Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12904

 1                           Thursday, 11 December 2008

 2                           [Open session]

 3                           [The witness entered court]

 4                           --- Upon commencing at 8.32 a.m.

 5                           [The accused entered court]

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

 7     call the case.

 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, Registrar.

14             This is Thursday, December 11, 2008, and I welcome all

15     representatives of the OTP, Ms. Dahl, Ms. Biersay, their case manager.  I

16     welcome our witness, and I greet Mr. Seselj and everyone helping us.

17             Mr. Seselj is about to continue with his -- is about to start

18     with his cross-examination.  You have the floor.

19             THE ACCUSED: [Interpretation] Mr. President, I meant to do that

20     at the end - I assume we'll have time - but I want to start my

21     cross-examination straight away, if I may, if you have nothing against

22     it.  I can of course do it now, but I'd prefer to do it later.  If you

23     insist, I'll do it straight away.

24             JUDGE ANTONETTI: [Interpretation] Please proceed with your

25     cross-examination, and then we will deal with pending questions.

Page 12905

 1             THE ACCUSED: [Interpretation] Very well.

 2                           WITNESS:  JOVAN GLAMOCANIN (Resumed)

 3                           [Witness answered through interpreter]

 4                           Cross-examination by Mr. Seselj:

 5        Q.   Mr. Glamocanin, when you decided to be a Defence witness, you

 6     gave several statements to my legal advisers; right?

 7        A.   Yes, that's right.

 8        Q.   In one of those statements, you set out, in detail, the first

 9     pressure exerted upon you to give false testimony against me, and that

10     was pressure exerted by Zoran Djindjic; right?

11        A.   Yes, that's right.

12        Q.   You described how a man called you up on the phone and said he

13     was somebody from his offices, a man called Markovic, and conveyed the

14     message that Djindjic wished to talk to you?

15        A.   Correct.

16             THE ACCUSED: [Interpretation] Judges, you have that statement

17     attached to my submission three months ago, when I asked for --

18             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

19             MS. BIERSAY:  If we could have the date of that statement,

20     perhaps it would assist us.

21             THE ACCUSED: [Interpretation] Of course, certainly.  It's the

22     statement of the 11th of August, 2008.  You have it in that set of

23     statements that I attached to my submission with the request that Defence

24     witnesses be protected, and that's been translated into English, too.

25        Q.   You said there that you were surprised, firstly, and then that

Page 12906

 1     you agreed to talk, and then that this meeting was scheduled for -- or,

 2     rather, somewhere in Kosutnjak; right?

 3        A.   Yes, in the Kosutnjak forest.  Well, that's not where the talk

 4     was supposed to take place, but it was said that I should come to the

 5     Federal Assembly in Belgrade and then go to Zoran Djindjic and have a

 6     talk.

 7        Q.   Now, this Kosutnjak area, what facility was that?

 8        A.   Well, there is no facility.  It's just a park.

 9        Q.   So you were outside in the park?

10        A.   Yes.  That's a nice part of Kosutnjak.

11        Q.   You knew Zoran Djindjic from before?

12        A.   Well, I never met him, but I knew him as a public personage.

13        Q.   You would see him in the Assembly, in the Assembly halls, I

14     assume.

15        A.   Yes.

16        Q.   And he greeted you there as if you were an old friend?

17        A.   Precisely.

18        Q.   Tell me now, please, because I don't want to ask a leading

19     question so as to make what I have to say more convincing, what did

20     Zoran Djindjic say to you straight away, when he saw you?

21        A.   Zoran Djindjic said that we should stabilise the new government,

22     that it was a government supported by the West, and that the West was

23     ready to invest a large amount of money into Serbia, and that that was

24     the only way out for Serbia, but that the strengthening of power in

25     Serbia had an obstacle, a serious obstacle, and that was

Page 12907

 1     Dr. Vojislav Seselj and the Serbian Radical Party, and that we should

 2     suppress Dr. Vojislav Seselj and that we should marginalise the Serbian

 3     Radical Party.  And once that is achieved, then the government and powers

 4     in Serbia will be stable.  And he also said, just like all the rest of

 5     them, that Dr. Vojislav Seselj was far more dangerous than Slobodan

 6     Milosevic, and the Serbian Radical Party was more dangerous for

 7     pro-Western policy than the Socialist Party of Serbia.

 8        Q.   And he was quite right in saying that, wasn't he?

 9        A.   Well, he was right, inasmuch as you, as a politician, as a

10     leader, were more consistent in waging your policies and politics on the

11     basis of a party programme, on the basis of your visions, on the basis of

12     your ideology and convictions, and on the basis of the fact that you

13     entered politics to do something for your own people and not to pilfer

14     the country, as the other structures in power were doing from Djindjic to

15     the present day.

16        Q.   And the West doesn't like the pro-Russian policies of the Serbian

17     Radical Party?

18        A.   Absolutely.

19        Q.   Did he also say that?

20        A.   Yes, he did.

21        Q.   And what did you tell him?  He knew that you were in conflict

22     with me and the Serbian Radical Party and had been for a number of years?

23        A.   Well, he wanted to use that and to use me to keep you at arm's

24     length, you and the Serbian Radical Party.  Now, he suggested various

25     things to me, and in return he would provide a good life for me.

Page 12908

 1        Q.   And did any possible war crimes on my part or on the part of the

 2     volunteers of the Serbian Party, were they ever mentioned?

 3        A.   Well, not specifically.  No specific crimes were mentioned, or

 4     events.  It was more in general terms that it was the policy and politics

 5     waged by Dr. Seselj, his ideology, that it was in fact a war ideology,

 6     and that that kind of ideology and the policies waged by you were an

 7     obstacle to the West, and that that kind of politics and ideology should

 8     be suppressed.

 9        Q.   Does that mean that he had some firm arguments to disqualify me

10     and the Serbian Radical Party?

11        A.   Well, no, he didn't, in my opinion, have any firm arguments.  All

12     that was needed -- or, rather, he needed people who would serve his

13     purpose, the purpose of some invented, fabricated policy with some

14     nonexistent proof, false proof and evidence.  That's how I understood his

15     intentions.

16        Q.   Does that mean that one had to morally disqualify me by inventing

17     things and presenting fabrications?

18        A.   Yes, probably.

19        Q.   That's not the first time that the regime in Serbia tried to

20     discredit me in that way; isn't that right?

21        A.   Well, the Slobodan Milosevic regime did that too.

22        Q.   On several occasions?

23        A.   Yes.

24        Q.   What did you tell Djindjic?

25        A.   I told him that I couldn't act against my convictions, I was --

Page 12909

 1     that I didn't agree with everything Dr. Seselj was doing or the Serbian

 2     Radical Party, but that I could not take part in a campaign of that kind

 3     and conduct of that kind.  That was unacceptable, as far as I was

 4     concerned.  I didn't enter politics to be a politician at all cost.  I

 5     entered politics on the basis of my convictions and on the basis of my

 6     deep psychological and moral need to help my own people.

 7        Q.   And what was Djindjic's reaction to that?

 8        A.   Well, Djindjic reacted fairly violently.  He said, "What

 9     patriotism, what convictions?  We have to work for the state.  Leave all

10     that behind.  You should see how you're to survive, how you're going to

11     live.  I know that you have a very modest pension and that you deserve

12     more and can do more."  And then he asked that I call him again in a

13     week's time to arrange our cooperation and see how we were going to

14     cooperate.

15        Q.   And did you call him up ten days later?

16        A.   No.  I considered Djindjic, although he is dead now, I think he's

17     a criminal hooligan and I think he's somebody without any credibility

18     whatsoever and not capable of heading the government of a state.

19        Q.   What happened afterwards, when you refused to call him up?

20        A.   Well, then on the 7th of May they took me into the headquarters

21     of the special police or people from the State Security, as they

22     introduced themselves.  They interrogated me without stop for 20 hours.

23        Q.   And what did they insist upon?

24        A.   Well, they insisted upon the fact that I had received a bribe of

25     some kind.  They showed me a disc of some sort, a CD, in which I gave my

Page 12910

 1     associates, among deputies, me providing documents for the pre-electoral

 2     campaign and activities, and me giving them some money, some of the party

 3     money.  Now, that was the time before the elections, just before the

 4     elections, because they were held in September, and this all happened --

 5     my meeting, that is, with my associates took place sometime at the end of

 6     July.  What we wanted to do was to prepare in advance for the elections

 7     and on time.

 8        Q.   Tell me, did they make ultimatums and say that if you didn't

 9     agree to cooperate against me, that you would be taken to court and legal

10     proceedings taken against you?

11        A.   Well, not everybody, but, yes, they did, a number of them did.

12     And I think one of them was the main person there.

13        Q.   One of those agents, did they tell your wife something on that

14     occasion when they ransacked or searched your flat?

15        A.   Yes.  That agent, at the time when they were waiting to take me

16     into the police station on the first day, on the 7th, I think, that was

17     the day after my patron saint's day, family patron saint's day, I was not

18     in my flat.  They entered the flat, the three of them, and one of them --

19     well, later on we learned that that was the Chef de Cabinet of the chief

20     of State Security of Serbia, and he said that they had been directly

21     sent -- they were there on orders, direct orders from Zoran Djindjic to

22     take me into custody.  And they said the same thing from the State

23     Security, those people said the same thing in Pancevo, the State Security

24     in Pancevo, who two days later searched my mother-in-law's flat in

25     Pancevo, and they also said that that was something directly demanded by

Page 12911

 1     Zoran Djindjic, and that he was -- they were told that by the head of the

 2     State Security Department for Pancevo.

 3             JUDGE HARHOFF:  Mr. Glamocanin, could you, just for the record,

 4     tell us which date did you receive the first call from Mr. Djindjic, and

 5     when did you subsequently meet up with him?

 6             THE WITNESS: [Interpretation] Judge, Your Honour, that was in

 7     mid-April.  I don't remember the exact date, but I do know that it was

 8     sometime around midday, around noon, and that this man, Mr. Markovic,

 9     said he'd call me that day and that he'd tell me when Mr. Djindjic would

10     receive me.  But he didn't call up that day; he called the following day

11     at 11.00, and then we arranged to meet in the afternoon, at around 1600

12     hours.

13             JUDGE HARHOFF:  What year?

14             THE WITNESS: [Interpretation] Oh, yeah, 2001, when he came into

15     power, immediately, this new government that overthrew Slobodan Milosevic

16     and his government.

17             JUDGE HARHOFF:  Thank you.

18             MR. SESELJ: [Interpretation]

19        Q.   Well, Djindjic's government, as far as I remember, was formed in

20     January 2001.  Is that right?

21        A.   Yes.

22        Q.   The elections were at the end of December 2000?

23        A.   Correct.

24        Q.   And then Zoran Djindjic became the prime minister?

25        A.   Right.

Page 12912

 1        Q.   And that's when the fierce clashes began straight away between

 2     the ruling coalition and the Serbian Radical Party?

 3        A.   Correct.  They undermined or, rather, abused the consistency of

 4     the Serbian Radical Party, who in following the electoral results to the

 5     very end, informed the public very correctly on the results.

 6        Q.   Do you remember that at the time, it was -- in Parliament, they

 7     prevented us from taking the floor and stating our views from the

 8     rostrum, and that they threw us out of the Assembly, they made us pay

 9     fines, the police hustled us out, and all that was in this campaign to

10     keep the Serbian Radical Party quiet?

11        A.   I understood it that they had come into power, but that they had

12     seen that there were a lot of problems facing them in setting up

13     government and successfully leading the state, and then they wanted to

14     marginalise and silence the only party that had a strong voice.

15        Q.   Do you remember that the leading people in Djindjic's regime

16     accused me publicly that I engaged in crime and abused my position as the

17     vice-premier and so on and so forth?

18        A.   Yes.

19        Q.   Did they manage to find a single shred of evidence for that

20     serious allegation of theirs?

21        A.   As far as I know, no, they didn't, and they couldn't.

22        Q.   Do you remember that there was just one criminal report filed

23     against me at that time, a single one, a criminal report, because as

24     vice-premier, I signed a government decision that part of the money from

25     the fund for assistance to earthquake-stricken areas should be

Page 12913

 1     rechanneled to those suffering from floods, because in the summer of 1999

 2     we had a lot of floods in Central Serbia?

 3        A.   Yes, I do remember that.

 4        Q.   And then they gave up on that criminal report and having

 5     proceedings taken further?

 6        A.   Well, I know that nothing -- it wasn't taken up afterwards.

 7     Nothing actually happened.

 8        Q.   But there were many other criminals reports filed against me and

 9     procedure taken for slander, because they said I had attacked ministers,

10     Prime Ministers accused of being involved in various affairs and so on

11     and so forth; do you remember that?

12        A.   Yes, I do, because from the very beginning when the authority and

13     the new government was set up in Serbia, I knew that they were people of

14     doubtful -- well, we didn't know where their riches came from, and

15     recently a paper in Serbia wrote about the disillusionment of the head of

16     the American CIA in the protagonists of the new government in Serbia.  In

17     fact he was criticising with his associates who had brought into power in

18     Serbia just pure criminals and people who were incapable and thereby

19     compromised the policies and politics of the West.

20             THE INTERPRETER:  Could the speakers kindly be asked to slow down

21     and speak one at a time.

22             THE ACCUSED: [Interpretation]

23        Q.   Do you remember that the Congress in America published public

24     information that in 2000, in toppling Milosevic, they invested $150

25     million, the Americans?

Page 12914

 1             JUDGE ANTONETTI: [Interpretation] Witness, you are speaking too

 2     fast, and the interpreters are having a difficult time keeping track with

 3     you.  Please slow down.

 4             THE WITNESS: [Interpretation] I remember, Mr. Seselj, that that

 5     had been discussed, but I forgot the figure.  But as for now, there is

 6     this one figure in relation to your position as president of the Serb

 7     Radical Party.  That's one that I know for sure; namely, the Americans,

 8     through their intelligence services, provided $100 million to

 9     Tomislav Nikolic and Vucic, and the tycoons of Serbia gave the rest in

10     order for the figure to be 300 million Euro.

11             MR. SESELJ: [Interpretation]

12        Q.   Quite frankly, I have to tell you that the figure seems to be a

13     fantastic one to me.

14        A.   It's not fantastic.

15             MR. SESELJ: [Interpretation] I'm not prone to believe it.

16             JUDGE LATTANZI: [Interpretation] I apologise, Witness, but when

17     did this happen, what you say allegedly happened with the Americans?

18     When did it happen?

19             THE WITNESS: [Interpretation] In relation to Tomislav Nikolic,

20     that happened this year, and --

21             JUDGE LATTANZI: [Interpretation] Then it's not relevant.

22             THE WITNESS: [Interpretation] All right.  Then I will give

23     decided questions [as interpreted] to Mr. Seselj's questions.

24             MR. SESELJ: [Interpretation]

25        Q.   Do you know that from 1990 onwards, the Americans were financing

Page 12915

 1     the pro-Western opposition in Serbia?

 2        A.   I do know that, because for the most part it was Vuk Draskovic

 3     who took part in that.

 4        Q.   But the Democratic Party; right?

 5        A.   Well, the Democratic Party, but just one wing.  I mean, the part

 6     of the party that consisted of Kosta Cavoski, Marko Jankovic and Vojislav

 7     Kostunica and others did not take part in this.

 8        Q.   Soon they left the Democratic Party?

 9        A.   Yes, they did, just like many socialists left who had been

10     founding members of that party, people of integrity, of convictions, who

11     were in favour of a modern socialist party, of a pro-European profile.

12     All of them left the Socialist Party, and it was mostly criminals who

13     took over that party.

14        Q.   Now came May 2003, and you were called in to the Belgrade office

15     of The Hague Tribunal; right?

16        A.   I don't know.

17        Q.   Where was that?

18        A.   I think it was 2004.  But if you're saying "2003" --

19        Q.   On your alleged statement, it says 2003.

20        A.   Well, I don't know, I think it was 2004, but it doesn't really

21     change things, it doesn't change the essence.  First from The Hague, some

22     Philip Petrovic called me, and he connected me with someone from the OTP,

23     I no longer remember the name.  And then that person said to me with --

24     through the interpretation of Mr. Petrovic, that I had to enter a

25     cooperation with the representatives of the OTP in Belgrade and that I

Page 12916

 1     should make a statement.  And when I asked in what capacity should I make

 2     a statement, as an accused person or a witness, they said, "It doesn't

 3     matter, but you have to cooperate."  That happened on the 4th of May,

 4     just before my patron saint's day.

 5             And about ten days later, I don't know exactly how many days

 6     later, a person called me from The Hague Tribunal, I mean Paolo Stocchi.

 7     Again, of course, he spoke through an interpreter, and he said that I had

 8     to come to the offices of The Hague Tribunal in Dedinje.  I went on the

 9     day that was agreed upon, and I spent four days there.

10        Q.   All right.  Tell me, here in the statements, it says that there

11     were two persons who took part in this meeting, Philippe Oberknezev and

12     Paolo Pastore-Stocchi?

13        A.   I don't know what the name of the other person is.  He just said

14     that he was a Frenchman of Russian origin.

15        Q.   Did Philippe Oberknezev speak Serbian?

16        A.   No.  Well, he didn't show any knowledge.

17        Q.   He didn't show that he was of Serb origin?  He claimed that he

18     was of Russian origin?

19        A.   He said that he was a Frenchman of Russian origin.

20        Q.   Did you hear of Milos Oberknezevic?

21        A.   No.

22        Q.   Let me remind you.  You are an educated person.  When Pavelic

23     looked at the remaining Serb -- Orthodox Serbs in the so-called

24     independent state of Croatia, when he wanted to set up an Orthodox

25     Church, he appointed a Russian emigre as the patriarch and Milos

Page 12917

 1     Oberknezevic was the number two man of that church.  He was a

 2     metropolitan priest.  Do you remember that?

 3        A.   Yes, I remember that activity of the Ante Pavelic and the

 4     Ustashas.

 5        Q.   Right.  So I have no proof that this Philippe Oberknezev is

 6     related to Milos Oberknezevic, but since this is a very rare surname,

 7     it's symptomatic, isn't it?

 8        A.   I agree.

 9        Q.   Since it's symptomatic, let us leave it aside for the time being.

10     Right.

11             Now, this interview that went on for four days, how long did it

12     go on during the course of one day?

13        A.   From 9.00 until 5.00 or 6.00 in the evening.

14        Q.   Eight or nine hours a day?

15        A.   Yes.  On that day, it was a bit shorter, but it was regular

16     working hours and even longer than that.

17        Q.   More than 30 hours; right?

18        A.   That's right.

19        Q.   And after these exhausting interviews, you could hardly wait for

20     them to be over?

21        A.   Of course, because Paolo Stocchi made it seem that I would be

22     interrogated even further.

23        Q.   That's when you signed what they gave you to sign in English;

24     right?

25        A.   Yes.

Page 12918

 1        Q.   And yesterday you said that they never read it out to you in

 2     Serbian?

 3        A.   They didn't, and I didn't ask for it either.  I just wanted for

 4     it all to be over as soon as possible.

 5   (redacted)

 6     claims that she read it back to you in the Serbian language.

 7        A.   I don't remember that her name was Dana.

 8        Q.   And what really matters to me is she did not read it back to you,

 9     and what her name was doesn't matter at all.  All right.

10             Now, tell me, please, during that conversation, both Stocchi and

11     Oberknezev for the most part insisted on my moral disqualification;

12     right?

13        A.   Right.  I quickly convinced them that I did not know about any

14     war crimes, that I was not at the front-line, that I did not participate

15     in the war, and that I really did not know about any kind of war

16     crimes --

17             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

18             MS. BIERSAY:  Your Honour, we are at this time requesting that

19     the name of the interpreter be redacted.  I understand that it's

20     considered sensitive in Belgrade, so I've been informed.

21             THE ACCUSED: [Interpretation] Very well.  That is not a sensitive

22     issue at all in Belgrade, and there is no reason to redact it.  No

23     official of The Hague Tribunal in Belgrade ever had any kind of personal

24     problems.

25             JUDGE ANTONETTI: [Interpretation] Let me consult with my fellow

Page 12919

 1     Judges.

 2                           [Trial Chamber confers]

 3             JUDGE ANTONETTI: [Interpretation] After deliberating, the Trial

 4     Chamber decides to redact the name.  It's irrelevant, anyway.  It's

 5     irrelevant when it comes to the issue.  And so at line 20, please, line

 6     24, page 14, please redact.

 7             THE ACCUSED: [Interpretation] You know what the problem is there,

 8     Judges?  You redact one name, and indeed that name is deleted from the

 9     transcript.  That's no problem.  However, on the recording, the Registry

10     deletes an entire passage.  From the video clip, the Registry does not

11     redact only that name but an entire section of the hearings, and then the

12     public is denied the opportunity to view the entire proceedings.  And

13     that is why I complain this much about redactions.

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, as far as redaction

15     is concerned, I sign an order and the name is deleted.  All the rest

16     remains.  You're saying that there is more that is deleted than just the

17     name, but I'll check, because normally the name is deleted and all the

18     rest stays unchanged.

19             Proceed.

20             MR. SESELJ: [Interpretation]

21        Q.   What I see here is that they tried to carry this slander out in

22     two different ways; by providing information that I had lots of money and

23     that I got it in an illegal way, and, secondly, that I was linked to

24     various killings.  Right?

25        A.   That's right.

Page 12920

 1        Q.   You mentioned that in 1992 and in 1993, we had a certain number

 2     of sponsors, but I hope that you will agree with me that, for the most

 3     part, these were small-scale sponsors.

 4        A.   Well, it was that truck of fuel that was the biggest piece of

 5     sponsorship.

 6        Q.   Do you remember that in 1992 and 1993, Serbia and the Federal

 7     Republic of Yugoslavia were under an embargo?

 8        A.   I remember.

 9        Q.   Do you remember that there was no gasoline at the gasoline

10     stations?

11        A.   I remember.

12        Q.   Do you remember that we had to make do in order to get each and

13     every jerry can of gasoline in order to be able to travel through Serbia?

14        A.   Correct.

15        Q.   You mentioned this company that was headed by Petar Vujasinovic?

16        A.   Yes.

17        Q.   I was surprised here when you said that he was involved in export

18     and import.

19             THE INTERPRETER:  Interpreter's note, it is too fast for

20     interpretation.

21             MR. SESELJ: [Interpretation]

22        Q.   [No translation].

23        A.   [No translation].

24             THE INTERPRETER:  Interpreter's note, a significant passage is

25     missing.  It was too fast for interpretation and for the court reporter.

Page 12921

 1     Thank you.

 2             JUDGE ANTONETTI: [Interpretation] Hold on.  You're too fast.  The

 3     court reporter can't follow, can't keep track.  Therefore, he stops

 4     everything.  Please continue.

 5             THE ACCUSED: [Interpretation] I am going to slow down, but time

 6     is always somehow too short for me, and I want to achieve as much as

 7     possible within a single hour.  So I don't even feel it, but I really

 8     speed up.

 9        Q.   Now, you said yesterday that Stocchi insisted that I had property

10     that was valued at $50 million US?

11        A.   Well, he insisted on that, but I found that to be fantastic.

12        Q.   Mr. Glamocanin, now, let's see, where could this property

13     possibly be?  If it is immovable property, it cannot be hidden at all?

14        A.   It cannot.

15        Q.   You cannot hide real estate and that kind of big money?

16        A.   Exactly.

17        Q.   Let's look at bank accounts now.  Can it be hidden in any way?

18        A.   No.  As a person accused in The Hague --

19        Q.   Every bank transaction can easily be traced?

20        A.   Right.

21        Q.   Thirdly, if it is in cash, you know that what is in circulation

22     now are bank notes of $100?

23        A.   Right.

24        Q.   There are no bigger bank notes in circulation.  A few decades

25     ago, the Americans printed bills of 1.000, 5.000, 10.000, but then they

Page 12922

 1     were quickly withdrawn?

 2        A.   Exactly.

 3        Q.   So it would mean 500.000 bills of $100?

 4        A.   Right.

 5        Q.   It's a truckload, then?  If it were all to be tied up in bundles,

 6     that would be 5.000 bundles; right?

 7        A.   That's right.

 8        Q.   Now, for these 5.000 bundles to be loaded into these regular

 9     briefcases, you'd need 50 briefcases, because one can take about 10?

10        A.   Your math is right.

11        Q.   So you don't really need a truck, but you would need one of those

12     small trucks or vans to carry that around.  So this is something that

13     sounds truly fantastic, and nevertheless they insisted that this be

14     included in your statement.  Why?

15        A.   Well, they wanted to get me involved in this against you in every

16     conceivable way, to show that you were a person who was prone to crime,

17     that you were a violent person, a person who is not fit to be in

18     politics.

19        Q.   You see, it also says here that my wife, Jadranka Seselj, owns an

20     export/import company.  Do you know that when my wife, Jadranka, married

21     me, she was immediately laid off, dismissed, from the company where she

22     had worked until then?

23        A.   I really don't know about your lady wife.

24        Q.   If she really had a company, somebody would have known about

25     this, they'd have a document?

Page 12923

 1        A.   Well, all the opposition parties would do that.

 2        Q.   Well, only perhaps it would be possible if my wife was engaged in

 3     some kind of business on the side, without me knowing it, and now Paolo

 4     Stocchi is helping me do that?

 5        A.   I think your wife is an honourable person and she really wouldn't

 6     do anything without you knowing it.

 7        Q.   The Hague Tribunal would want me to be suspicious of my wife and

 8     to ask for part of the profits of this company.

 9        A.   The Hague OTP or, rather, someone from the OTP is looking at all

10     possible ways and means of presenting you as a bad person who is working

11     against the interests of the Serb people.

12        Q.   Now, these accusations that I was involved in killings, first of

13     all, this was the -- it was the Democratic Party that said that I killed

14     Vojin Vuletic, and then Slobodan Jovic, and that I killed him wife Paska,

15     and now I cannot even remember who it was that said that I killed Oliver

16     Dennis, a Chetnik vojvoda, who I held in high esteem, and so on and so

17     forth?

18        A.   I remember that Vojin Vuletic was a very sick man and that that

19     was the cause of his death, illness.  I even socialised with him.  As for

20     Paska Jovic, that story was launched and kept on the burner, as it were,

21     by his wife -- by her husband, Slobodan Jovic.  He exerted such pressure

22     against all of us that he came across.  He wanted us to believe his

23     assertion that Mr. Seselj had something to do with this.

24             At that time, I was head of the Deputies Club that cooperated

25     with the Socialist Party or, rather, the government of the Federal

Page 12924

 1     Republic of Yugoslavia.  I took Slobodan Jovic to the then Minister of

 2     the Interior of the Federal Republic of Yugoslavia, Vukasin Jokanovic, so

 3     that he would say to Slobodan Jovic what the police knew about that case.

 4     Vukasin Jokanovic, at the meeting at his office, and I think this was in

 5     1995, stated explicitly that Vojislav Seselj and the Serb Radical Party

 6     had nothing to do with this whatsoever.  However, even that was not

 7     sufficient for Slobodan Jovic.  We went together to the then Minister of

 8     the Interior of Serbia, Zoran Sokolovic.  Zoran Sokolovic gave us the

 9     names of three men who were then under investigation for the killing of

10     Paska Jovic.  Of course, later on it was publicly disclosed that this was

11     one man, a man who was a criminal and a pervert.

12        Q.   Tell me, please, when such lies are launched in the public, did

13     anyone serious in the Serbian public opinion believe this or did they

14     just thing that this was something that was tabloid fodder?

15        A.   Well, serious people didn't believe it.

16        Q.   After that, did the rating of the Serb Radical Party just go up?

17        A.   Exactly, because the logical conclusion was, in relation to such

18     nebulous accusations, that this was a dirt campaign against

19     Vojislav Seselj and the Serb Radical Party.

20             JUDGE ANTONETTI: [Interpretation] Witness, just a very short

21     follow-up question.

22             Mr. Seselj puts a series of questions about a series of crimes.

23     I suppose that there were investigations into those crimes in your

24     country.  I know and we know that there are high-quality investigative

25     judges working in your country, and they must have carried out

Page 12925

 1     investigations into those crimes.

 2             As far as you know, the offenders, were they identified, tried?

 3     Were they convicted, as far as you know?  In all these cases, did Serbian

 4     justice at any time incriminate Mr. Seselj?

 5             THE WITNESS: [Interpretation] An investigation was carried out.

 6     I knew that, and sentences were passed out to the perpetrators.  But the

 7     name of Dr. Vojislav Seselj never appeared in the investigation or during

 8     the trial.  Well, the police and the law found out the suspects and

 9     through an investigation and legal proceedings and trials and a judgement

10     which was passed, the perpetrators were found and they were sentenced,

11     and in both -- in these cases that Mr. Seselj mentioned.

12             MR. SESELJ: [Interpretation]

13        Q.   Do you remember how we, the Serb Radicals, in the second half of

14     1993, clashed with Slobodan Milosevic and the Socialist Party, and how

15     this fierce clash went on right up until the end of 1997?

16        A.   Yes, I remember it well.  I took part in it.  Slobodan Milosevic,

17     using television and other information media, ascribed various things to

18     you, or rather the Slobodan Milosevic regime did, and all the

19     protagonists of the system of the day, his propaganda and so on, they

20     ascribed it to you and blamed you for engaging in violence and many other

21     negative things, and they made it impossible for you and the Serbian

22     Radical Party to respond to the accusations made against you.

23        Q.   Did anybody ever use more brutal words to attack Slobodan

24     Milosevic and his wife, Mira Markovic, than me?  Did anybody use worse

25     words than me?

Page 12926

 1        A.   Well, nobody dared think along those lines, let alone utter the

 2     kind of things that you uttered.  And I remember some of your

 3     accusations, the ones that you hurled against them.  I remember them

 4     today.

 5        Q.   And they're to be found in the titles of my books as well, right,

 6     because with my book titles, I showed what I thought about the people who

 7     wielded might and were at the head of the government?

 8        A.   Yes.  You were -- you never compromised in unveiling the truth.

 9        Q.   Tell me this:  Could -- had Milosevic's regime been able to find

10     anything that compromised me, would they have used it to finally settle

11     accounts with me?

12        A.   Yes, he would use anything that he could find, because he treated

13     you as the most -- his most serious political adversary.

14        Q.   They arrested me three times and threw me into prison, first of

15     all because of an incident in the Federal Assembly.  The second time was

16     because of an incident in the Federal Assembly again, and the third time,

17     because I held a banned rally in Gnjilane; right?

18        A.   Yes.

19        Q.   So in this period from 1993 to 1997, I was in prison three times

20     exclusively for politics, for reasons of politics?

21        A.   Yes.

22        Q.   There was never any crime involved, was there?

23        A.   No.

24        Q.   Now, the next time the investigators of The Hague Tribunal, in

25     September 2006, asked you to come to their premises; right?

Page 12927

 1        A.   Yes, they did ask me to do that, but I didn't want to go.  And

 2     then Paolo Stocchi said that one of the OTP representatives would come to

 3     see me anywhere I say.

 4        Q.   Was that Daniel Saxon?

 5        A.   Yes.

 6        Q.   And a woman with him?

 7        A.   Yes, a lady who introduced herself and said she was from New

 8     Zealand.

 9        Q.   And then in your own flat, according to your statement, and

10     that's your statement of the 19th of November, 2007, for the Prosecutor

11     to be able to follow, in your own words, he insisted that Dr. Seselj

12     should be depicted in The Hague Tribunal in such a way that he be

13     politically eliminated, and he said that you could help them there; is

14     that right?

15        A.   Yes.

16        Q.   You say he insisted upon that when he saw that he could learn

17     nothing from me about war crime allegations?

18        A.   Yes, he put the same ideas forward as the late Zoran Djindjic.

19     He also said that the new government should be stabilised, that the only

20     way out for Serbia was a pro-Western government, that all those against

21     that government should be suppressed, and the most serious adversary to

22     Western policy was Dr. Vojislav Seselj and the Serbian Radical Party, so

23     he should be rendered impotent.  And I had the impression that Dan Saxon

24     was far more oriented towards implementing politics and the activities of

25     the US CIA than his legal functions and court functions.  He acknowledged

Page 12928

 1     that he was an official of certain American structures and that --

 2             JUDGE ANTONETTI: [Interpretation] One moment.

 3             Yes, Ms. Biersay.

 4             MS. BIERSAY:  I understand that this witness has some training as

 5     a lawyer.  I would request that the Court remind him about the

 6     possibility of perjury charges being brought and under what conditions

 7     that could happen.

 8             JUDGE ANTONETTI: [Interpretation] Witness, you are a lawyer.  You

 9     must keep this in mind.  You are testifying under oath.  You made a

10     solemn declaration.  You are aware of the scope of such a declaration.

11     Now you describe a meeting with an OTP investigator [as interpreted] and

12     with an investigator, and you allege that this man said that Mr. Seselj

13     has to be put out of the political loop, as it were.  Is this something

14     that you're saying under oath?  We agree on that?  This is being said

15     under oath, is it?

16             THE WITNESS: [Interpretation] Under oath, and the oath makes it

17     incumbent upon me to tell the truth.

18             JUDGE LATTANZI: [Interpretation] But, equally, you do confirm,

19     Witness, that you signed, with your own hand, a statement given to Saxon,

20     Stocchi, a statement in which you were saying just the opposite?  So can

21     you confirm that you signed this statement?

22             MS. BIERSAY:  Your Honours, forgive me for interrupting, but just

23     to clarify, the statement, which is 65 ter number, I believe, 7427, was

24     signed in 2003.  That is the only statement that was ever signed for the

25     OTP by this witness.  With respect to that statement, Mr. Saxon did not

Page 12929

 1     in any way participate in that meeting.

 2             JUDGE LATTANZI: [Interpretation] Thank you very much,

 3     Ms. Biersay.

 4             So you signed a statement given to the investigator, to Paolo

 5     Stocchi, and you signed it, confirming what was written in it.  You

 6     equally signed a statement in which the interpreter certified that your

 7     entire statement had been read back to you in Serbian; everything had

 8     been translated from English into Serbian.  And you did sign.  We have it

 9     in front of us.

10             Can you confirm that you signed the statement?

11             THE WITNESS: [Interpretation] I did sign, but I told you what

12     pressure I was under.  It was not translated to me or interpreted to me,

13     and the statement is in English and I don't understand English.

14             JUDGE LATTANZI: [Interpretation] But you did sign that this

15     statement was translated back to you into Serbian.  So did you sign a

16     fake document?  Are you confirming this here in this courtroom?

17             THE WITNESS: [Interpretation] No, it wasn't translated back to

18     me.  I stand by that, and that's the truth of it.

19             THE ACCUSED: [Interpretation] May I continue?

20             JUDGE ANTONETTI: [Interpretation] Please carry on.

21             MR. SESELJ: [Interpretation]

22        Q.   Mr. Glamocanin, even if this statement had been read out to you

23     in Serbian, you had absolutely no possibility of checking to see whether

24     the interpreter read it out to you in full?

25        A.   No.

Page 12930

 1        Q.   So you were left to the will of the translator and interpreter to

 2     make restrictions, change the contents of the statement, or do anything

 3     that he had been given orders to do?

 4             THE INTERPRETER:  Could the speakers speak one at a time, please.

 5     We did not catch the answer.  It was overlapping.

 6             THE WITNESS: [Interpretation] The statement was written by the

 7     interpreter, so that's it.

 8             MR. SESELJ: [Interpretation]

 9        Q.   And it's your impression that the interview would have gone on

10     for five or six days, had you not signed?

11        A.   Right.

12             JUDGE HARHOFF:  Mr. Glamocanin and Mr. Seselj, again you're

13     overlapping, making it impossible for the Judges to understand the

14     conversation between you.  You are both lawyers, and you both know how

15     these things work.  You should be able to do better, so please observe a

16     pause between the question and answer.

17             JUDGE ANTONETTI: [Interpretation] Witness, do take this into

18     account.  What was said by my fellow Judge is very important indeed.

19             Let me get back to this essential thing.  You are testifying

20     under oath, so we take it for granted that what you're saying is true,

21     unless there is perjury.

22             I have your statement signed in English, of course.  The

23     statement in your own language is not signed.  At any rate, I don't have

24     it.  It is a statement of exactly 19 pages, the 20th page, being the last

25     one, in which you stated that the 20 pages were read back to you in your

Page 12931

 1     own language.

 2             If 20 pages were read back to you in your language, it takes at

 3     least an hour for the 20 pages to be read back to you in your own

 4     language slowly for you to understand.  The question is very simple.  I'm

 5     not going to name the interpreter, but did the interpreter read the 20

 6     pages, starting with the very first word saying:  "My name is

 7     Jovan Glamocanin.  I am a Serb male ...," et cetera?  Did she read the 20

 8     pages?

 9             THE WITNESS: [Interpretation] No.

10             JUDGE ANTONETTI: [Interpretation] Your answer, she didn't?

11             THE WITNESS: [Interpretation] No.

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

13     given the document in English, did you sign it, did you initial it, just

14     in your stride?

15             THE WITNESS: [Interpretation] Correct.

16             JUDGE ANTONETTI: [Interpretation] If the Trial Chamber feels it

17     is necessary, there is one very simple solution to this problem.  We just

18     need to hear the interpreter.

19             Continue, Mr. Seselj.

20             MS. BIERSAY:  Excuse me, Your Honour.  Excuse me, Mr. Seselj.

21             Just for the record, Your Honour, we would move that the

22     statement, which has been the subject of much discussion, be given at

23     least an MFI number, and that would be 65 ter number 7427.

24             JUDGE ANTONETTI: [Interpretation] Yes, let's give an MFI number

25     to the statement.

Page 12932

 1             THE REGISTRAR:  Your Honours, the statement shall be given

 2     Exhibit number P688, marked for identification.  Thank you, Your Honours.

 3             JUDGE ANTONETTI: [Interpretation] Continue, Mr. Seselj.

 4             MR. SESELJ: [Interpretation].

 5        Q.   Mr. Glamocanin, you're a lawyer, you have many years of

 6     experience -- or, rather, a legal man.  In the Serbian legal system, can

 7     any statement be valid which a citizen signed and it is written in a

 8     language he doesn't understand at all?

 9        A.   No, it cannot be valid.  It must be in a language which the

10     person signing understands and knows well.

11        Q.   You described here how, on the 16th of September, 2006,

12     Ms. Christine Dahl came to your flat with Paolo Stocchi, an interpreter

13     and two policemen?

14        A.   Mr. Seselj, that was on the 15th of November, 2007.

15        Q.   2007, you say?

16        A.   Correct.

17        Q.   And you go on to explain that while you were talking to them, one

18     of the policemen went to your daughter's room, sat down at the computer,

19     and checked to see what was on the hard disc there; right?

20        A.   Yes.

21        Q.   Paolo Stocchi even mentioned that your daughter used the internet

22     at night too much; is that right?

23        A.   Yes.

24        Q.   And from that, you draw the conclusion that you were being -- you

25     were under surveillance from The Hague investigators or the Serb police

Page 12933

 1     that provided them with intelligence about you?

 2        A.   Well, yes.  By stating that, Mr. Stocchi said it all.

 3        Q.   And he said that you would be arrested and forcibly taken to

 4     The Hague if you failed to sign?

 5        A.   Well, Mr. Stocchi and Ms. Dahl mentioned all the measures they

 6     could take and steps they could take and resources they had to force me

 7     to come in and testify.

 8        Q.   On the 27th of February --

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

10             Witness, now you are incriminating the investigator from the OTP.

11     You said that he went to check the computer, to check the hard disc in

12     the computer.  This is a serious allegation.  You know that, technically,

13     that can be ascertained.  Why did you not think of asking the lawyer to

14     start proceedings for an independent expert to check the hard disc in

15     order to show that at a precise time, one file was opened or there was

16     one search launched?  Didn't that occur to you?

17             THE WITNESS: [Interpretation] It didn't occur to me.  As for my

18     daughter's computer, it was a Serb policeman that was handling it, not

19     Mr. Stocchi.  Mr. Stocchi just said that our daughter uses the internet

20     for a long time during the night.

21             JUDGE ANTONETTI: [Interpretation] So it was the Serbian policeman

22     who was there who started the computer?

23             THE WITNESS: [Interpretation] Yes.  The Serb policeman came with

24     a team that was headed by Ms. Dahl, and first he came into the apartment

25     on his own, and he said that he first had to search the apartment and

Page 12934

 1     that it was only then that Ms. Dahl and the rest could come.

 2             JUDGE ANTONETTI: [Interpretation] You're a distinguished lawyer,

 3     so what was the legal authority allowing a Serbian policeman first to get

 4     into your apartment and, secondly, to access a computer?  Is there any

 5     legal foundation in that or not?

 6             THE WITNESS: [Interpretation] Mr. President, I know that in order

 7     to have a search carried out, a policeman has to have a warrant, a search

 8     warrant.  However, I did not want to refuse to talk to Ms. Dahl, because

 9     she's a Prosecutor, she came all the way from The Hague.  Of course, it

10     wasn't only for the sake of talking to me that she came, but I did accept

11     to talk to her in my apartment and I did not want to refuse to have

12     Ms. Dahl and Mr. Stocchi come, since they had arrived in front of the

13     apartment building where my apartment is.  Therefore, although there was

14     this deficiency in terms of the procedure involved and the Serbian

15     policeman coming in, I really wanted to talk to them and to say that

16     there was no reason for me to be a Prosecution witness.

17             JUDGE ANTONETTI: [Interpretation] Very well.

18             You have 23 minutes left, Mr. Seselj.  Please proceed.

19             MR. SESELJ: [Interpretation].

20        Q.   On the 27th of February, 2008, you gave another statement to my

21     associates, and in it you described that on that day, at 1550 hours, a

22     Slovene woman violently entered your apartment, barged into your

23     apartment?

24        A.   Exactly.

25        Q.   You didn't write her name out here, but never mind.  She came as

Page 12935

 1     a friend of the Court?

 2        A.   Well, yes, she came in a strange way.  She did not announce over

 3     the telephone that she would be coming, or she didn't let us know in any

 4     other way.

 5             JUDGE ANTONETTI: [Interpretation] Yes.

 6             MS. BIERSAY:  Out of an abundance of caution, Your Honour, may we

 7     go into private session for a few moments?

 8             JUDGE ANTONETTI: [Interpretation] Personally, I don't see the

 9     need for this.  I don't see what should be hidden.

10             Witness, when the Trial Chamber was seized of all these issues,

11     we appointed an amicus curiae, and the Trial Chamber made sure to find

12     someone that was a professional, someone who was used to investigation,

13     and that was the person that was appointed.  This person was supposed to

14     investigate, and we expected that when you met with this woman, you would

15     give explanations on things.  So she had a warrant by the Trial Chamber

16     in order to investigate and to put questions to you to know exactly what

17     happened.

18             We are perfectly neutral.  There are two parties here.  There is

19     the Prosecution, on the one hand, and the Defence, on the other hand.

20     Both parties can allege what they want.  But we have to judge, it is our

21     responsibility, and because of this we have to double-check everything,

22     which is why we had asked this woman to come and to investigate.  She was

23     on a mission, and she was there to tell you that given the Chamber's

24     decision, she wanted to meet with you in order to put a number of

25     questions to you.  I wanted you to -- I wanted this to be very clear so

Page 12936

 1     you know exactly what the context was for all this.

 2             Mr. Seselj, proceed.

 3             MR. SESELJ: [Interpretation]

 4        Q.   Mr. Glamocanin, I would like you to describe to the Trial Chamber

 5     how it was that this lady barged into your apartment.  So that I do not

 6     put leading questions to you, you explain it on your own?

 7        A.   This lady did not announce herself over the telephone or in any

 8     other way.  Quite simply, she rang the doorbell of my apartment.  I

 9     opened the door.  She introduced herself, and she said straight away that

10     she was looking for Jovan Glamocanin and that she had to talk to me.

11             When I asked her who she was, she said that she was Ana Marhajn

12     or something like that or something along those lines, and I said, "What

13     is it we have to talk about?  I don't know you."  She said, "But we have

14     to."  I hesitated, but she entered the apartment.  She didn't ask me --

15     she didn't wait for me to ask her to come in.  She walked in and she said

16     that she's Ana Marhajn, that she's a Slovene, and that she's a friend of

17     The Hague Tribunal.  When she said that, I threw her out of the apartment

18     straight away, because if she was functioning on behalf of the OTP or

19     some other organ of The Hague Tribunal, that was my reasoning, although

20     there was little time for reasoning.  She certainly would have announced

21     herself.  Why some kind of clandestine entry in this way, as if she were

22     a commando or something.  I had no other choice than to kick her out of

23     my apartment.

24             JUDGE LATTANZI: [Interpretation] Witness, but she said she was

25     coming as an amicus curiae.  I mean, you're an educated man.  You must

Page 12937

 1     have understood that she was not a friend of the Prosecution.

 2             THE WITNESS: [Interpretation] She did not say anything about

 3     Prosecutors.  It's not that she mentioned a particular Prosecutor.  But

 4     what kind of a friend of the Court is that?  What does she have to

 5     discuss in that way?  I would have accepted to talk to her, had she

 6     announced herself, had she explained.  After all, Mr. Dan Saxon and

 7     Ms. Christine Dahl came to my apartment in a very civilised way.  Why to

 8     barge in like a commando?

 9             I am not a criminal, I am not hiding anything.  I am not involved

10     in any kind of conflict.  Why would anyone enter my apartment in that

11     way?  I know that one's apartment can be entered in accordance with the

12     law and Constitution in agreement with me or with a search warrant from

13     the Court; no other way.

14             MR. SESELJ: [Interpretation]

15        Q.   In your statement, it says that after this reaction of yours, she

16     started threatening you too.  She knew Serbian; right?

17        A.   She did speak the Serbian language, yes, truth to tell, with a

18     Slovenian accept, but she said, "Wait and see until you get to

19     The Hague."

20        Q.   So she started using two terms in the singular, which was the

21     impolite form; right?

22        A.   Yes, yes, impolite, and also it was a brief conversation and it

23     was a conflict.

24        Q.   Did you address her in "vu" terms all the time?

25        A.   Yes.

Page 12938

 1        Q.   And she quarrelled, she started addressing you as "tu"?

 2        A.   Yes, that's right, that's exactly what she did.

 3        Q.   All right.  In this statement dated the 11th of August this year,

 4     you mentioned this detail, too; namely, that you found it very strange to

 5     hear Stocchi and his colleague ask all these questions about the Serb

 6     Radical Party and about me, and that you thought that they wanted to

 7     represent the Serb Radical Party as some kind of a criminal organisation

 8     with a firm structure?

 9        A.   Yes, and with elements of violence in the party, considerable

10     ones at that, and they asked me about all sorts of details that had

11     nothing whatsoever to do with an investigation, the needs of the

12     investigation, or the indictment.  It went beyond that scope.

13        Q.   As you were upset, you cautioned them, warned them that this was

14     improper behaviour, and you asked them whether they were perhaps from the

15     American CIA, if they were putting questions like that.  What was their

16     reaction?

17        A.   Well, Paolo Stocchi said that he's not a member of the CIA.  If

18     he were to work for any intelligence service, he would work for his own

19     Italian one, Italian intelligence service, and why, why be against the

20     CIA?  The CIA is the striking force of the West.  Why not cooperate?

21        Q.   On the basis of that, I draw the conclusion that for them,

22     everything good is in the West and everything evil is in the East.

23             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

24             MS. BIERSAY:  Could we have a time frame for this particular

25     discussion -- alleged discussion with the investigator that the witness

Page 12939

 1     is describing?

 2             JUDGE ANTONETTI: [Interpretation] Could you tell us when this

 3     happened?

 4             THE WITNESS: [Interpretation] Well, it was during those four days

 5     of interviews that were carried out in Belgrade.

 6             JUDGE LATTANZI: [Interpretation] Was it in the first day, in the

 7     middle of these four days, at the end of the four days?  Tell us when it

 8     occurred.

 9             THE WITNESS: [Interpretation] Well, around the middle of the

10     interviews.  I think it was during the course of the second day of the

11     interviews.

12             MR. SESELJ: [Interpretation]

13        Q.   They even suggested to you during this main interview that went

14     on for four days that you, Maja Gojkovic and I had a meeting in

15     Novi Zednik with the chief of police of Subotica, Milan Jerinkic, and

16     that over there we agreed to compile a list of Croats who should be

17     killed, who work for the Croatian Secret Service?

18        A.   Right, that's what they discussed, and they wanted me to state my

19     views.  I said then and I can say now that I never took part in any such

20     meeting, nor am I aware of the making of any such lists for liquidations

21     in Subotica.

22        Q.   On that occasion, Paolo Stocchi said to you, and now I'm quoting

23     your statement --

24             THE INTERPRETER:  Interpreter's note, we do not have the text.

25             MR. SESELJ: [Interpretation]

Page 12940

 1        Q.   "That Vojislav Seselj is dangerous for the new government in

 2     Serbia, that Vojislav Seselj is a hindrance and that Serbia should have a

 3     pro-Western government.  Stocchi repeated several times that Vojislav

 4     Seselj is far worse than Slobodan Milosevic."

 5             Since I'm talking about Stocchi, I have to point out that during

 6     the course of these interviews, he said many things that were insults and

 7     slander, which I could not accept as a human being.  He said that

 8     Vojislav Seselj is not a democrat, that he is unpleasant to his

 9     associates, that he slanders his political foes, and he asked for -- and

10     he demanded from me that I confirm this in The Hague; is that right.

11        A.   Yes, that's right.  As for your qualification or, rather, what he

12     said about you, it was in line with what Zoran Djindjic had told me and

13     what I heard later during conversations.

14        Q.   Later on, Saxon repeated what Stocchi had said, and I'm going to

15     quote from your statement once again:

16             "That Vojislav Seselj was a great danger, the greatest danger to

17     the new government in Serbia, and the Saxon said that the concept of a

18     Greater Serbia, advocated by Vojislav Seselj, was the war option, and

19     that Vojislav Seselj was a danger to peace in the Balkans."

20             Is that correct?

21        A.   Yes.

22             JUDGE LATTANZI: [Interpretation] Witness, the Prosecution's team

23     came to meet with you, and all they wanted to do was talk politics with

24     you?  They weren't there to investigate anything; is that it?

25             THE WITNESS: [Interpretation] Madame Lattanzi, we spent the first

Page 12941

 1     part of our interview discussing the topic war crimes and the indictment

 2     against Mr. Vojislav Seselj.  I managed to convince Mr. Saxon that I knew

 3     nothing about any war crimes allegedly committed by Mr. Seselj, or hate

 4     speech, for that matter, either, and Mr. Saxon accepted that.  Mr. Saxon

 5     is a very pleasant man.  It's pleasant to talk to him.  He has good

 6     manners.  A good atmosphere prevailed during the interview, and I wanted

 7     to show him that I'm not an enemy to any people in the world, any nation,

 8     and that I was ready to talk and discuss matters, but that I could not be

 9     a Prosecution witness against Dr. Vojislav Seselj.

10             And later on we went on to discuss politics, and he said, for

11     example, that he represented American politics and that he was

12     implementing American politics, and I even drew the conclusion that he

13     was linked in a way to political life and might be some official of the

14     American intelligence service.  But when I put that to him, he laughed

15     and said, "Well, why not?"  And during that conversation, we also

16     discussed politics, and he was a fervent advocate of American politics

17     and policies.

18             And let me state once again, that was my impression, and my basic

19     conclusion, based on that interview with the Americans, is that they are

20     all taken up with their politics, the politics of their government.  It's

21     a cowboy politics, but they see politics as the great rancher coming to

22     another person's farm and says, "Give me your land or I'll kill your

23     wife," and so on and so forth.  But that's not the kind of relations that

24     exist in the world.  You have to respect other nations and other peoples.

25     Other people have intellectuals, too.  They have their own traditions,

Page 12942

 1     their own values.  And what we can do is sit down to the negotiating

 2     table and reach agreements, and respect the civilizations, the legal

 3     systems, the European, Anglo-Saxon, and all the other civilizations and

 4     systems.

 5             JUDGE ANTONETTI: [Interpretation] Witness, your hearing went

 6     on -- your interview went on for four days.  We know that, we have proof

 7     of this.  It started in the morning, it went on in the afternoon, and it

 8     went on for four days.  What about lunch?  Did you have lunch with them

 9     or did everyone go and have lunch in different places?

10             THE WITNESS: [Interpretation] No, nobody had lunch.  The talk

11     went on all the time.  Sometimes we spoke a bit more freely, and I got a

12     bit passionate and emotional when I realised I was talking to a typical

13     Italian, and I remembered all the stories of my mother, how an Italian

14     officer grabbed me from the Ustashas when I was only one year old.  It

15     was in the native village of my mother, where we had fled from Banja

16     Luka.  That Italian officer had taken me away from a Croatian Ustasha who

17     meant to spear me with a bayonet, so I have a great affection for

18     Italians.  And when I saw this Paolo Stocchi as a typical Italian, I sort

19     of imagined him as a nephew of that Italian officer, but Paolo Stocchi

20     was the one who led the conversation.  He asked the questions.  He led

21     the conversation in a way that was convenient to him; that is, to

22     incriminate, as much as possible, Dr. Vojislav Seselj, whereas I had no

23     arguments, no motive, no grounds to incriminate Mr. Seselj, and I didn't

24     give a statement of that sort.

25             JUDGE ANTONETTI: [Interpretation] Sir, you're an educated man, as

Page 12943

 1     I said earlier.  You're a lawyer, and you are knowledgeable when it comes

 2     to procedure.  Those 20 pages were supposed to sum up what you had said,

 3     so you really should have double-checked it in your own language, what

 4     this Mr. Stocchi had written, even if you found him very friendly,

 5     because he was drafting the statement from what you had said.  And you

 6     should have controlled it, you should have double-checked it.  Obviously,

 7     you didn't.

 8             THE WITNESS: [Interpretation] I did not check it.  He dictated,

 9     and on day 4 I described in which way I signed it.

10             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

11             MS. BIERSAY:  Thank you, Your Honour.

12             I had the impression that Mr. Seselj had indicated that he was

13     reading from the February 2008 statement, when he described the

14     similarities between the conversations had with the -- the alleged

15     conversations had between the witness and Mr. Saxon, as well as

16     Mr. Pastorre-Stocchi.  I think I am mistaken -- I think Mr. Seselj was

17     mistaken, so if he could please tell us where those quotes were coming

18     from.

19             THE ACCUSED: [Interpretation] 11th August, 2008, 11th of August.

20     That's the last thing I quoted from.  Maybe I was mistaken, I'm not sure,

21     when I mentioned it the first time.

22             Now, I still have some time left, don't I?

23             JUDGE ANTONETTI: [Interpretation] You don't have much time left,

24     but you have 15 minutes left.

25             MR. SESELJ: [Interpretation]

Page 12944

 1        Q.   The first time I read my statement, I have to be perfectly honest

 2     with you, Mr. Glamocanin, I was immediately suspicious it was really your

 3     statement, because there is some information here that is completely

 4     inaccurate.  And I don't believe that even if you were very angry and

 5     very hateful, you would say a thing like that.

 6             You state here that it was clear to you that I had been in

 7     contact with Radmilo Bogdanovic, who during the war was the Minister of

 8     the Interior of Serbia.  Radmilo Bogdanovic was Minister of the Interior

 9     until March 1991, and then after the protests of the 9th of March, he

10     submitted his resignation.  Did you remember I attended a press

11     conference of the Serbian Radical Party, demanding his resignation?

12        A.   I remember you demanded his resignation, but you certainly did

13     meet with Radmilo Bogdanovic, as had I.  Radmilo Bogdanovic was a very

14     talkative man and very witty, and he was --

15        Q.   I have to correct you here.  As far as the Assembly is concerned,

16     he was a vice-president of the chamber of republics and provinces, and

17     there was another president of the upper house of the Parliament?

18        A.   Yes.  Radmilo Bogdanovic was a very pleasant man.  Those were

19     friendly meetings that do not impose any obligations on anyone, no

20     political strings attached.

21        Q.   It was incredible to me, when I read in the paragraph 120, that

22     you allegedly stated that your son, Srdjan, had left the Serbian Radical

23     Party and hated me because I was fighting only for power, and he wanted

24     to fight against the Slobodan Milosevic regime.  Do you know that my

25     relationship with your son remained sincerely amicable even after you

Page 12945

 1     left the Serbian Radical Party, that he visited me both at the party, in

 2     my office in Serbia?

 3        A.   I know that you wrote to him a very friendly letter, a very nice

 4     letter, and that he has only the greatest respect for you.

 5        Q.   Do you know, Mr. Glamocanin, when the Milosevic regime arrested

 6     me in 1994, you and I were in profound conflict, and your daughter came

 7     to attend a protest rally in my support?

 8        A.   Yes, she did.

 9        Q.   Is it possible that you ever said anywhere that your son, Srdjan,

10     hates me?

11        A.   No, he doesn't.

12        Q.   Do you know that he went to the front-line several times as a

13     Serbian Radical Party volunteer?

14        A.   Twice, at least.

15        Q.   And he commanded volunteers?

16        A.   Yes.

17        Q.   Do you remember he was in the group of volunteers that was

18     surrounded in 1992 in Hrasno, in Sarajevo, somewhere in April, and they

19     barely got out of a Muslim encirclement?

20        A.   Yes, I remember.

21        Q.   And do you remember that publicly, an interview for the most

22     popular paper in Serbia, I said that your son deserves to be a Chetnik

23     vojvoda, but because his father is a high-ranking official of the party,

24     we didn't want to give him that title?

25        A.   I remember that.

Page 12946

 1        Q.   Is it true?

 2        A.   Yes, it's true.

 3        Q.   Is it the 'Nedeljni Telegraf' for 1994?  The Prosecution can find

 4     it.  I see in paragraph 124 that they were very interested to locate the

 5     archives of the Serbian Radical Party.

 6        A.   Yes.  Well, you see, they asked all sorts of questions outside

 7     the scope of their work.

 8        Q.   And do you know that the Milosevic regime and the secret police,

 9     they put a lot of effort into finding our archives in the years when we

10     were in a deep rift, but they never succeeded?

11        A.   The Milosevic regime used tried and tested police methods.  They

12     used the service of State Security that had been inherited from the

13     Communist regime and that were to compromise all free-thinking and

14     freedom-loving people.

15        Q.   And do you know that during that deep rift with them, I

16     established within my party a group of people who would work on

17     intelligence affairs and who would provide me with useful information on

18     a daily basis?  Do you remember Stojan?

19        A.   I remember Stojan.

20        Q.   You still don't know his real name, do you?

21        A.   I don't.  You used to say that something like that was

22     established, but I had never had anything to do with that sort of work.

23        Q.   Do you know that I have my personal archive as well, with several

24     dozen thousand very confidential documents that nobody has ever been able

25     to locate?

Page 12947

 1        A.   You are a very meticulous man, a very thorough man, and you leave

 2     nothing to chance.  You think always of the future.

 3        Q.   They can't find it in my apartment or on the premises of the

 4     party.  They can't find it anywhere.

 5             You know I also published several books, including those

 6     confidential documents, but always I was very selective.  I never

 7     published the most interesting things.  And I have three books of over

 8     1.000 pages full of such documents.

 9        A.   Yes.

10        Q.   Do you know I was offered a lot of money from abroad to give

11     those archives away, but I refused?

12        A.   No, I don't know that.

13        Q.   And many of these documents will remain inaccessible to the

14     public, and I will take all these secrets to my grave.

15             All right, Mr. Glamocanin.  I was surprised by one more thing

16     here, but you did explain in examination-in-chief; that it's something

17     Stocchi imposed on you, as part of your statement, the bit that refers to

18     Petar Panic; right?  You know him well, don't you?

19        A.   I know him as your bodyguard.

20        Q.   He was my bodyguard for three or four years.  He accompanied me

21     to the most forward front-lines?

22        A.   Yes.

23        Q.   But have you ever heard of him being involved in any sort of

24     crime?

25        A.   No.

Page 12948

 1        Q.   He was a rambunctious man, quarrelsome, a person who caused bar

 2     brawls, he was in prison several times but only because of these brawls

 3     and fist fights?

 4        A.   Yes.  He was a man who could be well liked.

 5        Q.   But he was prone to fist fights.  And how could they then confuse

 6     him with street dealers who traded foreign currency outside the building

 7     of our party?

 8        A.   Well, in this conversation with Stocchi, he said he had spoken to

 9     late Slobodan Jovic, and among other things he said that Slobodan Jovic

10     had taken some papers to the ambassador of Great Britain and that he had

11     spoken to -- and the latter had spoken to Stocchi, saying that it's a

12     great pity Slobodan Jovic was dead, because he could provide interesting

13     information to the investigation, although I do doubt that he knew

14     anything concerning you, that he could provide any evidence against you.

15        Q.   Do you know that this foreign currency dealing was in the hands

16     of Albanians, this whole street was controlled by Albanians?

17        A.   I heard something about that.

18        Q.   What could possibly Petar Panic have to do with these Albanians

19     trading in foreign currency?

20        A.   I have no idea.

21        Q.   During examination-in-chief, you mentioned several cases --

22     several incidents of walkouts and conflicts and incidents and quarrels

23     within the Serbian Radical Party, involving you as well, and you also

24     mentioned the case of the latest two, Tomislav Nikolic and

25     Aleksandar Vucic, how they immediately changed the policy by 180 degrees?

Page 12949

 1        A.   Yes.  Nowadays, Aleksandar Vucic is saying that he never worked

 2     for a Greater Serbia.  Tomo Nikolic constantly emphasizes European

 3     integrations, and we know very well what his story was before; that these

 4     integrations are very far away from us --

 5             JUDGE LATTANZI: [Interpretation] Mr. Vucic and Mr. Nikolic's

 6     opinions have nothing to do with our case.  They're not relevant.

 7             THE ACCUSED: [Interpretation] But what is of interest is the fact

 8     that Mr. Glamocanin stated in examination-in-chief, when you did not

 9     intervene, that precisely those two people were the main reason why he

10     had a conflict with me and left the Serbian Radical Party in 1994.

11             THE WITNESS: [Interpretation] It was not only them --

12             JUDGE LATTANZI: [Interpretation] You have to place it back in the

13     context, you know, of how it happened in 1994.  The present opinion of

14     these two people is not relevant.

15             THE ACCUSED: [Interpretation] Well, you were impatient, ma'am.

16     You did not want to hear my point, and the point is that I wanted to

17     remind Mr. Glamocanin that these two people, too, were fierce Serbian

18     nationalists and advocates of a Greater Serbia.

19        Q.   Is that so, Mr. Glamocanin?

20        A.   Yes.

21        Q.   Now, you mentioned here this factor of money as a way of bribing

22     politicians into changing their political views, political affiliations,

23     et cetera.  Now, I'm asking you, as an experienced man, as a politician

24     and intellectual, is money always the decisive factor?  Was there also

25     blackmail of politicians, if various secret services had the dirt on

Page 12950

 1     them?

 2        A.   I am aware of one attempt of bribery in 1995.  The late Zoran

 3     Todorovic summoned me at that time and offered me 1 million Deutsche mark

 4     to move that Deputies Club, MPs Club that I had formed after leaving the

 5     Serbian Radical Party, he wanted me to lead that Deputies Club towards

 6     the Yugoslav left, called J-u-l, "Jul," and I would get 1 million

 7     Deutsche mark for it.

 8        Q.   Now, speaking of the latest number, let's talk about these two

 9     figures.  The secret service and all those other parties had for years

10     been digging dirt up on politicians in order to blackmail them and

11     politically convert them.  That happened in 1990, 1991, 1992, 1993, all

12     those years.  Remember that great political change in Vuk Draskovic?  He

13     also changed his ideology by 180 degrees?

14        A.   Yes, I witnessed the change, and the conflict, and the joining by

15     Vuk Draskovic with Slobodan Milosevic, which was very turn-coat, very

16     unprincipled.

17             With my association, we were talking in Novi Pazar about

18     organising an all-Serbian rally where all representatives of all Serbian

19     lands would be attending, and Slobodan Milosevic was against such a

20     Serbian agreement because he wanted to be the only creator, the only

21     architect of a unified Serbian policy, and he negotiated with

22     Vuk Draskovic that he should take it into his own hands and kick us

23     aside.  At that time, I talked with -- was he deputy or chief of the

24     State Security Service of Serbia, Mr. Janackovic, and he told me about it

25     when we were in Novi Pazar on the occasion of that great rally.  And

Page 12951

 1     instead of having a really constructive meeting, a constructive rally to

 2     adopt a binding all-Serbian policy, it was left to Vuk Draskovic, who had

 3     suddenly become a friend of Slobodan Milosevic instead of a great

 4     opponent, it turned out that he had received money from Janackovic and,

 5     and once he spent them, he changed his tune again.

 6             JUDGE ANTONETTI: [Interpretation] This will be your last

 7     question, because your time is up soon.  Put your last question.

 8             MR. SESELJ: [Interpretation]

 9        Q.   What did you think, Mr. Glamocanin?  Why was no one ever able to

10     blackmail me into changing my ideology, my political orientation, or the

11     policy of the Serbian Radical Party?  Why was no one ever able to

12     blackmail me, not even here in The Hague Tribunal?

13        A.   Mr. Seselj, I have my own view, my own position on this issue.

14     Very frequently, even in the Serbian Parliament, especially by Vladan

15     Batic, we often hear that there is nothing emotional in politics, there

16     is only the ratio.  But if people enter politics without great passion,

17     without love for their own nation, for the whole humanity and desire for

18     prosperity, one cannot be successful in politics, at least not in the

19     kind of politics that contribute to the welfare of the people.  It can

20     only be a selfish man who enters politics in order to grab power as much

21     power and wealth for themselves personally.  That's the situation that

22     prevails in Serbia now.

23             You were really a man who entered politics wanting to do

24     something good for your people.  That's the only kind of politician that

25     I respect.  Unfortunately, in our country, Serbia, the selfish ones

Page 12952

 1     outnumber any other category, and they work in the interests currently of

 2     Western states.

 3             JUDGE ANTONETTI: [Interpretation] I'm a little amazed,

 4     Ms. Biersay, because you said that you had some redirect.  As far as I

 5     know, given the practice of this Tribunal, when you have a witness called

 6     by the Trial Chamber, each party puts questions and that's it.  Why do

 7     you want any redirect?

 8             MS. BIERSAY:  I may not need redirect if Mr. Seselj could just

 9     clarify a point with respect to the statements obtained by the Defence

10     from this witness.

11             He did refer me to some pages in Cyrillic of a book which

12     contains some statements from this witness, and my question is:  With

13     respect to the allegations about the political agendas proposed by both

14     Mr. -- allegedly by Mr. Saxon and Mr. Pastorre-Stocchi, is the August

15     2008 statement the only statement by this witness which encompasses those

16     claims or are there other statements given to the Defence that does?

17             JUDGE ANTONETTI: [Interpretation] I see.  Ms. Biersay puts a very

18     good question.

19             You have explained what the OTP investigator said to you in the

20     interview.  Ms. Biersay wants to know whether this refers to the exact

21     date in August 2008 or does this refer to other dates?

22             THE WITNESS: [Interpretation] That topic was mentioned in talks

23     with Mr. Paolo Stocchi and his colleague over the four days when they

24     interrogated me and during the talks with Mr. Saxon.  It was just

25     fleetingly mentioned in the talks attended by Ms. Dahl.  It had to do

Page 12953

 1     mostly with the indictment against Mr. Seselj.

 2             JUDGE ANTONETTI: [Interpretation] So Mr. Stocchi, that was in

 3     2003.  As to Mr. Saxon, that must have been in August 2008.  Is that

 4     right, Ms. Biersay?

 5             THE WITNESS: [Interpretation] With Mr. Saxon, I talked on the

 6     16th of September, 2006.

 7             JUDGE ANTONETTI: [Interpretation] On the 16th of September, 2006,

 8     you say.

 9             MS. BIERSAY:  The claims that the witness is now advancing with

10     respect to Mr. Saxon and Mr. Pastorre-Stocchi, are they only contained in

11     his statement from August 2008, that means not in the November 2007

12     statement, that means not in the 2008 February statement, but only after

13     he rejoined the Serb -- the SRS in March 2008.

14             JUDGE ANTONETTI: [Interpretation] What you said as to what

15     Mr. Stocchi allegedly told you in 2003 to what Mr. Saxon allegedly told

16     you in September 2006, is all this to be found in the statement you gave

17     to Mr. Seselj's associates; is that in that statement?

18             THE WITNESS: [Interpretation] It can be found in there, and one

19     part from this context of questions is that Mr. Stocchi said he was

20     intensively cooperating with the current authorities of Serbia,

21     intensively cooperating with Mr. Sutanovac, they agree on everything.

22             JUDGE LATTANZI: [Interpretation] Witness, you have spoken at

23     length already about the contents of this declaration.  What we wanted to

24     know now was whether these accusations against Mr. Stocchi, against

25     Mr. Saxon, whether they were contained only in the statement you gave in

Page 12954

 1     August 2008 or whether they were also to be found in the statement of

 2     November 2007 given to Mr. Seselj's associates.  That's the only thing we

 3     want to know.  That's a procedural matter.  We're not interested now in

 4     the contents, because that has been dealt with at length.

 5             THE WITNESS: [Interpretation] Well, Madame Judge, everything is

 6     in those statements, those signed statements.  I cannot separate

 7     anything, but it was certainly in the passage when I described my talks

 8     with Mr. Stocchi.  That's where I made these allegations, just as when I

 9     talked with Mr. Saxon.  But we have a compilation statement where all

10     this is indicated.  That's the latest statement, the overall statement

11     covering all these interviews with Paolo Stocchi, with Mr. Saxon, with --

12             JUDGE LATTANZI: [Interpretation] The latest statement was in

13     August 2008, the one you referred to?

14             THE WITNESS: [Interpretation] If I remember correctly.

15             THE ACCUSED: [Interpretation] You have it in the statement of

16     that 19th of November, 2007, on page 71 of the book, where Dan Saxon

17     insisted that Seselj should be portrayed in The Hague Tribunal in such a

18     way that he is politically eliminated, and "I can help considerably in

19     doing that."  It's all there.

20             JUDGE ANTONETTI: [Interpretation] I have it.

21             Now, to answer your question, Ms. Biersay, you'll find the answer

22     in the filings by Mr. Seselj, because I have this thanks to the good work

23     of the legal officer.  She passed on to me the application made by

24     Mr. Seselj when he asked for protective measures.  And in the statement

25     the witness gave to Mr. Seselj's associates, indeed, we can find a part

Page 12955

 1     addressing what Mr. Saxon allegedly said.  So please look at it, because

 2     I have it here, page 57.  Is that suitable to you?  You just need to look

 3     at it.  This application or motion was translated into English, by the

 4     way.

 5             MS. BIERSAY:  Thank you, Your Honour.

 6             JUDGE ANTONETTI: [Interpretation]  So, Witness, let me thank you.

 7     Your testimony is completed, but I forgot that my fellow Judge had a few

 8     questions for you, so I can't release you as yet.

 9             We're going to have a 20-minute break, and then we shall resume,

10     because Judge Harhoff has questions.  I had totally forgotten it.  I am

11     very sorry about it.

12             Let's have a 20-minute break.

13                           --- Recess taken at 10.13 a.m.

14                           --- On resuming at 10.36 a.m.

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

16             The Judges have a few questions for the witness.

17                           Questioned by the Court:

18             JUDGE HARHOFF: [Interpretation] Thank you.

19             [In English] Mr. Glamocanin, contrary to what many people seem to

20     believe, and maybe possibly also contrary to what you may believe, and

21     certainly contrary to what Mr. Seselj seems to believe, this Court is not

22     putting the Serbian nation at trial.  We do not entertain any prejudice

23     against the Serbian nation, or against the Croatian nation, or the

24     Bosnian nation, or any other nation, for that matter.  We are not,

25     furthermore, engaged in any attempt to condemn those who waged the wars

Page 12956

 1     in the Balkans.  We are here only and exclusively for one purpose, and

 2     that is to prosecute those who were responsible for the crimes that were

 3     committed during the war, and notably crimes committed against innocent

 4     civilians who took no part in the hostilities and therefore were

 5     protected by the Geneva Conventions.

 6             It does not serve the interests of justice, nor does it serve the

 7     interests of the Serbian nation, to deny or to seek to escape

 8     responsibility for such crimes, if indeed such crimes were committed by

 9     any member of the Serb armed forces or by Serbian volunteers.

10             I think for the sake of the Serbian nation itself and for the

11     peace in your country, it is in everybody's best interest to have these

12     crimes dealt with and those responsible for them punished adequately.  So

13     it is with this in mind that I would wish to put a few questions to you

14     in relation to your statement given to the Prosecution in May 2003.

15             I don't know if you have the statement, and if you don't have it,

16     if we could call it up on the screen, because I wish to draw your

17     attention to what you said, apparently, in paragraph 102, which is on

18     page 15 of the English version.  And if we can have it drawn up in the

19     Serbian version, paragraph 102, and shown to the witness.

20             Madam Biersay.

21             MS. BIERSAY:  Thank you, Your Honour.

22             I have hard copies, just in case it might be easier for the

23     witness to --

24             JUDGE HARHOFF:  I think you should give the hard copy in Serbian

25     to the witness.

Page 12957

 1             MS. BIERSAY:  So it's the B/C/S version and the English.

 2             JUDGE HARHOFF:  Please.

 3             So, Mr. Glamocanin, please read for yourself paragraph 102.

 4        A.   Well, this is in English.  Ah, I see.  I found it, I found it.

 5             Would you like me to read it out or would you -- are you waiting

 6     for an answer?

 7             JUDGE HARHOFF:  No.  I just want you to have read it for

 8     yourself.  We do not need to read it out.

 9             In this paragraph, Mr. Glamocanin, you seem to suggest that

10     Mr. Seselj motivated the volunteers to kill and defeat the enemy, and you

11     also say that Mr. Seselj never told you that the Chetnik volunteers had

12     to kill civilians at the war front?

13        A.   Correct.  This statement does not go along those lines.  This

14     statement says that the volunteers have to fight against the enemy, and

15     the enemy is not the Croatian people and it's not the Muslim people; the

16     enemy is the armed portion of the Croatian army and paramilitary units,

17     and this applies to the Muslim units, too, who were engaged in enemy

18     activity, engaged in killing and all the rest of it, all the other crimes

19     against the Serb people.  So the volunteers were going to war to fight

20     that kind of enemy.

21             This statement has nothing to do with civilians, who did not take

22     part in the war and the fighting.  And the speeches were quite realistic,

23     because what you should know is this:  I don't remember that here in the

24     Tribunal there was ever this piece of information given, that already at

25     the end of 1990, for example, at Mount Igman, there was already a camp in

Page 12958

 1     existence where the Mujahedin from the Mideast were being trained.

 2             And, otherwise, what you just said, before you went on to ask

 3     your specific questions, what you said at the beginning of the session,

 4     I can inform you that the Serb people are becoming more and more

 5     convinced that you are conducting these proceedings in the right way,

 6     that you are men and women of integrity, and that you will reach your

 7     ruling and decisions on the basis of looking at the realistic situations

 8     presented, the evidence, and all the valid facts, and that you act as

 9     people with great professional knowledge, with a great respect for the

10     legal system and the principles of the law in general.

11             JUDGE HARHOFF:  I'm glad to hear that, Mr. Glamocanin, but let me

12     return to your testimony here or your statement in paragraph 102, because

13     as much as I agree with the proposition that you make that civilians

14     should not be targeted during an armed conflict, that's not exactly what

15     you are saying in paragraph 102, because it seems to me that what you are

16     saying here is that Mr. Seselj never told you, never told you, that

17     Chetnik volunteers had to kill civilians.

18             The immediate question that springs to mind, when you express

19     this view in your statement, is:  Well, did Mr. Seselj tell you that he

20     had ordered the Chetniks not to kill civilians?

21        A.   Yes, Mr. Seselj always stressed that, and I've already described

22     the way in which the volunteers were sent off to the units of the

23     Yugoslav People's Army.  They were sent off, having been taken to the

24     church first and pledged there that they would fight chivalrously and

25     bravely.  And along those lines, in the profound ethics that they

Page 12959

 1     professed, Mr. Seselj sent off the volunteers at a joint rally held in

 2     Belgrade.  I attended two such ceremonies, and he always stressed the

 3     traditions of the Serbian army and the Serbian Chetniks, and the

 4     tradition is not to kill civilians and not to kill the infirm, but to

 5     fight valiantly and chivalrously.

 6             And I'd like to take this opportunity, as I've already talked

 7     about the way in which the Serb people have already changed their

 8     opinions with respect to this Trial Chamber, I would like to say that

 9     something happened which each and every well-intentioned Serb wanted to

10     see happen.  Special sympathies go to the Presiding Judge,

11     Judge Antonetti, and the Serbs see these legal proceedings and this trial

12     in that light, that the accused is given all the rights that he deserves

13     to have, and the Serb people have got back their faith to see that the

14     French are really friends of Serbia, as they have always been.

15             JUDGE HARHOFF:  We can get back to that --

16        A.   And your --

17             JUDGE HARHOFF:  [Previous translation continues]... my line of

18     questions.  What I want to establish here is if it is your testimony here

19     today that you heard Mr. Seselj say to the volunteers, as he saw them off

20     to the front-line, that they should not, under any circumstance, kill

21     innocent civilians.  Can you verify that or do you not remember clearly?

22        A.   Yes, I can verify that, I can confirm it, because I was present

23     at such meetings and when he addressed people in this way; that is to

24     say, when Dr. Seselj addressed the volunteers that way before they went

25     to join up with the JNA units.

Page 12960

 1             JUDGE HARHOFF:  Very well.  This raises two small questions

 2     before we move on.  The first question is:  Do you know if those

 3     addresses were recorded and are available in video?  Can we see what he

 4     said; is that possible?

 5        A.   Well, I don't really know.  I didn't look at that side of the

 6     matter.  Mr. Seselj will know that better than me.

 7             JUDGE HARHOFF:  I'm just asking because, you know, maybe you

 8     would have known if those speeches were recorded.

 9             The second issue before we move on is the issue of order.  Was

10     Mr. Seselj, in your view, in a position to instruct and, indeed, to order

11     the volunteers as to how they should fight their battles when they came

12     to the war front?

13        A.   Well, he did speak about that in his welcoming address to the

14     volunteers, and at every meeting he would stress the traditions of

15     Serbian chivalry.  He used every opportunity to do that, and he would

16     always stress that we were, in fact, one nation, the Croats and the

17     Muslims, and that ultimately we would realise that assertion.

18             JUDGE HARHOFF:  Mr. Glamocanin, you keep coming back to the issue

19     that Mr. Seselj urged the volunteers to observe Serbian chivalry.  Now,

20     that is not exactly the same thing as to say that they are not allowed to

21     attack or kill innocent civilians, so my question to you again, just to

22     make sure that I got it right:  Did Mr. Seselj, in his address to the

23     volunteers, specifically refer to civilians, not only to Serbian chivalry

24     but to civilians, and did he instruct them never to kill civilians?

25     That's -- we have to be clear about these matters, so, please, as a

Page 12961

 1     lawyer, I urge you to be precise in your answer.

 2        A.   I will be precise.

 3             Dr. Seselj would say that we must not behave like our

 4     adversaries, like the Ustashas.  We must not kill civilians and the

 5     infirm and weak.  And as a Chetnik vojvoda, he prohibited them from doing

 6     that.  "You have to defend the Serb traditions and the honour of the

 7     Serbs," that's what he said in his speeches at these meetings.  And I

 8     remember one particular occasion when he read out all those conventions

 9     on the rules of warfare, the Geneva and the others.

10             JUDGE HARHOFF:  Thank you.

11             Mr. Glamocanin, let's move on to the next paragraph, 103, and I

12     kindly ask you again to read it just for yourself.

13             In this part of your statement, you seem to suggest that

14     Mr. Seselj was well aware of the inference that the speeches had on the

15     Chetniks who volunteered for the war front, and that he knew the

16     consequences of his inflammatory speeches, because he's a brilliant

17     speaker and an intelligent man, and he was well aware of what he was

18     saying and doing.  A simple reading of this part of your statement,

19     Mr. Glamocanin, does suggest that Mr. Seselj knew well that in speaking

20     in the way he did, flamboyantly and inspiringly, he knew that some of

21     these volunteers might get so excited, once they came to the war front,

22     that they could commit crimes.

23             What is your reaction to that?  This is just taking your

24     statement verbatim.

25        A.   You know, my understanding of this, and I'm quite sure of it

Page 12962

 1     being correct, is that Dr. Seselj wanted to awaken the chivalrous spirit

 2     and valiant spirit in each of the volunteers, for them to be the real

 3     bearers of the struggle for the freedom of their people, for the Serbian

 4     struggle, and not retaliation or revenge.  And let me stress again that

 5     in all his speeches, he said we must not act in the same way as our

 6     adversaries, the Ustashas, we must not kill the infirm and the weak and

 7     civilians.  So he wanted to awaken the -- to urge them to combat and to

 8     settle accounts with those people who are killing the Serb people and not

 9     to awaken any forms of destruction or retaliation.  He would always

10     stress that.

11             JUDGE HARHOFF:  So you are telling us that indeed the fact that

12     the enemy did commit crimes against Serb civilians was discussed and

13     raised by Mr. Seselj.  Was it also discussed and raised within the SRS

14     party leadership?

15        A.   Well, the overall action was started to send volunteers to

16     prevent the suffering of the Serbs, and many Serb civilians were killed

17     and expelled, and from Western Slavonia first and then later on from the

18     other parts.  And I don't claim that there were no crimes committed on

19     the Serb side; however, I am certain that those crimes were, for the most

20     part, committed by the Serbs -- the local Serbs from those parts,

21     somebody, for example, whose daughter -- child had been killed, or mother

22     or father, and then they lose control, faced with a situation like that.

23     So those were the basic sources of all the evil and suffering, these

24     clashes and settling of accounts locally in the field.  We didn't send

25     volunteers from Serbia to kill civilians and the weak and infirm, but to

Page 12963

 1     defend our compatriots in other parts, in those areas of Croatia and

 2     later on in Bosnia-Herzegovina.

 3             How could you not send volunteers to Bosnia-Herzegovina when, as

 4     I've already said, at the end of the 1990s -- 1990, there was the

 5     Mujahedin camp with their short sabres and black turbans and the clothes

 6     they wore?  That was terrible, frightening.  And do you know what was

 7     most frightening?  When the berets arrived, they saw young men being

 8     carried away, hands tied in chains.  It was an unfortunate time,

 9     unfortunate circumstances, when we had to save our people.

10             JUDGE HARHOFF:  As I have already said, Mr. Glamocanin, I have no

11     objections against sending volunteers off to the war front, and I'm sure

12     that the Serbian armed forces and also the Serbian volunteers fought

13     bravely in the war.  But, again, I repeat, the issue here is not whether

14     it was correct or not correct to send the wars [sic] or even to wage the

15     wars.  The issue here is only:  How do we deal with the crimes that we

16     now know were, in fact, committed, because we have heard, in this trial

17     and in other trials before this Tribunal, abundance of evidence showing

18     that indeed, on both sides, civilian -- innocent civilians were tortured

19     and killed.

20             You mentioned just a while ago -- in fact, you confirmed this by

21     saying that you would accept that also on the Serb side, such crimes were

22     committed, but you then went on to say that if such crimes were committed

23     by Serbs against Croats or Muslims, then those crimes would certainly not

24     have been committed by the volunteers.  Do you remember that?

25        A.   Yes, I do.

Page 12964

 1             JUDGE HARHOFF:  Now, did you, in the Serbian -- in the SRS

 2     leadership, did you discuss the possibility of some of the volunteers

 3     committing crimes?  Was that something that was ever raised?  I'm asking

 4     because I'm curious to know, first of all, if you discussed the

 5     possibility and, secondly, what would you have done if it had been

 6     brought to your attention during the war that, indeed, crimes had been

 7     committed by Serbian volunteers?  What would your reaction have been?

 8     Would you have taken any measures to seek to have these people

 9     prosecuted, or kicked out of the SRS, or otherwise would any action have

10     been taken?

11        A.   They would certainly have been thrown out of the party if they

12     would be struck off the list of volunteers, and I'm sure they would have

13     been reported to the responsible organs of the JNA and later on to the

14     police.  We didn't want to have that blot on our party or slur on our

15     party or any of us.  We didn't want rumours stating that our volunteers

16     committed crimes.

17             I cannot claim that none of the volunteers committed any crimes,

18     but I cannot say, by the same token, that somebody did.  What I am saying

19     and can say is that measures would certainly have been taken against such

20     perpetrators.

21             JUDGE HARHOFF:  That was exactly the purpose of my question,

22     Mr. Glamocanin, because I wanted to know if there was a policy or a

23     position taken by the SRS leadership, that if any such thing would

24     happen, that measures would be taken immediately.  And you confirmed that

25     this was the case; is that correct?

Page 12965

 1        A.   Yes, that is correct, and we didn't want affirmation, as a party,

 2     were there war crimes, but we wanted to gain our party's assertion in the

 3     defence of our people in the right way, in the proper way.

 4             JUDGE HARHOFF:  Thank you, Mr. Glamocanin.

 5             In the next paragraph, paragraph 104, you seem to suggest that

 6     the issue of going to war, and that's also in the following paragraphs

 7     105 and 106, that the issue of going to war would be something that, in

 8     your view, would have to first be accepted by the International

 9     Community, and I wonder what you meant by this.  Can you clarify?

10        A.   I'm sorry, but which paragraph did you say?

11             JUDGE HARHOFF:  Excuse me, Mr. Glamocanin.  It was the

12     paragraph 104, 105 and 106.  It's just -- yes, please read it quickly,

13     but my question is simply this:  That you seem to say that it was the

14     understanding at the time that war should not be waged unless somehow it

15     had been accepted by the International Community?

16        A.   Well, by saying that, Mr. Seselj wanted to say that we must not

17     wage a war against the rights of other nations, but within the frameworks

18     of that which was the right of the Serbian people and all other peoples

19     too, which means that we had the right to defend our own nation, but

20     certainly not to have pretensions on Croatia and Bosnia-Herzegovina, to

21     take them over and to make them Serb lands.  We should set this subject

22     apart from the concept of a Greater Serbia.  Greater Serbia is a concept

23     which envisages evolution, perhaps hundreds of years of evolution,

24     whereas these are specific war conditions, and Mr. Seselj rightly

25     realised that, and Serbia in the conflict -- came into conflict with the

Page 12966

 1     International Community, and Serbia was the least to blame for all that.

 2     But never mind, we suffered serious consequences because of that, and

 3     this Tribunal is one such example and the result of that clash with the

 4     International Community or, rather, the unprincipled policy of the

 5     International Community and its organs.

 6             But Dr. Seselj viewed the situation properly and the issue

 7     properly, and he wanted to see that the Serbian people and the Serbian

 8     state, in going to war, was oriented exclusively to the defence of the

 9     Serbian people.

10             JUDGE HARHOFF:  Thank you for this answer.

11             I would not wish to go into a lengthy debate with you about the

12     policies, because I think this is not really what we're here for, but

13     there is one thing that strikes me in what you have just said, and that

14     is that, on the one hand, you say that you would not in any way infringe

15     the rights of other nations, and yet, on the other hand, you say that you

16     were there to fight for the Serbian cause and to secure Serbian land.

17     These two parts of what you have just said seem to me to be in

18     contradiction to each other.

19             As I said, I don't want you to give us a lengthy explanation of

20     it, but let me at least seek to verify if that is your position.

21        A.   Your Honour, we did not create the Republic of Serbia and

22     Krajina; it wasn't us, the Radicals.  The Serbian people living in that

23     region established it, and they saw it as the only way of saving the

24     lives of Serbs.  We were only helping our people.  And that the Serbian

25     people were right is proven by the expulsion of Serbs from Croatia.  We

Page 12967

 1     hear the numbers like 200.000, 380.000.  Believe me, it was 500.000 Serbs

 2     who left Croatia because of the policies brought on by Tudjman and the

 3     new authorities.  They -- Serbs were afraid as soon as they heard the

 4     public presentation of the programme and platform by Tudjman that

 5     reminded them of Paraga and the Pavelic regime.  We, the Radicals and the

 6     state of Serbia, supported the local Serbs.  In Bosnia and Herzegovina,

 7     again it was the local Serbs who created the Republika Srpska.  It was

 8     not us Radicals.

 9             JUDGE HARHOFF:  Thank you.

10             Mr. Glamocanin, you go on to say in paragraph 107 that you were

11     afraid that Seselj might be prepared for Serbia to become a victim.  This

12     is, indeed, what I think Mr. Seselj has confirmed to us at a number of

13     occasions, that in fact the Serbs were victims of all of this.  But you

14     say here that you were afraid that Seselj might be prepared for Serbia to

15     become a victim.  Why were you afraid?  Was that an erroneous position,

16     and was it true?  Do you agree that Serbs were the victims?

17        A.   Well, the Serbs were victims of all the circumstances that came

18     to prevail in the former Yugoslavia, because the Serbs lived across five

19     republics, in both provinces, and with the breakup of Yugoslavia the

20     Serbs were broken up.  They were left without a common state, and

21     solutions had to be sought that would be favourable to Serbs as well.

22     Numerous solutions were offered by the International Community, but many

23     of them were to the detriment of the Serbs.

24             I don't know what my thinking here was exactly, but at any rate

25     Dr. Seselj was always for the defence of the Serbian people, but not a

Page 12968

 1     kind of defence that would lead to a genocide against the Serbs.  He was

 2     very much in favour of defending the Republic of Serbia Krajina and

 3     everything else, but when this Republic of Serbian Krajina failed, we did

 4     not send volunteers to fight in Croatia.

 5             JUDGE HARHOFF:  Let me just understand you correctly.  My

 6     question was:  Why did you say that you were afraid that Seselj might

 7     embark on the victim image?

 8        A.   I can't remember what I meant by saying that.  It sounds a bit

 9     odd.  That's not really my thinking, that Seselj was prepared to

10     sacrifice Serbia.

11             JUDGE HARHOFF:  Thank you, Mr. Glamocanin.

12             THE WITNESS: [Interpretation] Thank you.

13             JUDGE LATTANZI: [Interpretation] Witness, I have a couple of

14     questions.

15             You, when answering questions put to you by the Presiding Judge,

16     you talked about the relationship that the SRS, and Mr. Seselj in

17     particular, had with Mr. Karadzic and Mr. Milosevic.  That's what you

18     talked about yesterday.  I would like to know whether you know anything

19     about the relationship between Mr. Seselj and Arkan.

20        A.   As far as I know, and that's also my position, Dr. Seselj did not

21     have much respect for Arkan, and the only good thing about Arkan was his

22     readiness to defend the Serbian people.  However, I must tell you I have

23     no insight into wartime activities of Arkan.

24             JUDGE LATTANZI: [Interpretation] So there was a common purpose,

25     common goal, pursued by Mr. Arkan and by the Serbian Radical Party, by

Page 12969

 1     Arkan's volunteers, as well as the volunteers from the SRS?

 2        A.   Ms. Lattanzi, Arkan could not be cooperated with.  He was a very

 3     categoric and exclusive man.  He wanted to command over both the army

 4     units and all the volunteer units.  We could not accept that, of course.

 5     We sent our volunteers to be subjected to the discipline and the

 6     structure and the programme and the military campaigns of the JNA.  Arkan

 7     was something different.  He wanted to command even officers.  It is well

 8     known that he threatened generals, even -- he was a brave man and he

 9     instituted strict discipline in the ranks of his units, but he was a

10     great individualist, to put it mildly.

11             JUDGE LATTANZI: [Interpretation] I understand that.

12             In military operations, there's command and so forth, but here in

13     this case we're not concerned with command responsibility.  I was just

14     referring to the programme that lay behind the activities, independently

15     of how the activities were conducted by Arkan's volunteers or by

16     Mr. Seselj - no, I apologise - of the SRS volunteers.  From what I

17     understood in your answer to my first question, the goal was shared by

18     the two.

19        A.   Well, the only common goal was to defend the Serbian people in

20     Croatia and in all other regions where the Serbian people were

21     threatened, but we had no party or any other cooperation with Arkan.

22             JUDGE LATTANZI: [Interpretation] Thank you.  I have one last

23     question, I'd like some information on one thing.

24             You said either yesterday or today that last spring, at the

25     spring of 2008, on your own initiative, you met up with the SRS because

Page 12970

 1     you wanted to join the SRS.  I would like to know the following:  I don't

 2     believe that you applied for the position of regional deputy.  I believe

 3     that somebody from the SRS -- from the leadership of the SRS must have

 4     offered the position or offered for you to take up the position.  Could

 5     you tell us who in the SRS actually offered that you apply for the

 6     position?

 7        A.   Well, nobody offered it to me.  In fact, I spoke to the president

 8     of the District Board of Pancevo District, and in talking we came to the

 9     conclusion that I should get involved in the implementation of the

10     programme of the Serbian Radical Party.  And in the course of that

11     conversation, I said that I saw the programme of the party and its

12     policies, regardless of the current rift within the party, as the only

13     programme, along with that of Vojislav Kostunica, that is able to conduct

14     a realistic and successful policy of recovery in Serbia, because, you

15     see, in Serbia the situation is very difficult.

16             Let me just give you two examples.  In Nis, for instance, only

17     70.000 people are employed.  Many more are unemployed; 40.000.  And in

18     2009, 15.000 will be laid off.  So the number of the employed and the

19     unemployed will be equal.  That's 50/50.  The amount of unemployment

20     among the youth is catastrophic.

21             JUDGE LATTANZI: [Interpretation] Thank you, yes.  I'm putting

22     questions to you, and you must answer my questions.  I was just asking

23     for a small piece of information, you know, like who is the president of

24     the Pancevo branch of the SRS?  Could you give us his name?

25        A.   The president of the District Board is Petar Jojic, a lawyer, a

Page 12971

 1     colleague of mine, a friend and acquaintance whom I see often and talk

 2     to.  But it's my decision.  Petar Jojic does not have to convince me.

 3     The time of persuasion is long gone.

 4             JUDGE LATTANZI: [Interpretation] Very well, thank you.

 5             THE WITNESS: [Interpretation] Thank you.

 6             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

 7             MS. BIERSAY:  Thank you, Your Honour.

 8             At this time, the Prosecution will move for the admission of the

 9     statement which currently has an MFI number, which is now MFI 688.

10             JUDGE ANTONETTI: [Interpretation] The Trial Chamber will

11     deliberate on this.  We will deliberate.

12             Mr. Seselj.

13             THE ACCUSED: [Interpretation] We cannot adopt -- admit a

14     statement allegedly given to the investigators of the OTP, first of all,

15     because the witness testified viva voce.  A statement cannot be

16     introduced through a viva voce witness.

17             Second, the witness himself refuted the authenticity of the

18     statement and stated several times that the contents of the statement had

19     not been read out to him before he signed it.  He also disputed the

20     specifics of the statement in several places.

21             And for all these reasons, if we are to respect legal principles,

22     it is impossible to admit this into evidence.  But if you intend to

23     flagrantly break the Rules, then you go ahead.

24             JUDGE ANTONETTI: [Interpretation] Very well.  As I said, the

25     Trial Chamber will decide on this and deliberate on this.

Page 12972

 1             Mr. Mundis.  For the Trial Chamber, the testimony is over.

 2             MR. MUNDIS:  I just have two observations, Mr. President, that

 3     can be made either in the presence of the witness or as the witness is

 4     being led out of the courtroom.

 5             JUDGE ANTONETTI: [Interpretation] Very well.

 6             Let me first thank our witness for having come upon the request

 7     of the Trial Chamber.  I wish you all the best for your return home, and

 8     I would like to ask our usher to please escort you out of the courtroom

 9     now.

10             THE WITNESS: [Interpretation] Thank you very much for your kind

11     wishes.

12                           [The witness withdrew]

13             JUDGE ANTONETTI: [Interpretation] Mr. Mundis.

14             MR. MUNDIS:  Thank you, Mr. President.

15             The Prosecution would certainly, just on the last point raised by

16     Dr. Seselj, the Prosecution certainly would submit that there are

17     adequate bases and legal grounds under the Rules for that statement to be

18     admitted into evidence, first of all.  And, second of all, there's

19     nothing that would lead to any conclusion that the admission of the

20     statement would be a flagrant violation of the Rules of Procedures and

21     Evidence.  The Chamber is certainly aware of the jurisprudence with

22     respect to the admissibility of written statements, particularly when a

23     witness has been present in the courtroom and subject to extensive

24     examination and cross-examination.

25             Let me, however, raise one very short point before the next

Page 12973

 1     witness is brought into the courtroom, and that concerns some of the

 2     allegations made by Mr. Glamocanin with respect to the interviews that

 3     were given and the staff members of the Office of the Prosecution that

 4     were involved in taking those interviews.

 5             The Prosecution categorically rejects any such allegations --

 6             THE ACCUSED: [Interpretation] Objection.

 7             MR. MUNDIS:  Just let me finish.  Let me --

 8             THE ACCUSED: [Interpretation] No, no, no, no.

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, Mr. Seselj, let

10     Mr. Mundis finish, and then you will reply.

11             THE ACCUSED: [Interpretation] And when the Prosecution interrupts

12     me, you don't say, "Let the accused speak and then you will respond."  As

13     soon as the Prosecution is on their feet, you interrupt me.

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, very often when you

15     want to take the floor, I let you take the floor, but this time the

16     Prosecutor has something to say following what the witness said.  I mean,

17     he is entitled to do so, and then you will reply, I'm sure.

18             Mr. Mundis, let me remind you that we have a witness waiting, so

19     please be brief.

20             MR. MUNDIS:  I will indeed, Mr. President.  Thank you very much.

21             The Prosecution categorically rejects these allegations made by

22     this witness with respect to the way in which the statements were given.

23     The Prosecution, without any prejudice to future developments in this

24     case, is prepared to make available to the Chamber any witness -- or any

25     staff member who was involved in the taking of this statement, to include

Page 12974

 1     Mr. Saxon, Mr. Pastore-Stocchi, Ms. Costello, Ms. Dahl, or any other

 2     member of the Office of the Prosecutor.  We are prepared to do that this

 3     afternoon.  There is courtrooms available if that would be suitable to

 4     the Trial Chamber.

 5             In addition, however, in light of the fact that there may be

 6     other witnesses who raise similar allegations, we would be prepared to

 7     make those individuals available to the Trial Chamber perhaps at the --

 8     towards the end of the Prosecution case.

 9             And I also will simply indicate that whether or not the Trial

10     Chamber, on its own, decides to call any of those staff members, the

11     Office of the Prosecutor is reserving its right to seek leave to add to

12     its witness list in order to add any such people who were involved in the

13     taking of statements, in the event we feel that it's necessary for the

14     Trial Chamber to have that evidence before the Chamber with respect to

15     what was done by the Office of the Prosecutor.

16             So we will make those people available if the Chamber wants to

17     call them.  We can do that this afternoon, we can do that later.  We will

18     make whatever steps need to be taken in order to bring those people

19     before the Trial Chamber, if the Trial Chamber feels that's important or

20     is in any way inclined to give credence to what this witness has said

21     with respect to those statements.

22             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you now have the

23     floor.  As you see, the Trial Chamber is letting everyone speak, so now

24     you have the floor.

25             THE ACCUSED: [Interpretation] What Mr. Mundis just said is

Page 12975

 1     completely pointless, from the legal point of view.  Mr. Mundis is

 2     proffering his own associates as indisputable moral or professional

 3     authorities.

 4             More than a year ago, I filed two criminal reports and one

 5     addendum against certain persons from the OTP, including trial attorneys

 6     themselves and also investigators, citing a lot of evidence against their

 7     unlawful -- of their unlawful conduct.  My motion to institute

 8     proceedings for contempt was not accepted, and I'll not interpret the

 9     decision of the Trial Chamber, but the Trial Chamber indicated that these

10     matters will be discussed too.  We discussed the possibility of bringing

11     a Defence witness or Defence witnesses who will bring it up, and we see

12     that some Prosecution witnesses bring it up too.  This is not the first

13     one.

14             The first Prosecution witness you brought and heard,

15     Goran Stoparic, stated here that there were things in his statement that

16     he had never said, although he was not kindly disposed to me.  I

17     contested his statement in many places, but he said that the passage in

18     his statement which says that I saluted people in Sid with a Hitler

19     salute was something he never said.

20             You know this procedure, that statements are taken in English,

21     subsequently only read to the witness, and translated only here much

22     later.  If somebody reads 20 pages to me, even though I believe myself to

23     be superior to all the employees of the Prosecution, I cannot always

24     focus and carefully follow all the 20 pages.  People are generally

25     divided into audio and visual types.  Very rare are audio types who can

Page 12976

 1     remember and understand everything they hear.  I, myself, am the visual

 2     type.  Which one of you can carefully listen to 20 pages being read?  No

 3     one.  That's why serious professors at the university do not read.  They

 4     read their lectures out of their head, and they have a number of

 5     strategies to keep the attention of the audience.  They use humour, they

 6     use specific examples, et cetera.  Who is able to listen carefully to 20

 7     pages being read out after four hours of interrogation?  Sorry, not four

 8     hours, four days, eight hours per day.  Nobody's capable of that.  And

 9     you want to offer that as evidence.  This is evidence of nothing, of

10     nothing at all.

11             I don't mind that the Prosecution calls all their employees to

12     appear here, but I am against extending their time by one single hour,

13     because the Prosecution has squandered so far a lot of their time by

14     bringing witnesses who had nothing to do with the indictment.

15             JUDGE ANTONETTI: [Interpretation] Very well.  Mr. Mundis stated

16     his views; you stated yours.  The Trial Chamber will make sure the best

17     is done.

18             And we're going to have the last witness now in this month.  I

19     understood, Mr. Seselj, this morning, that you had a few matters to

20     address.  You may as well do it now so that we only deal with the witness

21     after that.  So you may proceed.

22             We'll then have a ten-minute break, because we need to have a new

23     tape, so we'll have a short break.

24             You may proceed.

25             THE ACCUSED: [Interpretation] Well, I think, Judges, that this is

Page 12977

 1     a very important problem.  We'll now have 27 days of adjournment.  You

 2     scheduled the continuation for January the 8th.

 3             Already now, I have had no cooperation with my legal associates

 4     for two months, and I have had to prepare alone for the cross-examination

 5     of many witnesses in these two months.  And I'm not complaining and I'm

 6     not unhappy with the quality of my cross-examination, as it was, but

 7     please bear in mind this cooperation with my legal associates is

 8     indispensable to me.  I have to meet at least once with them before the

 9     continuation of the trial, I have to get new material and new information

10     from them, because they have been working diligently all this time.  I

11     have to have all this information, and I have to gain access to fresh

12     statements.

13             As far as I know, the Registrar addressed the President of the

14     Tribunal, as he had announced in that letter of his, seeking

15     interpretation and advice how to act under the latest decision of the

16     Chamber, and in the meantime I can communicate with only one legal

17     adviser and I can receive faxes that would not be supervised.  That is

18     not enough.

19             Earlier today, I sent a letter to the Registrar, explaining that

20     to all three of me legal advisers, Krasic, Jerkovic and Aleksic, as well

21     as to my case manager, Marina Raguz, I scheduled a visit for the 22nd and

22     23rd December.  I need two full days to talk to them, to organise my

23     documentation together with them.  And, mind you, if the issue of

24     financing my Defence is not resolved, I will not be presenting a Defence

25     case at all.  We will move immediately to the final brief.  I entrusted

Page 12978

 1     this work to my legal advisers.  It should be several hundred pages long,

 2     as far as I know from practice hitherto, and I will be preparing my

 3     closing arguments.  I need the cooperation of my legal advisers for that.

 4             I ask you to instruct the Registrar to enable me to meet with my

 5     advisers unhindered on the 22nd and the 23rd of December, to enable me to

 6     receive all the documentation from them, and they will take my

 7     documentation that I have to give to them, including the DVDs, so that

 8     they can transcribe them all, because I have to work with paper.  I

 9     cannot use the DVDs in anything that concerns prior testimony.

10             JUDGE ANTONETTI: [Interpretation] Let me answer straight away,

11     because everything you say is going to be read immediately in the

12     Registry's office, so they are aware of this.

13             You are asking for your associates, Jerkovic, Aleksic, Krasic and

14     Ms. Raguz, may be allowed to see you on the 22nd and the 23rd of

15     December.  Well, it's the Registry -- the Registrar that pays for

16     airfare, so it's up to him to decide.  This is not within the purview of

17     the Trial Chamber.

18             With regard to Mr. Aleksic, the Registrar asked you to provide a

19     telephone number, for that to be a privileged line.  Whether it was done

20     or not, I do not know at all.  It was for you to provide the telephone

21     number to Mr. Aleksic.

22             The Trial Chamber is of the view that you are to keep and

23     maintain a link with your associates, but there is a problem with regard

24     to Mr. Krasic because confidential information cannot be sent to him.

25     But he can send you anything.  He can even meet with you.  So in the view

Page 12979

 1     of the Trial Chamber, there's no technical obstacle or problem, as to

 2     whether you can see the people you've named.

 3             The Trial Chamber notes that you had absolutely no difficulty

 4     when cross-examining witnesses, because you know the case file very well.

 5             In January, we don't know how you will be able to cross-examine,

 6     failing other means, especially because you've been given a schedule.  We

 7     still have a few weeks before we resume in January.  In this way, you

 8     will be able to prepare appropriately.  As to the Registrar, he'll be

 9     able to see what he can do for your rights of defence can be exerted

10     properly.

11             That's all I can say now.

12             THE ACCUSED: [Interpretation] Mr. President, what is this legal

13     document that makes it impossible for Zoran Krasic to have insight into

14     confidential documents?  Please explain that to me.  What legal document

15     says that he cannot have insight into confidential material?  The

16     Registrar has banned me from having unsupervised and unmonitored

17     communication with him, and the Prosecution is just asking now for

18     insight into confidential material to be prohibited to him?

19             JUDGE ANTONETTI: [Interpretation] Wait a moment.  I must speak

20     with the legal officer.

21                           [Trial Chamber and legal officer confer]

22             JUDGE ANTONETTI: [Interpretation] There are scores, if not

23     hundreds, of decisions that are issued.  Therefore, it is sometimes

24     difficult to answer immediately to all the questions.

25             Back in November, the Trial Chamber issued a decision - you have

Page 12980

 1     received it - in which Krasic and Jerkovic no longer may access

 2     confidential material.  You were given the decision.

 3             THE ACCUSED: [Interpretation] No.

 4             JUDGE ANTONETTI: [Interpretation] You didn't receive it?

 5             THE ACCUSED: [Interpretation] I never received such a decision.

 6             JUDGE ANTONETTI: [Interpretation] I see.  It is a decision by the

 7     Registry.  The Registrar is the one who issued the decision.  Krasic and

 8     Jerkovic no longer may access confidential material, but the Registrar's

 9     decision is based on a previous decision by the Trial Chamber.  So,

10     please, do look at all this again.

11             THE ACCUSED: [Interpretation] Mr. President, I have never

12     received such a decision.  The Registry denied my right to unhindered

13     communication with the legal advisers, so I cannot talk to them over a

14     line that is not being listened in to, in principle, and nothing else.

15     And they refuse to pay for their previous trip to The Hague.  The

16     Prosecution is just asking now for these people to be denied insight into

17     confidential material.

18             JUDGE HARHOFF:  Mr. Seselj, let's just clarify what we are

19     talking about.

20             The Registrar decided to withdraw the privilege that had

21     previously been given to Mr. Krasic and to Mr. Vusic [sic].  He decided

22     to do so for a number of reasons, including allegations of intimidation

23     of witnesses and other reasons.  Now, once that privilege has been

24     withdrawn, Mr. Krasic and Mr. Vusic [sic] are no longer entitled to be

25     given confidential material that belongs to your trial.  That can only

Page 12981

 1     now be given to Mr. Aleksic, who is now your privileged counsel and the

 2     only one that you have.

 3              And let me just add that this also implies that when Mr. Krasic

 4     comes to town to see you, along with Mr. Aleksic and Mrs. Raguz, it is

 5     only Mr. Aleksic who will be entitled to have an unmonitored meeting with

 6     you.  The two others would be -- or at least Mr. Krasic, because I think

 7     the privilege still is with Mrs. Raguz.  But for Mr. Krasic, his

 8     privilege has been withdrawn, so he shall have to meet you as any other

 9     visitor; that is to say, monitored.

10             JUDGE ANTONETTI: [Interpretation] My colleague has just set out

11     the situation to you, and I refer you to the letter of 28th of November,

12     2008, that you received from the Registrar in your own language.  I have

13     it in your language, in which it is said that based on current

14     allegations, Mr. Jerkovic and Mr. Krasic are no longer authorised to

15     receive confidential information.  Therefore, the Registrar said that

16     these two advisers of yours can no longer have privileged access.

17             You can challenge this decision by the Registrar, putting it to

18     the President of the Tribunal, since this is an administrative decision

19     by the Registrar.  But as this has been just been said by my fellow

20     Judge, there are two people that you can see without any problem,

21     Ms. Raguz and Mr. Aleksic.

22             This is what I wanted to tell you.

23             What this what you wanted to address?

24             Well, since we were speaking about this, you know that our

25     hearings will resume on Thursday, 8th of January, I believe, at 9.00, so

Page 12982

 1     we'll work from 9.00 to 12.30 and then from 2.30 until 5.00, including on

 2     Friday, because we're going to have a viva voce witness, three hours for

 3     the Prosecution, three hours for you, so it will spill over into the

 4     Friday, and then we'll have a 92 ter witness.  That's our schedule.

 5             I have to have a break, a technical break, because the tape has

 6     to be replaced.  We shall resume at 12.00 with the witness who's been

 7     granted protective measures.  So the usher will have to lower the blinds,

 8     bring the witness in before we come in, in order not to waste time.

 9             So let's reconvene at 12.00.

10                           --- Recess taken at 11.44 a.m.

11                           [The witness entered court]

12                           --- On resuming at 12.04 p.m.

13             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, let us move into

14     private session for a few moments.

15                           [Private session]

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 12983











11 Pages 12983-12984 redacted. Private session.















Page 12985

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

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

13             JUDGE ANTONETTI: [Interpretation] Very well.

14             Mr. Prosecutor, please read the summary.

15             MR. MUSSEMEYER:  The witness was a Muslim inhabitant of

16     Bosanski Samac.  The town had about 3.000 to 4.000 inhabitants,

17     approximately.  2.000 of them were of Muslim faith.

18             The witness originates from a wealthy family.  He worked as a

19     waiter in a local restaurant, and thus was in a position to closely

20     observe the developments in the village.

21             At the beginning of 1992, the witness realised that his Serb

22     neighbours were packing their belongings and obviously preparing to leave

23     their houses.  When the witness asked one of them where they were going,

24     the answer was they were going to the country for a while.

25             The night of 16th April 1992, the witness was working at the

Page 12986

 1     restaurant.  There were only a few guests that night, which was quite

 2     unusual.  No Serbs were among the guests, so instead of closing the

 3     restaurant at about midnight or even later, like usual, the restaurant

 4     was already closed at about 2300 hours.

 5             In the night, at about 2.00 to 3.00, the witness heard shooting

 6     from the direction of the town.  When he went outside to check what was

 7     going on, he saw a large number of military vehicles moving in all

 8     directions.  The next morning, the witness saw military vehicles and many

 9     soldiers in JNA uniforms in the town.

10             On Radio Bosanski Samac, which was already renamed into Radio

11     Srpski Samac, it was said that the Serbian authorities have taken over

12     the Samac town and everything would be all right.  People were called

13     several times to hand over their weapons.  Nobody would be maltreated.

14     However, Croats and Muslims whom the Serbs suspected of having

15     distributed weapons before the outbreak of the conflict were arrested

16     immediately.

17             On 18th April 1992, the non-Serb inhabitants from Bosanski Samac

18     were ordered, via Radio Srpski Samac, to report the next morning at 8.00

19     at the TO building.  People not showing up would be killed immediately.

20     At the TO building, the non-Serb inhabitants of Bosanski Samac were told

21     that they had to perform forced labour on the following days.

22     Furthermore, they were ordered to wear a white ribbon and that more than

23     two non-Serbs were not allowed to get together in the streets.  The

24     following days, posters with this order appeared all over the town.

25             The next day, the witness and other non-Serbs from the town went

Page 12987

 1     to the TO building.  They all wore white ribbons.  While waiting for the

 2     registration, the witness heard terrible screams from prisoners inside

 3     the police building.

 4             The following days, the witness and his brother had to perform

 5     forced labour, like cleaning the town, collect broken glass, and clean

 6     weapons, et cetera.  He was forced to dig trenches and carry sandbags.

 7     Once, he found himself right in the middle of gunfire.

 8             One day, the witness saw Sulejman Tihic, the trained lawyer and

 9     local politician, sweeping the street in front of the police building.

10     The Serbs laughed at him and humiliated him, because he was an educated

11     man who now had to do this kind of work.

12             On 5th April 1992, the witness was arrested and brought to the

13     police building, where he was immediately brutally beaten with truncheons

14     and other tools by the chief of police, Stevan Todorovic, and others.  He

15     was asked for money and for his car.  In addition, they stole his gold

16     jewellery.  At the end, when he was bleeding, he was locked up in the

17     cell together with 13 other Croats and Muslims.  All of them looked

18     dreadful, were covered with blood, starved and exhausted.

19             The next day, two men called Lake and Nisa took the witness for

20     interrogation.  They started brutally beating him.  They asked for money

21     and gold, cut his neck and his ears, and Lake threatened him to cut his

22     fingers.  They told him, "You want to make a Muslim state in the heart of

23     Europe.  You will never get such a state."  At the end, Lake stuck a

24     screwdriver through his hand.

25             The following days, different members of the Serb guards

Page 12988

 1     constantly and brutally beat the witness and other detainees.  The

 2     witness was beaten on the head and other sensitive parts of his body, the

 3     consequences he is still suffering today.  They broke his jaw, knocked

 4     out his front teeth.  One day, he was also sexually abused.

 5             When a Red Cross delegation arrived in mid-May 1992, the most

 6     severely beaten prisoners were separated and locked into cells on the

 7     other side of the corridor.  The remaining detainees were provided with

 8     blankets, and when the Red Cross delegation arrived, the detainees did

 9     not dare to tell the member of the Red Cross the truth about their real

10     conditions.

11             The witness and other detainees were forced to participate in

12     systematic looting of properties from non-Serb inhabitants in and around

13     Bosanski Samac.  On 7th June 1992, while looting the house of a wealthy

14     non-Serb doctor, he witnessed the rape of a 17-year-old Croatian girl by

15     about 10 Serbian soldiers.  When the witness returned to the police

16     station, he was brutally beaten by Lugar, a commander of the Serb

17     Radical Party.  Lugar beat him with different kind of objects.  He wore a

18     chain made from children fingers and drove a car which was stolen from a

19     rich Muslim restaurant owner of the town.  While ferociously beating the

20     witness, Lugar used all kinds of tools he could get hold of at that

21     moment.  Among others, he used a heavy spanner and beat the witness on

22     all sensitive parts of his body, including his head and his genitals.  In

23     order to break his back, Lugar lifted the witness and throw him over his

24     knees.  He pulled out four of the witness teeth using repair pliers.  He

25     broke several of the witness teeth with the barrel of an automatic

Page 12989

 1     weapon.

 2             THE INTERPRETER:  Would you mind slowing down.  Thank you.

 3             MR. MUSSEMEYER:  At the end, the witness had to be transported to

 4     the local hospital, where he had to stay for recovery for about a month.

 5             In the hospital, the witness came across other Croat and Muslim

 6     inhabitants who had been inflicted serious injuries by members of the

 7     Serb forces in various prison camps of Bosanski Samac.  One of them was

 8     his former neighbour, who was in a very bad condition and told him that

 9     Serb soldiers and volunteers had inflicted him all the serious wounds

10     while he was detained in the TO building.  Also, Lugar had participated

11     in the beatings, using weapons and kicking him.  In addition, Lugar also

12     jumped several times on his stomach with all his weight.  This former

13     neighbour died a few days later in the witness arms.

14             When the witness was released from hospital on 8 July 1992, he

15     was brought back to the police station, where he had to help repairing

16     cars.  A few days later, he was taken by the guards to a nearby village

17     to take some parts from abandoned cars.  He saw the arrival of persons in

18     a truck.  The witness saw that Lugar took an elderly man from this group

19     and killed him with a pistol.

20             On 5 November 1992, the witness was exchanged.

21             JUDGE LATTANZI: [Interpretation] Would you mind slowing down.

22             MR. MUSSEMEYER:  I am done, Madame Judge.

23             Mr. Registrar, I would like to have the document with the ERN

24     number -- sorry, we have to go into private session.  I was reminded of

25     this.

Page 12990

 1             JUDGE ANTONETTI: [Interpretation] Let's move into private

 2     session.

 3             MR. MUSSEMEYER:  Mr. Registrar, could you please show the

 4     document with the ERN number --

 5                           [Private session]

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 12991











11 Pages 12991-13000 redacted. Private session.















Page 13001

 1                           [Open session]

 2             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

 3     you, Your Honours.

 4             MR. MUSSEMEYER:  Mr. Registrar, I would like you to move the

 5     document which bears the 65 ter number 2250 on the monitor.

 6        Q.   And when it's shown, Mr. Witness, can you please tell us what

 7     this photo depicts?

 8        A.   This photo depicts the yard, the police station yard or camp,

 9     with the garages, and we worked there, among other things, and we slept

10     there too.

11        Q.   Is this the location you have been beaten by Lugar?

12        A.   Yes, precisely where this white Golf car is, in the middle.

13     I think it's a Golf, Volkswagen Golf.

14        Q.   So the beating happened outside?

15        A.   Yes.

16             MR. MUSSEMEYER:  Mr. President, I would like to move this

17     document into evidence.

18             JUDGE ANTONETTI: [Interpretation] A number for this photograph,

19     please.

20             THE REGISTRAR:  Your Honour, this document shall be given Exhibit

21     number P692.  Thank you, Your Honours.

22             MR. MUSSEMEYER:  The last document I want to discuss with the

23     witness bears the 65 ter number 1734, and I would ask the Registrar to

24     bring it on the screen.

25             JUDGE ANTONETTI: [Interpretation] It's not to be broadcast, I

Page 13002

 1     believe.

 2             MR. MUSSEMEYER:  We are in the possession of a hard copy, and we

 3     can show this to the witness.

 4        Q.   Mr. Witness, could you please let us know what this document

 5     shows and if you remember about this document?

 6        A.   Yes, I do remember this document.  It is a certificate confirming

 7     that I was exchanged on the 5th of November, and this certificate was

 8     issued on the 6th of November, 1992.

 9        Q.   Does it also say that you have been arrested before you were

10     released?

11        A.   Yes, it does.  It says that I was imprisoned by the

12     Serbo-Chetniks of Bosanski Samac, and then it states the date I was

13     exchanged.

14             MR. MUSSEMEYER:  Mr. President, I would like to have this moved

15     into evidence.

16             JUDGE ANTONETTI: [Interpretation] A number, please,

17     Mr. Registrar.

18             THE REGISTRAR:  Your Honours, this document shall be given

19     Exhibit number P693.  Thank you, Your Honours.

20             MR. MUSSEMEYER:  And it should also be under seal.

21             THE REGISTRAR:  Under seal.  Thank you, Your Honours.

22             MR. MUSSEMEYER:  Your Honours, this concludes my examination.

23             JUDGE ANTONETTI: [Interpretation] Witness, I only have one

24     question for you.

25                           Questioned by the Court:

Page 13003

 1             JUDGE ANTONETTI: [Interpretation]  You were beaten.  This is

 2     obvious, but I wonder about those who actually beat you, because in the

 3     chain of responsibility we have to know who did what and who actually did

 4     this.

 5             So if I understood you correctly, this Lugar wore emblems of the

 6     Grey Wolves.  That's what you said when answering the questions put to

 7     you by Mr. Mussemeyer, and you confirmed this; right?

 8        A.   Yes, he was one of the Grey Wolves, and for a time they had the

 9     insignia of the White Eagles.  So rumour had it that they were Grey

10     Wolves, but sometimes he wore the uniform with the White Eagle emblem.

11             JUDGE ANTONETTI: [Interpretation] In April 1992, when these

12     events started, I believe that you were arrested on May 15 -- on May 5,

13     1992.  So from April to June 1992, I would like to know whether, in that

14     town, there was presence of the Serbian Radical Party as a recognised

15     political party, or maybe to help you, you could maybe -- they were just

16     Chetniks, describe these Chetniks to us?

17        A.   As far as the political situation is concerned, I really can't

18     say, but I seem to feel that I heard mention of the Serbian Radical

19     Party.  But during the war itself, that is to say, while I was an inmate

20     of the camp, I worked outside very often, and I often saw members of the

21     Chetniks, that call themselves Chetniks.  They call themselves Chetniks.

22     I saw them, and that's why I mentioned the name of Mr. Bozic, because I

23     knew that he was a Radical.  Now, whether a party existed, I don't know.

24     I did hear that it did, but I couldn't provide you with any exact

25     information on the subject.

Page 13004

 1             JUDGE ANTONETTI: [Interpretation] Regarding this Bozic, how did

 2     you know he was a member of the Radical Party, Serbian Radical Party?

 3     How did you know?

 4        A.   I knew that because his daughter, Georgina, was herself a

 5     Radical.  And since I used to go to school with her, I saw her on one

 6     occasion next to the camp.  She was wearing a camouflage uniform and had

 7     an automatic weapon, and she told me herself that she was a Radical.  And

 8     then subsequently I heard that her father was also a Radical, and I even

 9     think that I heard later on that he was still a Radical in Samac.

10             JUDGE ANTONETTI: [Interpretation] The daughter in the uniform,

11     can you tell us exactly when you saw her, what year, what month?

12        A.   That was sometime at the beginning when I was incarcerated.  Now

13     I can't give you a precise date, but, anyway, it was towards the start of

14     my incarceration, which would make it May, from the 5th of May onwards.

15             JUDGE ANTONETTI: [Interpretation] And she was in a camouflage

16     uniform, this girl?

17        A.   Yes, that's right.  She wore a camouflage uniform, and she had a

18     beret on her head.

19             JUDGE ANTONETTI: [Interpretation]  And she had a cap.  Very well.

20             JUDGE HARHOFF:  Thank you, Mr. Witness.

21             In your statement, you also explain that at a certain point, some

22     of the prisoners with whom you were together were sentenced falsely, so

23     that for the purposes of exchange, a heavy criminal could be exchanged

24     for, say, two Serbs in the process of exchanging Muslims and Croats with

25     Serbs.  And you tell us that you were sentenced to 25 years for that

Page 13005

 1     purpose, so that you would be worth more in an exchange process.  My

 2     question is:  Did you ever see the judgement, the false judgement that

 3     was handed down on you?

 4        A.   No, I didn't see it.  I said that in one of my statements, my

 5     previous statements.  I didn't see the judgements, and all this happened

 6     in Bijeljina.  Now, I wasn't in Bijeljina and Batkovic, but I did hear

 7     that I was given a 25-year sentence, and I also heard that we civilians

 8     that these trumped-up charges were made against, they said we were

 9     soldiers against the Serb people and things like that, they upped our

10     value in the exchange process so we would be worth more, and they'd say,

11     "Well, here we have a man who was up at the front," for instance, or

12     anything else, just so that they could get more people in exchange.

13             JUDGE HARHOFF:  I understand.  How did you learn about this

14     judgement that had been passed on you?

15        A.   I think I heard about it from Goran Blagojevic later on, that is,

16     because at that time I think he was a judge in Bijeljina or something

17     like that.  He was attached to the Bijeljina Court.

18             JUDGE HARHOFF:  And was the sentence and the judgement supposed

19     to have been handed down by the Court in Bijeljina?

20        A.   Yes.

21             JUDGE HARHOFF:  Thank you very much.

22             JUDGE ANTONETTI: [Interpretation] Sir, your testimony is now

23     over.  On behalf of my colleagues and myself, we express our deep

24     compassion for the terrible ordeal you went through.  We hope that these

25     terrible moments of your past will linger away with time, but we

Page 13006

 1     understand that you have been through a terrible ordeal, and we heard you

 2     and listened to what you had to say.  I thank you for coming here, even

 3     if mentioning all this was painful, probably.

 4             I will now ask our usher to please escort you out of the

 5     courtroom.  Don't move yet, because we will adjourn, so I believe we

 6     don't need to drop the blinds.

 7             I believe that we will now adjourn.

 8             Now, Mr. Mundis.

 9             MR. MUNDIS:  I just wanted to confirm the schedule with respect

10     to the witnesses that will appear during the week that we return after

11     the winter recess, being -- I can do this by numbers:  VS-65 and VS-1087.

12             I also wanted to indicate and put on the record that after the

13     break, in the week of 27 January 2009, pursuant to the schedule

14     previously circulated, VS-37 will appear, and in the week of 3 February,

15     VS-1066 will appear.  Both of those witnesses are the subject of

16     protective measures and delayed disclosure pursuant to the decisions of

17     the Trial Chamber.  We will be making that disclosure over the winter

18     recess, and I do want to put on the record that in the event that the

19     protective measures concerning those witnesses -- in the event those

20     protective measures are breached by the accused and/or his associates in

21     any way, that the Prosecution will take affirmative steps pursuant to

22     Rule 77 and/or any other applicable Rules, in the event of a breach of

23     those protective measures.  And I say that because, as I indicate, that

24     disclosure will be made over the winter recess, in the next short period

25     of time.

Page 13007

 1             JUDGE ANTONETTI: [Interpretation] Very well.

 2             This is our last hearing of the year -- yes.

 3             THE ACCUSED: [Interpretation] As Mr. Mundis threatened that the

 4     Prosecution would take firm steps of some kind, I have an additional

 5     question.  Will they be firm steps, just like the ones so far have been,

 6     or will they be even more stringent measures and steps than the ones

 7     we've seen thus far?

 8             JUDGE ANTONETTI: [Interpretation] This is a very theoretical

 9     debate.  The Prosecutor is saying that if there are problems, pursuant to

10     the Rules he will ask for measures to be taken.  But this is all

11     theoretical, at least as far as I'm concerned.  I can't imagine that

12     anything of that kind may happen.  The Prosecutor said what he had to

13     say.  You understood him, we understood him.

14             This is our last hearing of the year.  We will meet again in

15     early January, as I told you, and I wish you the best until then.  I hope

16     you will work hard to get ready for the hearings of January.

17             Thank you.

18                           --- Whereupon the hearing adjourned at 1.00 p.m.,

19                           to be reconvened on Thursday, the 8th day of January

20                           2009, at 9.00 a.m.