening, but I did not take part in that.

18             JUDGE ANTONETTI: [Interpretation] You therefore knew that

19     Mr. Seselj had appointed several vojvodas on account of their records?

20     What is your answer?  I asked you a question.

21             THE WITNESS: [Interpretation] Please go ahead.

22             JUDGE ANTONETTI: [Interpretation] [Previous translation

23     continues]... for you.  Did you know then that Mr. Seselj had appointed

24     vojvodas?

25             THE WITNESS: [Interpretation] Well, I did know that the

Page 12890

 1     appointment and proclamation of them was being prepared, but I did not

 2     take part in that.

 3             JUDGE ANTONETTI: [Interpretation] Very well, thank you.

 4             THE WITNESS: [Interpretation] I beg your pardon.  I was in charge

 5     of organisation and personnel.  I did not have the time or was there any

 6     need for me to take part in all the activities of the party.

 7             MS. BIERSAY:

 8        Q.   Mr. Seselj was a very -- was the highest member of the SRS; is

 9     that correct?

10        A.   Yes.  Yes, correct, he was president, but the Central Fatherland

11     Administration was above him, and the Assembly of the Party.

12        Q.   And with respect to the Serbian Chetnik Movement, he was also at

13     the head of that, as you described to the Trial Chamber previously; is

14     that correct?

15        A.   He was at the head, but I lost touch with the Serb Chetnik

16     Movement when the Serb Radical Party started functioning, and I don't

17     know anything about the Serb Chetnik Movement.  I'm not even sure that it

18     existed and functioned.

19             You know what?  When you're talking about the Serb Chetnik

20     Movement, many people pointed out that they were Chetniks.  Even our

21     enemies --

22        Q.   Just one moment, please.  Before discussing the Serbian Chetnik

23     Movement, my purpose in asking you that was:  In his capacity as the

24     functionary head of these two groups, did he meet with other high-level

25     officials from other parties?

Page 12891

 1        A.   Well, as far as I can remember, Dr. Vojislav Seselj met with the

 2     functionaries of other political parties only in the capacity of

 3     president of the Serb Radical Party, as far as I know.

 4        Q.   And as you described in your statement, he met -- he would meet

 5     with Radovan Karadzic; is that correct?

 6        A.   Yes, he did meet with Radovan Karadzic.

 7        Q.   And did he also meet with Milan Martic, for example?

 8        A.   Well, when I visited the Knin Krajina in the beginning of 1993,

 9     when the battle was being waged at the Medak Pocket, "Medacki Dzep," I

10     met with all the functionaries of the Serb Krajina, but we did not have

11     any special discussion there with regard to some particular units of the

12     Serb Radical Party.  We were interested in the position of the Serb

13     people, whether they had food, whether they were able to engage in

14     economic activity.  We could not be involved in decision-making

15     concerning their military operations, nor did we have any intention of

16     doing so.  We just wanted to help.

17        Q.   So is that a "yes," there were meetings between Mr. Seselj and

18     Martic?

19        A.   Well, I don't know specifically of any particular meeting, but I

20     do believe that there had been meetings.  Well, yeah.

21        Q.   And also, as you described, Mr. Seselj was also in contact with

22     Radmilo Bogdanovic as well; is that correct?

23        A.   Well, with Radmilo Bogdanovic, I was in contact with him too, but

24     these are no contacts that would lead to some special activities.

25     Radmilo Bogdanovic was president of the Chamber of Republics, the Chamber

Page 12892

 1     of Republics in the Federal Assembly, and it is only natural that we were

 2     in contact, especially Dr. Seselj, who was the president of our deputies

 3     club.  He was also in contact with Radoman Bozovic, who was also the

 4     president of the Chamber of Citizens.

 5             MS. BIERSAY:  If I may have one minute, Your Honour.  And in that

 6     time, may I inquire how much time I have left, please.

 7             JUDGE ANTONETTI: [Interpretation] Mr. Registrar.

 8             Fifteen minutes left.

 9             MS. BIERSAY:

10        Q.   I'd now like to move to the topic of the attempted kidnapping of

11     one of your family members.  When did you learn that it, in fact, was not

12     a member of the SRS who had attempted that?

13        A.   I learnt that on the very same day, because my deputy in this

14     newly-established Deputies Club, called the headquarters of the Serb

15     Radical Party and talked about that problem.  I mean, he found out that

16     it wasn't anyone from the Serb Radical Party.  And later on, we checked

17     that again, we asked again, and we were told explicitly that

18     Dr. Vojislav Seselj had been informed and that he condemned this kind of

19     thing, and that it had nothing to do with the leadership of the Serb

20     Radical Party.  These are some self-styled individuals that existed at

21     the front-line and throughout the former Yugoslavia.  Many of them

22     introduced themselves as Chetniks, and they had nothing to do with the

23     Serb Radical Party or with the volunteers of the Serb Radical Party.

24        Q.   Let me ask you this:  I'd like to turn your attention now to the

25     encounter that you described to the Trial Chamber between you and a

Page 12893

 1     member of the OTP, Mr. Saxon.

 2             Now, you have a degree in law; is that correct?

 3        A.   Correct.

 4        Q.   You have been a successful politician in your own right; is that

 5     correct?

 6        A.   I don't consider myself a politician.  I consider myself a

 7     patriot, and there you go, a man of letters, who writes, who is

 8     preoccupied with the fate of his people.

 9        Q.   And let me now again show you 65 ter number 7427A.  That is the

10     document that you previously recognised as being your signature, if you

11     recall.

12             As the Trial Chamber pointed out, the statement that you provided

13     the OTP in 2003, you signed that statement; is that correct?

14        A.   2004, that's when I gave this statement, the end of May.  I

15     signed it, it wasn't read out to me, and it was Mr. Paolo Stocchi who

16     conducted this in a very special way.  He actually used my statement to

17     the effect that I was very grateful to the Italian nation and that I see

18     him as the nephew of the Italian officer who took me out of an Ustasha's

19     hands when I was one year old, and in that way he prevented that Ustasha

20     from killing me with a bayonet.  And on the basis of that, he wrote up

21     whatever he wrote up, and the last day he forced me to sign what he had

22     written up in English.  And then he said that I would be called for

23     further interviews.  And I was already fed up with those that had taken

24     place until then.  He asked me all sorts of things, "Who financed

25     municipal committees," and at one moment I asked him whether he was

Page 12894

 1     asking me these questions as a CIA agent or as an investigator.  He was

 2     completely going beyond the scope of the judiciary.  And he said if I

 3     were to cooperate with anyone, I would cooperate with the Italian.  And

 4     then this other colleague said, "Why not cooperate with the CIA when --"

 5        Q.   My question is simply this:  And I see that you're smiling.  My

 6     question is whether or not you applied your signature and initials to the

 7     pages of the 2003 statement that you gave to the OTP.

 8        A.   In 2003, I didn't give any statements.  It was in 2004, and I

 9     did --

10             MS. BIERSAY:  Can we please zoom in on the signature of 7427A,

11     please - it's at the bottom - to see if this perhaps refreshes your

12     recollection of the date of that first statement.

13        Q.   Are you telling this Trial Chamber that although you're a man of

14     letters and educated in the law, that you signed -- you were forced to

15     sign this?  Is that what you'd have this Trial Chamber believe?

16        A.   I am telling you how it was that I was forced.  As far as I can

17     remember, and I guess I remember well, it was 2004, not 2003.

18             THE ACCUSED: [Interpretation] Objection, objection.  Judges, this

19     paper here is not an integral part of the statement of Mr. Glamocanin.

20     Have the Prosecutor show us the statement that Mr. Glamocanin did sign.

21     What he signed here was a sheet of paper, and in his own hand he wrote

22     out some names.  This is not a signature below the statement.

23             JUDGE ANTONETTI: [Interpretation] Let's not waste any time.  I've

24     already asked questions on this topic.  The Prosecution thinks it's

25     necessary to return to the topic.  I don't see the point in doing so.

Page 12895

 1             But have you signed, in your own language, a statement made in

 2     Serbian?  Answer by "yes" or "no."

 3             THE WITNESS: [Interpretation] No, no, not in Serbian, no, no way.

 4             JUDGE ANTONETTI: [Interpretation] You signed a statement in

 5     English?

 6             THE WITNESS: [Interpretation] In English, Mr. President.

 7             JUDGE ANTONETTI: [Interpretation] Thirdly, you signed the

 8     document we see in front of us on the 30th of May, 2003?

 9             THE WITNESS: [Interpretation] Mr. President, how could I

10     challenge my very own signature?  But I don't remember this.

11             JUDGE ANTONETTI: [Interpretation] But you can see there's a

12     signature, there is the date in front of you.

13             THE WITNESS: [Interpretation] Well, I see it, but I can't

14     remember.  I guess it's a question of age, too, if I can't remember

15     everything.  So many things have happened, I really don't know.  I am

16     familiar with all these names.  We did cooperate.

17             JUDGE ANTONETTI: [Interpretation] Madam Biersay.

18             MS. BIERSAY:  Thank you, Your Honour.

19        Q.   Previously, you described to the Trial Chamber that Mr. Seselj

20     did not talk about genocide.  Did Mr. Seselj talk about the genocide of

21     the Serbian people in his speeches?

22        A.   Well, yes, he did.  He spoke about the genocide that took place

23     in World War II.  Well, the Ustashas killed a million Serbs during the

24     Second World War.  And there was genocidal killings of Serbs in 1991,

25     too, in July and August, in Western Slavonia, for instance, and the area

Page 12896

 1     of Vukovar.  There were such phenomena.  They occurred in Gospic, too.

 2     And as far as our nation is concerned, it is a terrible -- it's terrible

 3     to know that the genocide of World War II is repeating itself.

 4        Q.   And didn't Mr. Seselj advocate the retaliation for crimes he says

 5     were committed against Serbs in World War II?

 6        A.   Seselj never did that.  Seselj claimed and especially stressed

 7     that we must not believe the Ustashas and pro-Ustasha forces and

 8     pro-Ustasha authorities in Croatia, just like the Serbs believed in 1941.

 9     Quite simply, our people were led to churches, incarcerated there, set

10     alight there; they were burnt there.  Then they were killed in their

11     masses in the most atrocious ways.  And they responded to the new

12     Croatian Ustasha authorities and said, "Well, why are we to blame?"  It

13     wasn't a question of why were they to blame or not, but the fact is that

14     they weren't to blame for anything, it's just that they were Serbs and

15     Orthodox.  And now this was repeated with the programme and all the

16     various signs and insignia, and the intimations of new Croatian politics

17     of the HDZ led by Franjo Tudjman.

18             MS. BIERSAY:  At this time, the Prosecution has no further

19     questions, Your Honour.  Thank you.

20             JUDGE ANTONETTI: [Interpretation] Very well.

21             Time is of the essence.  Mr. Seselj, maybe you can start your

22     cross-examination, but the Trial Chamber has one thing to tell you

23     beforehand.

24             You told us, and we thank you for that, that you intend to use a

25     book which has been published and which gave rise to confidential written

Page 12897

 1     submissions made by the Prosecution.  If you use this book only as far as

 2     the SRS is concerned and the role played by the witness in the SRS,

 3     that's fine, but the Trial Chamber is prohibiting you from using this

 4     book in order to reveal the name of a protected witness.  You have to

 5     understand that you can only use this book in order to put questions to

 6     the witness regarding the SRS, Greater Serbia, and maybe other things,

 7     but not to reveal names of witnesses.  And to avoid controversies, the

 8     Trial Chamber is also asking you not to mention the title of this book,

 9     because as we already said, this is irrelevant.

10             My fellow Judge would like to add something.

11             JUDGE LATTANZI: [Interpretation] I'd like to add, as far as I'm

12     concerned, it's my opinion that I am stating here, that you are not

13     entitled to use the excerpts of this book where you make reference to the

14     witness we have here today, because when you wrote the book, this witness

15     was a protected witness.  So the -- so this crime of contempt is being

16     tried by another Trial Chamber, and I believe you cannot use these

17     excerpts for this reason.

18             THE ACCUSED: [Interpretation] Madame Lattanzi, I always liked

19     your ability to think logically, but now you have surpassed yourself and

20     you have even put Hagel upside down, stand on his head.

21             This statement of Mr. Glamocanin's was confidential until today.

22     And since Mr. Glamocanin came into the courtroom and said he was

23     testifying publicly, this is no longer confidential, and that relates to

24     all of Mr. Glamocanin's statements.  And as I respect your ability to

25     think logically, I do, but I can't accept that.  On the one hand, I

Page 12898

 1     respect you immensely, and on the other, I have complete resistance to

 2     that from the very insides of my being, and then you can stop me from

 3     cross-examining, if you like.

 4             But what I wanted to say is this:  I informed Ms. Biersay that I

 5     was going to cross-examine only on the basis of those passages which

 6     relate to Mr. Glamocanin, and I said that was from page 68, onwards some

 7     20 to 25 pages; but that's not essential, and she has it all.

 8             Thirdly, Judges, when two or three months ago I submitted a

 9     request to the Trial Chamber to stand up and protect Defence witnesses, I

10     added to that at least 18 witness statements where I said that the

11     Prosecutor was trying to seize them away from me; and they've all been

12     translated into English, my submissions and the attachments.  You

13     rejected my submission, but you are aware of the statements.  You have

14     them in English.  And now I insist that I be allowed to use all the

15     statements which have to do with Mr. Glamocanin, and they are statements

16     which he gave to my associates.

17             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I do not know what

18     is in your book.  We did not read it.  We only saw the cover page.  We do

19     not know what is in the book.

20             It is true that this witness is no longer protected as of today,

21     and therefore what he said or wrote is public.  And I note that he has

22     written a great number of books.  He's given a great number of

23     interviews.  He's a public figure.  He's a well-known person.

24             Now, in the book you wrote, I assume you are referring to things

25     that this person might have written or said.  It might be useful to say,

Page 12899

 1     "Witness Glamocanin said this or that at one point in time," as long as

 2     it does not reveal the name of protected witnesses.  The position of my

 3     fellow Judge is her own opinion.  She is raising a legal question.  She

 4     is of an opinion, and I'm of a different opinion; and since we have no

 5     jurisprudence when it comes to the Appeals Chamber regarding this, we are

 6     in the dark.

 7             In order to bypass this difficulty, if in this book there are

 8     excerpts where the witness talked about the SRS, the role you played in

 9     Vukovar, you can say, "In the book, I wrote you said this or that.  Do

10     you confirm it?  Do you maintain it?  Yes or no?"  This is not going to

11     jeopardise anything.  What do you want to say, we'll see as we go.  If

12     the Trial Chamber believes that it is jeopardising something, we'll

13     redact.

14             But so far this is a very theoretical debate.  I have no idea

15     about the questions you are going to ask, so please proceed and we'll see

16     as we go.

17             JUDGE LATTANZI: [Interpretation] I just wanted to add one thing.

18             My problem is quite different from what Mr. Seselj and the

19     Presiding Judge are saying.  It's not the problem of confidentiality, the

20     fact that the protective measures were granted and are no longer there

21     and have been lifted.  That's not it.

22             The issue is that it's the book as it is, because if there are

23     some excerpts dealing with this witness are quoted, because this witness

24     was protected when the book was written, this will mean that it must be

25     investigated by another Trial Chamber in order to know whether, having

Page 12900

 1     revealed the status of this witness at the time was correct or not, and

 2     whether this is contempt, "yes" or "no."  So that's a bit of a different

 3     problem.

 4             That's my opinion.

 5             JUDGE ANTONETTI: [Interpretation] Have you understood,

 6     Mr. Seselj?

 7             THE ACCUSED: [Interpretation] Judge Lattanzi, whether I committed

 8     contempt of court or not has nothing to do with these proceedings and the

 9     examination of this witness.  Apart from the fact whether an accused can

10     be held in contempt of court, that will have to be looked into, and then

11     all the rest of it.

12             But, anyway, this witness gave a statement to my associates, and

13     he gave permission that may be disclosed to the public.  When the book

14     was published, this witness received a copy by the author of this book,

15     and he came to speak at the public promotion of this book in the large

16     hall of the trade union building in Belgrade.  So he was there publicly.

17     There were 3.000 people there, and he spoke about this book in public.

18     It was a public event.

19             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, if I understood you

20     correctly, and we need your help here because we don't know what's in the

21     book, you say this witness made written statements to your associates.

22     There are statements, I guess that they have been certified by the

23     competent court. (redacted)

24     (redacted)

25     (redacted) And you

Page 12901

 1     want to use this book in order to confirm statements made to your

 2     associates, but why don't you just use the statement made to the

 3     associates instead of going through the book?

 4             THE ACCUSED: [Interpretation] Mr. President, I provided you with

 5     those statements directly three months ago.  I haven't got them now

 6     because I threw that paper away.  It's easier for me to keep it in one

 7     small book rather than having a whole pile of papers to carry around,

 8     because I have too much of that already.  I don't have to rely on this at

 9     all.  I'll rely on its contents, and I have almost all the contents in my

10     head.

11             And you're very well aware of another thing, Judges.  Several

12     months ago, when I mentioned the title of this book for the first time

13     and when we moved into private session because of that and redacted the

14     transcript, every subsequent time that I mentioned the book, I said, "I'm

15     not going to say the title of the book," to avoid going into private

16     session, so there's no need for you to caution me on that score.

17             Now, we've only got four minutes left.  Is there any sense in me

18     starting my cross-examination with just four minutes?  I was quite ready

19     to cross-examine if I had 10 or 20 minutes, but is there really any sense

20     in me starting when there's just four minutes?

21             JUDGE ANTONETTI: [Interpretation] Very well.  It's best you begin

22     your cross-examination tomorrow.

23             The Trial Chamber will allow you to refer to the statements, but

24     you are not to give the title of the book.  I believe you agree on this.

25     You can say, "In the statement in this book, Witness, you said this or

Page 12902

 1     that.  Please explain."  All three Judges agree on this procedure.

 2             THE ACCUSED: [Interpretation] Mr. President, you see how much I

 3     respect those decisions of yours.  And when I intimated to Ms. Biersay

 4     that I would be using the book, I didn't even give the title then.  I

 5     just said, "I'll use this nice book," [In English] "I'll use this

 6     beautiful book." [Interpretation] Those were my words when I informed

 7     her.  I didn't want to state the title then to avoid Ms. Dahl hearing who

 8     was present there.  So you see how scrupulous I am.

 9             JUDGE ANTONETTI: [Interpretation] It's Trial Chamber is noting

10     that your English has greatly improved, and this will help us move

11     forward.

12             Mr. Seselj, we will resume tomorrow at 8.30.  You will have one

13     hour, and I hope everything will run according to plan.  Afterwards,

14     Judges might have some additional questions.  I don't know yet.  My

15     fellow Judge is already hinting at questions that he might have -- that

16     he will have.  Then we'll finish with this witness, and then we have

17     another witness scheduled, 92 ter witness.  So that's the programme for

18     tomorrow.

19             Witness, you are under oath at the moment, since you made the

20     solemn declaration.  You are not entitled to contact anyone from the OTP

21     or to have contact with Mr. Seselj, but that would be quite difficult for

22     you.  Please avoid contacting the press also.  If a reporter calls you to

23     ask you what your impressions are so far, just tell him that you will go

24     public later, after tomorrow, because as of now you're still in the hands

25     of justice.  And you are a lawyer, so you know exactly what I am talking

Page 12903

 1     about.

 2             That's it.  We will meet again tomorrow at 8.30 a.m.  Let's

 3     adjourn.  Thank you.

 4                           --- Whereupon the hearing adjourned at 1.15 p.m.,

 5                           to be reconvened on Thursday, the 11th day of

 6                           December, 2008, at 8.30 a.m.