Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15972

 1                           Wednesday, 12 May 2010

 2                           [Open session]

 3                           [The witness takes the stand]

 4                           --- Upon commencing at 2.26 p.m.

 5                           [The accused entered court]

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

 7     call the case.

 8             THE REGISTRAR:  Good afternoon, Your Honours.

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

10     Vojislav Seselj.

11             JUDGE ANTONETTI: [Interpretation] Thank you, Registrar.

12             We have started a few minutes late because the previous hearing

13     finished a few minutes late on the schedule, so we are starting only now.

14             Following a decision from the Trial Chamber, I would like to say

15     that the public order of redaction that had been issued on the 8th of

16     April, 2008 [as interpreted], dealing with page 29509 of the transcript

17     in the English version, has to become confidential in order to protect

18     the people that were mentioned on that page.  There you go.

19             Secondly, the Prosecutor has an hour and 36 minutes left, and

20     Mr. Seselj will have his two hours.  Given that we are very short of

21     time, I'm asking everyone to use their time to the best of their

22     abilities.  And if there are objections that are not justified, the time

23     will be deducted.

24             So, Ms. Biersay, please proceed with your questions.

25             MS. BIERSAY:  Thank you, Your Honour.

Page 15973

 1                           WITNESS:  ZORAN RANKIC [Resumed]

 2                           [The witness answered through interpreter]

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

 4        Q.   Good afternoon, Mr. Rankic.

 5        A.   Good afternoon.

 6        Q.   I'd like to start just by giving two little reminders.  I know

 7     that we don't speak the same language, but you do understand some

 8     English.  If you could just -- that's right, you do understand some

 9     English?  You're nodding your head.  You have to say out loud.  But if

10     you just wait for the translation before you answer, it will be helpful,

11     even if you understand what I'm saying.  Do you understand?  You have to

12     answer out loud.  Yes or no.

13        A.   I understand a little, but really very little.

14        Q.   Okay, so it shouldn't be a big problem for us.

15             The second thing I wanted to clarify was something you described

16     to the Trial Chamber yesterday about your Defence statements.  Do you

17     recall how many Defence statements you provided to the associates of the

18     accused?

19        A.   If I remember well, two or three.

20        Q.   Now, do you recall when you gave them?

21        A.   Beginning with 2007, through 2008.

22             MS. BIERSAY:  If I could ask the Registrar to call up in e-court

23     the subpoena objection, going to the last page.  I wanted to show

24     Mr. Rankic this.

25        Q.   Do you recognise that signature at the bottom of that page?

Page 15974

 1        A.   Yes.

 2        Q.   Whose signature is it?

 3        A.   Mine.

 4             MS. BIERSAY:  Now, for the record, this is -- if we could go to

 5     the first page in the B/C/S as well as English.

 6        Q.   That is objection to the subpoena that was issued to you

 7     December 4th of 2007, and the date on it is 24 December 2007; is that

 8     correct?

 9        A.   Yes.

10        Q.   Now, you described to the Trial Chamber that you had prepared the

11     previous -- all the statements you gave to the Defence, and I believe you

12     said that your son had helped you to type them up.  Did you also prepare

13     this one?

14        A.   To draft this document, I had the assistance of my legal counsel,

15     who is my close friend.  He is a lawyer.  And I have absolutely no legal

16     knowledge, so somebody had to help me with the legal clauses.

17        Q.   And what's the name of your friend?

18        A.   Do I have to say it in open session?

19             MS. BIERSAY:  It is necessary, Your Honour.  I'd be happy to go

20     into closed session.

21             JUDGE ANTONETTI: [Interpretation] Let's move to closed session.

22                           [Private session]

23   (redacted)

24   (redacted)

25   (redacted)

Page 15975











11  Page 15975 redacted. Private session.















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17   (redacted)

18   (redacted)

19                           [Open session]

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

21             MS. BIERSAY:  And for the Court's information, we, too, are

22     interested in the events that happened in that time-period.  What became

23     very clear yesterday is that this witness is now departing from his

24     previous statements about those events, and that will be the crux of my

25     examination.

Page 15977

 1        Q.   Mr. Rankic, you were contacted by OTP investigators in March of

 2     2003, correct, the very first time?

 3        A.   If I remember well, it was in August 2003.

 4        Q.   Okay.  I'm not going to argue with you.  But to the extent that

 5     our internal records show something else, let's take your date,

 6     August 2003.  You were contacted by investigators, and they asked you to

 7     come to a formal interview; is that right?

 8        A.   Well, yes, that's the date of my first statement.  I believe it's

 9     dated August 2003.

10        Q.   Mr. Rankic, so that we don't have to -- the Prosecution asks the

11     Court to bring you back here at another occasion to complete your

12     testimony, it's important that you listen to my questions.  To the extent

13     that I ask you for a yes or no, just say yes or no, and I will follow up

14     with more, if needed.  Do you understand?

15        A.   Yes.

16        Q.   You were contacted by OTP investigators, and they invited you to

17     come to the office in Belgrade for a meeting, an interview; is that

18     correct?

19        A.   No, it's not correct.

20        Q.   Did you go to the OTP office in Belgrade in August of 2003?

21        A.   Yes.  But before that, they called my family and threatened my

22     family, that unless I come, I will be brought in by the police.  That

23     means they'll bring me in by force.

24        Q.   I'll be forced to ask the Court to bring you back if we can't get

25     through this in time today, so again I will ask you to answer with yes or

Page 15978

 1     no.

 2             The question to you is:  Were you invited to come to a meeting

 3     with members of the Office of the Prosecutor in August of 2003?

 4        A.   I came to the interview.

 5        Q.   Were you escorted to the interview by police from your house?

 6        A.   No.  That's why I went on my own two feet, to protect my family.

 7        Q.   It's yes or no.

 8        A.   No, I was not escorted by the police.

 9        Q.   And from your house, were you escorted by any OTP representative?

10        A.   No.

11        Q.   When you went to the office, you met -- isn't it true you met

12     with Investigator Paolo Pastore Stocchi and Investigator Sabine Shulz?

13     You have to say, Yes, into the microphone.

14        A.   Correct.

15        Q.   There was also a translator there to assist with the

16     communication between the three of you; is that correct?

17        A.   Yes.

18        Q.   The representatives of the OTP, the investigators, asked you

19     questions about what you knew about the events of 1990, 1991, and 1992;

20     is that correct?

21        A.   Something like that.

22        Q.   They asked you about what you did during that time-period; right?

23        A.   Yes, but also before that period, my entire life.

24        Q.   And they asked you a lot of questions; right?

25        A.   Yes.

Page 15979

 1        Q.   And you answered them to the best of your ability; right?

 2        A.   Correct.

 3        Q.   In the room, at any time, were you beaten by these investigators?

 4        A.   No, no.

 5        Q.   And I see you laughing at that.  It sounds ridiculous to you,

 6     does it?

 7        A.   Well, it is ridiculous.

 8        Q.   Were any of the investigators armed?

 9        A.   Not that I noticed.

10        Q.   And, again, you're laughing because it sounds ridiculous to you,

11     doesn't it?

12        A.   Well, this is the first time I hear of the notion of armed

13     investigators.

14        Q.   So you gave a lot of information to the investigators in August

15     of 2003, and it was reduced to writing; right?

16        A.   Yes, that was the beginning.

17        Q.   And when you tried to give the information, you tried to give it

18     in a chronological order of when things happened; right?

19        A.   I tried to follow the chronology to the best of my recollection.

20        Q.   And the investigators told you, Follow the -- stick to the

21     chronology; right?

22        A.   No, they asked questions haphazardly, while I tried to keep to

23     the chronology.

24        Q.   Your statement, which is in your binder under tab 1, after you

25     gave the information to the investigators, they produced a document in

Page 15980

 1     English; correct?

 2             And that is 65 ter 7538, and it's in the Court's binder 1 at

 3     tab 1, if the Court would like to follow the hard copy.

 4             So what you -- the information you gave to the investigators,

 5     that was reduced to a written statement; right?

 6        A.   If Madam Biersay gave me leave, I could explain this, and I'll

 7     try to be very brief.

 8        Q.   But what I want to know is:  They produced for you a written

 9     statement; correct?

10        A.   That was at the end of day 3.

11        Q.   Now, according to the statement, you were interviewed on the 4th

12     and the 5th of August, 2003.  Does that refresh your recollection about

13     how many days it was?

14        A.   Possibly, then it was at the end of day two.

15        Q.   So it was reduced to a written format; correct?

16        A.   Yes.

17        Q.   The interpreter assisted in explaining to you the contents of the

18     written statement that was in English; correct?

19        A.   Before that, the interpreter read back to me from the laptop,

20     what I had stated, while the questioning was still underway.

21        Q.   And at the end, you were presented with a document from those two

22     days of interviews, and you signed that document; correct?

23        A.   Yes, but --

24        Q.   One step at a time.  You signed the document; is that correct?

25        A.   Yes, but you're not letting me explain.

Page 15981

 1        Q.   I'm asking you yes-or-no questions.  You signed the document on

 2     all pages, and you signed it at the very end; correct?

 3        A.   Yes.

 4        Q.   And the interpreter also signed, and she signed on page 19 in the

 5     English, 18 in the B/C/S.  What she signed on the 5th of August, 2003:

 6             "Zoran Rankic has acknowledged that the facts and matters set out

 7     in his statement, as translated by me, are true to the best of his

 8     knowledge and recollection, and has accordingly signed his signature

 9     where indicated."

10             You're turning the pages rather slowly.  It is on page 18, as I

11     said before, and I am --

12        A.   Eighteen.

13        Q.   Number 4.  You see that, don't you?

14        A.   Yes.

15        Q.   Now, between day 4 -- between the 4th and the 5th of August, you

16     were allowed to go home at the end of the interview?

17             JUDGE ANTONETTI: [Interpretation] Witness, I was not planning to

18     ask any questions of a technical nature, because I will recuse myself

19     regarding the part invoking Carla Del Ponte on contempt issues.  So I

20     have to remain very general on my questions, but I have just a technical

21     question to ask you regarding a document that was signed by the

22     interpreter.

23             The interpreter, and I'm not giving her name, states that she

24     hereby has translated the facts and the topics that were touched upon in

25     your statement, so what I would like to know:  When the 19 pages were

Page 15982

 1     translated into English, I was wondering whether the interpreter

 2     translated into your own language the entirety of the 85 paragraphs,

 3     which could take some time.  Has she done that; yes or no?  Has she said,

 4     Mr. Rankic, we are going to show you a document in English, a document of

 5     exactly 17 pages; I'm going to translate the entirety of the document.

 6     First paragraph, and then she translates in your own language the first

 7     paragraph.  And the second paragraph, My name is Zoran Rankic, I'm Serb.

 8     And she translated that into your own language.  And the third paragraph,

 9     You were conscripted within the JNA in 1976 [as interpreted].  And fourth

10     paragraph, and so on and so forth.  Has she done that?  Has she

11     translated the whole document, one paragraph after another, and

12     thereafter you signed the 17 pages?  This is the question that I would

13     like to put to you.

14             THE WITNESS: [Interpretation] Your Honour, while the interview

15     was underway she was reading to me from the laptop, and later on she said

16     that all of that would be merged and brought to me for my signature in

17     Serbian.  And I asked for all that to be shown to me, but the statement

18     was never given to me in Serbian.

19             JUDGE ANTONETTI: [Interpretation] Very well.  So you are saying

20     to us, and this is important, that the full 17 pages were not translated

21     to you by the interpreter before you signed at the end of the document.

22     But during questions and answers put by the investigators, questions were

23     interpreted to you and all the discussions were interpreted to you, but

24     the interpreter did not read all 17 pages in your own language.  It is

25     very important.

Page 15983

 1             THE WITNESS: [Interpretation] No, we did not understand each

 2     other.  She did bring me the translation of all the 17 pages, and I

 3     signed, but I asked for a copy to be submitted to me subsequently.  At

 4     7.00 in the evening, after two days of questioning, my psychological

 5     state was not the best, and I could not concentrate any more.

 6             JUDGE ANTONETTI: [Interpretation] Very well.  So you're saying

 7     that she brought a translation in your own language of all 17 pages.  So

 8     why is it that you did not sign this document in B/C/S if you had a B/C/S

 9     version of that document?

10             THE WITNESS: [Interpretation] I signed what they asked me to

11     sign.

12             JUDGE ANTONETTI: [Interpretation] Thank you.

13             Ms. Biersay, please proceed.

14             MS. BIERSAY:

15        Q.   Just to clarify, when you signed on August 5th of 2003, did you

16     see a B/C/S version of the statement that you'd signed in English?

17        A.   Yes.

18        Q.   Now, let's fast-forward now to January of 2004.  Again in

19     Belgrade, you received a scheduling call for another interview; is that

20     correct?

21        A.   Again through my family.

22        Q.   So are you saying that the investigators didn't speak to you

23     directly about coming in for an interview in January of 2004; is that

24     what you're telling the Court?

25        A.   All of the contacts were through my family.

Page 15984

 1        Q.   And again you went to the interview; is that correct?

 2        A.   Yes, in order to avoid any consequences that might have arisen.

 3        Q.   Mr. Rankic, I'd appreciate it if you kept your answers to match

 4     my questions.  Now, when you went to the same office to have this

 5     interview, this time there are two totally different investigators from

 6     the OTP; is that correct?

 7        A.   Yes.

 8        Q.   And a totally different interpreter; right?

 9        A.   I believe that there was a different interpreter, if my memory

10     serves me well.

11             MS. BIERSAY:  And this is in e-court as 65 ter 7539, and it

12     should be in binder 1, tab 2, for the Court.

13        Q.   And in this statement that you gave, you specifically were shown

14     your previous statement from 2003 and asked to make corrections and

15     clarifications to the 2003 statement; right?

16        A.   No, not correct.

17        Q.   Turn to tab 2 of your binder, please.  And if you could look at

18     paragraph 3, paragraph 3.

19             Mr. Rankic does seem to take a lot of time in getting to the

20     places that I direct him to, so I wonder if the usher could stand by him,

21     perhaps, to assist and make this a little bit more speedy.

22             Now, in paragraph 3 of your 2004 statement, it specifically says

23     that you were provided with a signed -- that you were provided with a

24     copy of that signed statement and that you were asked to clarify some

25     issues discussed in that previous statement; right?

Page 15985

 1        A.   Well, that's what is written here.  Perhaps, but I was never

 2     provided with that copy.

 3             JUDGE HARHOFF:  Ms. Biersay, could you enlighten us whether the

 4     copy that the witness was given was in English or B/C/S?

 5             MS. BIERSAY:  The copy, as the Court will see, as the signed

 6     version, is the English version.

 7        Q.   So, in your 2004 statement, you clarified what you told them in

 8     August of 2003; right?

 9        A.   There were some more questions and more questions.

10        Q.   Let's turn to paragraph 17 of your 2004 statement.

11             In paragraph 23, and I'm quoting:

12             "I would like to delete the sentence reading, 'The two republican

13     ministries existed at the time.  It was not at the federal level.'  This

14     is a mistake and doesn't make any sense to me."

15             Do you see that?  So you corrected the 2003 statement that was

16     presented to you again in 2004; right?

17        A.   Whatever was shown to me was on the laptop.

18        Q.   Okay.  You were shown -- whether it's an electronic version or a

19     hard-copy version, you were shown your previous statement and you were

20     allowed to make corrections to it; correct?

21        A.   You did not allow me to say at the very beginning how everything

22     transpired, so it is pointless for me to go on explaining what happened

23     next.  You did not allow me an introduction into what I was going to say

24     next.

25        Q.   And you signed the 2004 statement as well in English; correct?

Page 15986

 1        A.   Yes, I signed all the statements that I provided.  Let's not

 2     waste any more time on whether I signed or not.  I signed all of them.

 3        Q.   So this interview was conducted on the 17th, 18th, and 19th of

 4     January of 2004; correct?

 5        A.   Probably.

 6        Q.   And at the end of each day, you went home, and you would come

 7     back the next day; right?

 8        A.   Yes, yes.

 9        Q.   And at no time in 2003 did you report any allegations about the

10     OTP threatening you.  Did you do that in 2003?

11        A.   I apologise.  Who do you think I should have turned to and report

12     them?

13        Q.   I'm asking you a question.  Did you go to the police with reports

14     about OTP misconduct in 2003; yes or no?

15        A.   This is really preposterous.  This is funny.

16        Q.   Yes or no?

17        A.   For me to report an international organisation to the Serbian

18     police?

19        Q.   Did you go to a local newspaper to let them know what was

20     happening?  Did you do that in 2003?

21        A.   No.  My honour would not allow me to do that.

22        Q.   You didn't report these allegations in 2003; you didn't report

23     them in 2004; and you didn't report them in 2005.  Is that right?  You

24     have to answer --

25        A.   That's right.  I was waiting to come here to the Tribunal and

Page 15987

 1     present all that before the Trial Chamber.

 2        Q.   Did you write the Trial Chamber to tell them about what was

 3     happening?  Did you call the Trial Chamber?

 4        A.   No, I was waiting for the regular procedure to continue for me to

 5     come to the court.

 6        Q.   Now, in June of 2006, on the 13th, you met again with

 7     Investigator Stocchi -- Pastore Stocchi, and you met with attorney

 8     Dan Saxon, and the purpose of that meeting was to finalise a statement

 9     that would be used for your testimony in this case; correct?

10        A.   Yes.

11        Q.   And you began that process in June 2006, but it was not

12     completed, the statement was not completed in June of 2006; right?

13        A.   That's right.

14        Q.   And that is because you told them and reported that you had been

15     approached by a group of people in Belgrade and told not to play with

16     your life; right?  You reported threats to you?

17        A.   That's a fabrication.

18        Q.   And didn't you also tell them that your son had answered the

19     phone and someone threatened to blow you up?  Didn't you tell them that?

20        A.   I did say that, but that has nothing whatsoever to do with the

21     Serbian Radical Party.  It had to do with an idiot who was a protected

22     witness here.  Let me not mention his name.

23        Q.   Mr. Rankic, I'm confused.  Before, you said that's a total

24     fabrication; and then you said that you did say that.  Which one is it?

25     Is it a fabrication, or did you tell the investigators that there were

Page 15988

 1     threats against you?

 2        A.   What the investigator said is not correct.  However, what my son

 3     told me, that is correct, because there was an idiot who threatened him

 4     on the phone.

 5        Q.   And you also told them that you thought not that it was connected

 6     with the SRS or anyone else, that it was connected with your co-operation

 7     with the OTP?  That's what you told them in 2006; correct?

 8        A.   That's what I thought at the time.  Later on, I realised that it

 9     was something else.

10        Q.   But that's what you told them.  And out of concern for your

11     safety, as early as June 2006, there was a discussion about relocating

12     you for your own safety; right?

13        A.   That was just one of the reasons.

14        Q.   And, in fact, you even assisted them in identifying the country

15     to which you would prefer to be relocated.  You told them that you wanted

16     to go to Sweden; right?  In 2006, you told them that you wanted to be

17     relocated to Sweden because you knew people there.

18        A.   Correct.

19        Q.   The Victim and Witness Unit did a threat assessment with you in

20     July of 2006, again about the issue of relocating you to Sweden; correct?

21        A.   I don't know what they did, but it all came to nothing.

22        Q.   In September of 2006 -- I'm now directing your attention to the

23     first statement that you signed in your language, and that was the 89(F)

24     statement that's in your binder behind tab 3.  We talked about it

25     yesterday.

Page 15989

 1             Now, on the 18th and 19th of September, you were interviewed by

 2     Attorney Dan Saxon; correct?

 3        A.   You mean the Prosecutor?

 4        Q.   Yes.

 5        A.   Probably.  I don't know the date.  I should be allowed to consult

 6     my papers.

 7        Q.   They're right in front of you, tab 3.  And if you could stay

 8     close to the mike, so each time you don't spend a lot of time trying to

 9     get to the mike, it would help us to go a little bit faster.

10             So for your 89(F) statement, signed in B/C/S on the 18th and --

11     from interviews conducted on the 18th and 19th of September, 2006, you

12     were interviewed by Dan Saxon, Paolo Pastore Stocchi, and another

13     investigator by the name of Marie Costello; right?  That is right on the

14     first page of your statement.

15        A.   Yes.

16        Q.   And, in addition, there were four interpreters that -- excuse me,

17     three interpreters or four interpreters who participated in the

18     interpretation between you and the investigator and the attorney;

19     correct?

20        A.   Yes.

21        Q.   And that statement incorporated items from the first two

22     statements as well as some additional information; right?

23        A.   Probably.

24        Q.   Now, if you could go to paragraph 46.  So not only did it

25     incorporate the previous statements and add additional information, the

Page 15990

 1     interviewers sometimes asked you questions that you didn't know the

 2     answer to; right?  Mr. Rankic, did they sometimes ask you questions that

 3     you didn't know the answer to?

 4        A.   There were many such questions.

 5        Q.   And, for example, in paragraphs 46 and 47 -- paragraph 46, I

 6     read:

 7             "I do not know whether Seselj ever met with Pavlovic/Popovic in

 8     person."

 9             At the beginning of paragraph 47:

10             "I do not know anything about the relationship between

11     Brano Grujic and Seselj."

12             So the statement also captured the type of information that you

13     gave as well as the information that you didn't know; right?

14        A.   Yes, there were all sorts of information; ones, others, the third

15     type of information.

16        Q.   So if the OTP were crafting a statement to suit its own purpose,

17     it would -- the representatives would have just put in the information

18     they wanted.  They wouldn't have put down your response, which was:  "I

19     do not know."

20        A.   I am not saying that the OTP changed absolutely everything in my

21     statement.

22        Q.   Just the ones that are not favourable to Mr. Seselj --

23             JUDGE ANTONETTI: [Interpretation] Witness, Ms. Biersay is quite

24     rightly telling you that if the OTP had wanted to conceal a number of

25     things, these things would not have been mentioned.

Page 15991

 1             In paragraph 46, what is mentioned is extremely important for us

 2     Judges.  It has to do with a meeting of the Serbian Radical Party in

 3     Mali Zvornik in mid-April 1992.  You say in paragraph 46 that this

 4     meeting was held, and you say:

 5             "I know that Seselj was there or that he took part in that

 6     meeting."

 7             However, after that you say that Pavlovic and Seselj may have

 8     met, but you cannot confirm that because you were not there.

 9             What I'm interested in is this:  Was Mr. Seselj at this meeting

10     in Zvornik in April 1992; yes or no?

11             THE WITNESS: [Interpretation] Your Honour, I believe that I said

12     that already yesterday.  The rally of the Serbian Chetnik Movement took

13     place in 1990.  There was no rally in Mali Zvornik in 1992 of the Serbian

14     Radical Party, because the armed conflicts were ongoing in Bosnia at the

15     time and you can only imagine what would have happened if any such rally

16     had taken place.  There would be a lot of dead people.

17             JUDGE ANTONETTI: [Interpretation] In that case, sir, why, in your

18     own language in paragraph 46, do you say that this meeting took place?

19     This is what I'm trying to understand.  And you signed this statement in

20     your own language, and this is what Ms. Biersay is highlighting.

21             THE WITNESS: [Interpretation] The OTP suggested that they had

22     witnesses who can prove that there was a rally in 1992, that they have

23     statements to that effect by other witnesses, although I claimed that it

24     was in 1990.  And finally I said, Well, maybe, maybe there was.

25             JUDGE LATTANZI: [Interpretation] I have a question.

Page 15992

 1             Notwithstanding the rally and an important meeting, was there

 2     just a simple visit by Mr. Seselj in Mali Zvornik in April 1992?

 3             THE WITNESS: [Interpretation] I really don't remember any such

 4     thing.

 5             JUDGE LATTANZI: [Interpretation] I have another short question

 6     for you.

 7             You said to the Prosecutor that you wanted to denounce misconduct

 8     of the OTP when you came to testify before the Trial Chamber.  Could you

 9     explain to us, please, why two subpoenas needed to be issued for you to

10     come and testify?  We had great difficulty in serving the document on

11     you.  We had to resort to the Ministry of the Interior to do so.  Could

12     you enlighten us on this, please.

13             THE WITNESS: [Interpretation] Yes, of course.

14             First of all, I work in construction, which means that I am

15     rarely in Belgrade.  I work all over the place.  That's the first reason.

16             The second reason were my health problems.  I have medical

17     documentation that I forwarded to the Trial Chamber to explain why I

18     couldn't come when I was subpoenaed.  In other words, every time I

19     couldn't come, I could justify those absences by valid medical

20     documentation.

21             JUDGE LATTANZI: [Interpretation] Thank you.

22             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

23             MS. BIERSAY:

24        Q.   After you signed the B/C/S version or the original of your

25     statement from September 2006, you again had a meeting with VWS to

Page 15993

 1     confirm the relocation plans; isn't that right?

 2        A.   Yes.

 3        Q.   The Registrar, not the OTP, approved your relocation to

 4     The Hague, and the plan was for you to come one month before you were to

 5     testify and stay for one month after your testimony in The Hague; isn't

 6     that right?

 7        A.   I really don't remember those details.

 8        Q.   You, with the assistance of members of VWS, did, in fact,

 9     relocate to The Hague on October 6, 2006; correct?

10        A.   Approximately.  I don't know how to explain.  I was told that I

11     was under threat in Belgrade, and that's why -- one of the reasons for

12     which I had to go to The Hague.

13        Q.   But in June 2006, you reported to the OTP about threats being

14     made against you and your family; right?

15        A.   You're talking about the case involving my son that I mentioned

16     just a while ago.

17        Q.   Mr. Rankic, let's not --

18        A.   It has nothing to do with what happened later.

19        Q.   Let's not make this longer than it needs to be.  You reported

20     threats in June of 2006, and in July of 2006 VWS had already started

21     taking action in order to address your threat issues; right?

22        A.   They started to deal with it, but that was not the only reason.

23     There was another reason.  I was told that all my statements had been

24     stolen at the Belgrade Airport and that I needed to come to The Hague to

25     re-give all my statements.

Page 15994

 1        Q.   And you were told about your statements being taken -- you were

 2     told about that in September of 2006, well after you reported the threats

 3     in June of 2006; right?  You have to say, Yes, into the microphone.

 4     That's why I suggested that you sit closer.  You're nodding your head.

 5             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, do not forget that

 6     the witness has a back problem, which might explain why he leans back.

 7             MS. BIERSAY:  Could we get a portable microphone, then?  Maybe it

 8     would simplify things.

 9             JUDGE ANTONETTI: [Interpretation] Just proceed for the time the

10     way things are.

11             MS. BIERSAY:  So let me rephrase the question or ask the question

12     again.

13        Q.   The issue of you relocating to Sweden came up in June of 2006,

14     when you suggested the country to the OTP and later to VWS; right?

15        A.   Yes.  At that time, I was in a hopeless situation in Serbia,

16     without a job.  I had just divorced.

17        Q.   I'm sure we'll -- Mr. Seselj will get into all of those with you.

18     What I would like to know is:  You were relocated to --

19             THE ACCUSED: [Interpretation] Objection.  Ms. Biersay cannot

20     suggest what I'm going to deal with.  Maybe I'll deal with Ms. Biersay,

21     herself, in my cross-examination.

22             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, let Ms. Biersay

23     continue.  She quite rightly believes that you are going to address this

24     part of the questions.  I also believe that you will address this line of

25     questions.

Page 15995

 1             THE ACCUSED: [No interpretation]

 2             JUDGE ANTONETTI: [Interpretation] All the better, we shall gain

 3     some time.

 4             MS. BIERSAY:

 5        Q.   Let's fast-forward.  You arrived in The Hague, is that right, in

 6     October of 2006?

 7        A.   Yes.

 8        Q.   And VWS took care of getting you a place to stay, an apartment;

 9     correct?

10        A.   Correct.

11        Q.   You had a stipend of 25 Euros a day; is that correct?

12        A.   Yes.

13        Q.   They gave you a special ID to allow you to move freely in the

14     Netherlands; correct?

15        A.   In the Netherlands, probably, yes.

16        Q.   You had your own key to the apartment?  You could come and go in

17     the apartment whenever you wanted to; right?

18        A.   Yes.

19        Q.   And you stayed in The Hague from October 2006, and you left in

20     December of 2006; correct?

21        A.   Correct.

22        Q.   And while you were here, you met two more times -- well, more

23     than two more times, but you signed two more statements, one an addendum

24     to the September 2006 statement.  So you signed an addendum in October of

25     2006; correct?  And that is at tab 4 in your binder.

Page 15996

 1        A.   Correct.

 2        Q.   And that, too, was in your language; right?

 3        A.   The same system, an electronic version on the laptop.  It was

 4     later printed, and I signed.

 5        Q.   And you signed the version in your language; right?

 6        A.   Yes, without reading it.

 7        Q.   The first addendum to the statement made corrections to the

 8     September 2006 statement, didn't it?

 9        A.   Yes, there were certain corrections that needed to be made.

10        Q.   And in December of 2006, you decided to leave.  And on

11     December 4th, 2006, you called VWS to let them know that you had left;

12     right?

13        A.   Right.  I called them only when I got back to Serbia.

14        Q.   And what you told them was that you left because your son had

15     fallen ill; specifically, he had a ruptured appendix.  That's what you

16     told VWS; right?

17        A.   I did say that, but that was not the truth.

18        Q.   And you called them the next day, on December 5th, 2006.  You

19     again called them to give them an update on your son's condition.  That's

20     what you told them in December of 2006, on the 5th of December, 2006;

21     right?

22        A.   I just said I had made up the reason to leave The Hague.

23        Q.   I'm not interested in your reason right now.  I am interested in

24     what you did.  And what you did on the 5th of December, 2006, was to give

25     them a second call to let them know how things were with your son; right?

Page 15997

 1        A.   Right, so that they don't issue a bulletin, an all-points

 2     bulletin for me.

 3        Q.   And you spoke to them again in January of 2007, and you confirmed

 4     that you didn't want to go -- to be relocated to Sweden anymore and that

 5     you were going to stay in Serbia; correct?

 6        A.   Correct, because in the meantime they had not done anything, and

 7     I had checked that through the Swedish Embassy.

 8        Q.   Do you know a man by the name of Ljubisa Petkovic?

 9        A.   Yes, certainly.

10        Q.   When was your last contact with him?

11        A.   We are neighbours in Belgrade.

12        Q.   Do you know a man by the name of Zoran Drazilovic?

13        A.   Yes, of course, but I don't remember when I saw him last.

14        Q.   So back to my question about Ljubisa Petkovic.  He's your

15     neighbour.  Did you see him before coming here to The Hague?

16        A.   Not just before I came to The Hague.

17        Q.   Did you see Ljubisa Petkovic after you returned to Serbia in

18     January of 2007?

19        A.   I see Ljubisa Petkovic very often, and I probably saw him when I

20     returned.

21        Q.   And you see him so often that when you were issued to appear by

22     summons in November 2007 to talk to OTP representatives, you gave him a

23     document to give to the Prosecution on your behalf, the doctor -- the

24     medical records?

25        A.   That's not true.  I gave those papers to my lawyer,

Page 15998

 1     Zoran Stojkovic.

 2        Q.   And do you know someone by the name of Petar Jojic?

 3        A.   Yes.  He's an MP from the Serbian Radical Party.

 4        Q.   Do you know that there's documentation listing him as the person

 5     delivering the objections that we just talked about at the very beginning

 6     of your testimony today, that it was Petar Jojic who delivered the

 7     objections you said your lawyer drafted?  Are you aware of that?

 8             JUDGE HARHOFF:  Delivered to whom, Ms. Biersay?

 9             MS. BIERSAY:  Delivered to the field office in Belgrade.

10             JUDGE HARHOFF:  Thank you.

11             THE WITNESS: [Interpretation] I really don't know to whom

12   (redacted)

13   (redacted)

14     him implicitly.

15        Q.   And it's after you left The Hague and went back to Serbia that

16     you started signing Defence statements claiming misconduct on the part of

17     people working for the Tribunal; right?

18        A.   Only individuals among them, not all the people working for the

19     Tribunal.

20             MS. BIERSAY:  And if we could go back to that first document that

21     we looked at, and if we could go to page 2.  And that would be the

22     24 December 2007 objections to the subpoena.

23        Q.   And I will read for you:

24             "I have given a number of statements stating that I am threatened

25     by the Office of the Prosecutor, which had kidnapped me and held me for

Page 15999

 1     several months in confinement in the Netherlands."

 2             That's the document that you signed that was prepared by your

 3     lawyer; correct?

 4        A.   Yes.

 5        Q.   In the third full paragraph on that page, and it should be --

 6     this document is tab 6 in your binder 1, Your Honours:

 7             "This should be enough to understand that the Office of the

 8     Prosecutor has misled Trial Chamber III, and if this subpoena should

 9     remain valid, then Trial Chamber III is not protecting me, but rather

10     throwing me into the embrace and delivering me to those who had kidnapped

11     me and mistreated me."

12             That's what you wrote in your objections from December 2007;

13     right?

14        A.   I signed the subpoena drafted by my legal counsel.  I mean the

15     objections to the subpoena.

16        Q.   You testified, when we first started, that you agreed with

17     everything that was in this document.  And, in fact, it repeats what you

18     have said in other Defence statements about being kidnapped by the Office

19     of the Prosecutor; right?

20        A.   Well, it's not a traditional kidnapping, but I was lured here by

21     deceit.

22        Q.   So you're telling --

23             JUDGE ANTONETTI: [Interpretation] Witness, I noted, in a document

24     that the Judges have, that you said that you had been kidnapped, thanks

25     to the questions that were put to you by Ms. Biersay, that you had the

Page 16000

 1     key to your apartment, and that therefore you could move freely.  Had you

 2     been kidnapped, why stay here?  But, in fact, you remained several months

 3     in the Netherlands, and you could move freely in this country.  This is

 4     not how someone who has been kidnapped would find themselves.

 5             THE WITNESS: [Interpretation] Your Honour, apart from a little

 6     paper bearing a number, I had no personal documents.  All my documents

 7     were in the hands of the OTP, including my passports -- passport during

 8     that time.

 9             JUDGE ANTONETTI: [Interpretation] So when you were staying in

10     this apartment, you had no passport?

11             THE WITNESS: [Interpretation] No.

12             JUDGE ANTONETTI: [Interpretation] Very well.  And if I understand

13     correctly, you received your passport in December.

14             THE WITNESS: [No interpretation]

15             JUDGE ANTONETTI: [Interpretation] Very well.  Was this passport

16     given to you before you returned to Belgrade?

17             THE WITNESS: [Interpretation] Yes.

18             MS. BIERSAY:  Your Honours, as the Court is aware, there was a

19     correction to a notice that was given by VWS, and now I will turn to the

20     witness and ask you the following question:

21        Q.   Isn't it true that you had your passport when you landed in the

22     Netherlands; you had your passport?  It was given to you, it was returned

23     to you, right, by VWS?

24        A.   No, it's not right.  After passing through Immigration at the

25     Belgrade Airport, and until the beginning of December, my passport was

Page 16001

 1     with the VWS.

 2        Q.   First you said the passport was with OTP.  Now you're saying it's

 3     with VWS.  Isn't it true that VWS only had your passport from October 9th

 4     of 2006 until 7 November 2006, because your visa needed to be extended

 5     and they needed to submit it for that purpose?  Isn't that true?

 6        A.   I really don't know what the division of work is between

 7     different services here, but the fact is that I didn't have the passport

 8     in my hands until early December.

 9        Q.   Isn't it true that you were given your passport with the extended

10     visa on November 7th, 2006?

11        A.   Not on the 7th of November, but early December.

12        Q.   You left on December 4th [realtime transcript read in error "in

13     November"] of 2006, so what is it that you mean by "early December"?

14             JUDGE ANTONETTI: [Interpretation] I believe there is a mistake.

15     You said that you left on the 4th of December, and it says "in November

16     2006."  So I believe there is a mistake.

17             MS. BIERSAY:  Thank you, Your Honour.

18        Q.   So if representatives of VWS say that they gave you the passport

19     with the extended visa in November of 2006, you're saying that that's not

20     true; is that what you're telling this Trial Chamber?

21        A.   Right.  If I remember well, I got my passport back on the 1st of

22     December, 1996 [as interpreted], together with money for the next month,

23     which was December, I mean the allowance.

24        Q.   The translation said "1996."  Did you mean 1996, or did you mean

25     2006?

Page 16002

 1        A.   Sorry, I meant 2006.

 2        Q.   So just so I understand what you're telling the Trial Chamber,

 3     you're saying that everyone that handled your relocation with VWS, that

 4     everyone that participated in your interviews, all 17 interpreters and

 5     investigators and at least one attorney, that all those people conspired

 6     to threaten and kidnap you to give evidence against the accused, in the

 7     form of these statements?  That's what you're telling the Trial Chamber

 8     here today?

 9        A.   No, by no means.  I can only -- I can only really say that two

10     persons have not been fair and decent towards me.

11             MS. BIERSAY:  Your Honours, may I ask how much time I have?

12             THE INTERPRETER:  Microphone, please.

13             JUDGE ANTONETTI: [Interpretation] I don't think that you have

14     very much left, but the Registrar will tell us.

15             MS. BIERSAY:  While we're checking, Your Honour, I am prepared

16     to -- whatever bit I have left, I'd like to reserve.  And I'd also like

17     to indicate that we seek to tender all the 2003 [sic] statements.  So for

18     the record -- three.  So it would be 65 ter numbers 7540, 7541 -- I'm

19     sorry, it should say "2006 statements."  In the transcript, it says

20     "2003."  So 7540, 7541, and 7542, and we'd submit that it falls under

21     89(C) as well as 92 quinquies.

22             JUDGE ANTONETTI: [Interpretation] Very well.  You will have

23     38 minutes left.

24             So we shall have our break, and then after that Mr. Seselj will

25     start putting his questions to the witness, and we'll move on from then.

Page 16003

 1             So we'll have a 20-minute break.

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

 3                           --- On resuming at 4.07 p.m.

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

 5             Mr. Seselj will have two hours, and it's up to him to divide

 6     those two hours between the main questions and the additional questions.

 7     So Ms. Biersay wants to ask additional questions on redirect, but

 8     Mr. Seselj will take the floor last, as it was promised.

 9                           Cross-examination by Mr. Seselj:

10             MR. SESELJ: [Interpretation]

11        Q.   Mr. Rankic, let me just show you one piece of evidence which

12     confirms your claims that The Hague investigators ill-treated you in a

13     horrible way.  This was provided to me by the OTP.  The document is

14     signed by Mr. Mathias Marcussen.  He did not disclose the original of the

15     document.  He just told me or relayed the statement of a woman called

16     Marina Krstic who was an interpreter during the first interview.

17        A.   Yes.

18        Q.   Mr. Marcussen informed me that Ms. Marina Krstic has stated that

19     on the 5th, which was on the second day of your interview, you voiced

20     very serious objections with regard to the chronology of the statement,

21     and that you stated as follows:

22             "You told me during the two days to stick to the chronology, and

23     now look what you've done.  This doesn't make any sense.  Everything is

24     hickledy-pickledy.  This statement is shit.  If the whole Tribunal works

25     in the same manner, I will never go there to testify."

Page 16004

 1             MS. BIERSAY:  Excuse me, Your Honour.  Could we clarify which

 2     statement he's referring to?  I believe it's the very first one from

 3     2003.

 4             THE ACCUSED: [Interpretation] The first statement from 2003, the

 5     statement provided on the 4th and 5th of August, the only one provided on

 6     those dates.  And I am reading from a letter by Mr. Marcussen sent to me,

 7     in which he says:  "Dear Mr. Seselj," and I would like to thank

 8     Mr. Marcussen.

 9             Do you have that letters, Your Honours?  Maybe I could give you a

10     copy if you don't have one.  Do you have it or not?  You do; good.  Okay,

11     fine.

12             MR. SESELJ: [Interpretation]

13        Q.   So once you said that that statement was shit, Marina Krstic,

14     according to Mr. Marcussen's interpretation, stated as follows:

15             "Mr. Rankic's words were, indeed, interpreted.  It was very

16     tense.  When Mr. Paolo Pastore Stocchi tore up certain pages and he

17     turned towards the monitor and started changing paragraphs, and he also

18     put subtitles above some of them and changed the order of the

19     paragraphs."

20             And then Mr. Rankic repeated some of the objections.  I

21     interpreted them.  Mr. Paolo Stocchi put his finger in the left ear, very

22     theatrically, and said, I can't concentrate if you both speak at the same

23     time.  Mr. Rankic smiled ironically and said:

24             "I'm going to sign your statement because I trust this woman."

25             He pointed at Ms. Krstic.  And then:

Page 16005

 1             "Let's all go home."

 2             And later on, according to Mr. Marcussen's interpretation,

 3     Ms. Krstic said as follows:

 4             "Later on, Mr. Rankic signed the statement, and that statement

 5     had never been properly translated for him."

 6             In other words, Ms. Marina Krstic confirms that you are telling

 7     the truth, Mr. Rankic, and not Ms. Biersay.  Am I right?

 8        A.   Correct.

 9        Q.   I don't know what else is there in Ms. Krstic's statement.  I

10     wish I'd received it in its totality.  Mr. Marcussen was kind enough, and

11     ex officio he was also obliged to provide me with at least some of the

12     parts.  So Ms. Biersay actually ill-treated you for an hour and a half to

13     no avail, because here's the proof that you didn't fair too well during

14     that conversation.

15        A.   This is an understatement.  It was even worse than that.

16        Q.   It is my impression that you were telling the truth in the

17     statements provided to my associates, and that under duress you accepted

18     to sign some things, fully well aware of the fact that they were not

19     truthful.  And before we embark on those things, and that is very

20     important for me -- fortunately enough, we are in open session, and what

21     is important for me is for the Serbian public to realise how untruthful

22     things are that are mentioned here.

23             This just one thing that I would like to ask you.  You were

24     promised that you would be provided with a good apartment, a good job,

25     and a good salary in Sweden, and that you would be able to remain in

Page 16006

 1     Sweden, living there forever; is that true?

 2        A.   Yes, something to that effect.

 3        Q.   And then towards the end, or in the course of December 2006, they

 4     told you this:  You are going to Sweden, but only for three months; is

 5     that correct?

 6        A.   Allegedly, the Swedish government had to be in agreement.  That's

 7     how I understood it.  An application was filed with the Swedish

 8     government, and the answer was pending.

 9        Q.   You could go to Sweden, but only for three months, which means

10     you would not have been given an apartment, a job, a salary?

11        A.   I suppose that was the end result.

12        Q.   You felt deceived, and that's why you decided to leave Holland

13     and go to Belgrade?

14        A.   Yes.

15        Q.   And because you were disappointed in The Hague Tribunal, you

16     turned to my associates and you decided to be a Defence witness; is that

17     true?

18        A.   Yes.

19        Q.   And now I'm going to speculate a little.  Please do not be

20     offended if -- I am not trying to embarrass you.

21             If you had been given the ownership of a good apartment in

22     Sweden, if you had been given a good job, a good salary in Sweden, if you

23     had been provided with Swedish citizenship, would you, in that case,

24     confirm here in the courtroom that all those false allegations from your

25     five statements are actually correct and truthful?  Would you do it for

Page 16007

 1     the love of the apartment, the job, and the salary?

 2        A.   Everybody who knows, and a lot of Serbian people know what kind

 3     of a man I am, would know that I would never do that.

 4        Q.   Now I'm going to disappoint both the Trial Chamber and the OTP,

 5     and I will not follow up on any of Ms. Biersay's questions.  I'm

 6     interested in the financial aspect of the problem.

 7             Let's start with first things first.  Let's follow the paragraphs

 8     in the first, second, and third statement.

 9             In your first statement in 2003, in paragraph 9 you stated, and

10     the OTP recorded it on your behalf, that:

11             "Vuk Draskovic and Seselj founded the Serbian Freedom Movement,

12     which couldn't last long."

13             Could you have told them something like that?

14        A.   No, because I'm aware of the chronology of the events.

15        Q.   The entire Serbian general public knows that with a group of

16     intellectuals, I founded the Serbian Freedom Movement when we signed the

17     foundation document on the 6th of January, 1990, and that Vuk Draskovic

18     was not involved in that.  Is that correct?

19        A.   Yes, it is.

20        Q.   So it is an absolute lie, and the entire Serbian general public

21     knows that it is a lie.

22             And then it goes on to say:

23             "They split, and each of them founded their own parties.  Seselj

24     founded the Serbian Chetnik Pokret, and Vuk Draskovic founded the Serbian

25     Renewal Movement."

Page 16008

 1             Is that correct?

 2        A.   No.  First you founded the Serbian Rule Movement together, and

 3     then you split, and it was only then that you founded the Serbian Chetnik

 4     Movement.

 5        Q.   Let me add something to that.  On the same day when I founded my

 6     Serbian Renewal Movement, Vuk Draskovic founded the Serbian Popular

 7     Renewal in Nova Pazova?

 8        A.   Yes.

 9        Q.   Mirkovic was the president, and Vuk Draskovic was the

10     vice-president.  And then in the beginning of March 1990, Vuk Draskovic

11     was abolished from that movement?

12        A.   Yes.

13        Q.   And then one wing of the Serbian Renewal joined him?

14        A.   Yes.

15        Q.   And then we joined the Serbian Freedom Movement with that wing of

16     Draskovic's, and together we founded the Serbian Renewal Movement.

17        A.   Yes.

18        Q.   And then we excluded Draskovic in the beginning of June 1990 from

19     the Serbian Renewal Movement by a majority vote; is that correct?

20        A.   Yes, but he didn't want to cede the stamp, if I remember

21     correctly.

22        Q.   And then he set up, in the Rolex Restaurant, a new party and

23     called it by the same name; is that correct?

24        A.   Yes.

25        Q.   For a month, there were two parties called Serbian Renewal

Page 16009

 1     Movement.

 2        A.   Yes.

 3        Q.   And then we changed our name into Serbian Chetnik Movement

 4     primarily in order to stop having problems with Draskovic.  Is

 5     paragraph 9 in the statement completely untruthful?

 6        A.   Yes.

 7        Q.   It is very important for me that the entire Serbian general

 8     public will see that.

 9             Further on in paragraph 13, it says that you were one of the

10     founders of the Serbian Chetnik Movement, as a matter of a fact one of

11     the 100 signatories of the founding document that had to be submitted for

12     registration.

13        A.   Yes.

14        Q.   It says here that besides yourself, there were some other people,

15     including Jovan Glamocanin; is that correct?

16        A.   I don't know when Jovan Glamocanin joined us.

17        Q.   But in any case, he never joined the Serbian Chetnik Movement?

18        A.   No.

19        Q.   He only joined when the Serbian Radical Party was founded.

20        A.   Yes.  These names do not make too much sense.

21        Q.   So this is also a lie --

22             JUDGE HARHOFF:  Please slow down.  The interpreters are unable to

23     follow at this pace.  And, Mr. Witness, do observe a small pause between

24     question and answer.

25             MR. SESELJ: [Interpretation]

Page 16010

 1        Q.   Let's go on through paragraph 13, and they ascribe this to you:

 2             "I believe that this was in December.  The regime arrested

 3     Vojislav Seselj, and since it was at the time of the first multi-party

 4     elections in Serbia, by this the regime removed Seselj from the political

 5     scene.  In February 1991, Seselj was released from prison."

 6             Isn't this an absolute lie, a blatant lie?

 7        A.   I know the chronology very well.  You were arrested before the

 8     presidential elections, but you were released in December to start your

 9     campaign.

10        Q.   I was released at the beginning of November, because every

11     evening the state television published news about presidential

12     candidates, and my name was first on the list, "Dr. Vojislav Seselj," a

13     Dr. Lu [phoen], who was the presidential candidate, but sitting in

14     prison; wasn't that the case?

15        A.   Yes.

16        Q.   And then they released me against my will?

17        A.   Correct.

18        Q.   I did not want to sign any documents, I didn't want to leave the

19     prison, and I was forcibly thrown out of the prison.

20        A.   Yes.

21        Q.   In my campaign, I held 10 different promotions in Novi Sad,

22     Cacak, Subotica, Kragujevac, Nis, and some other places; is that correct?

23        A.   Yes.

24        Q.   At the beginning of December, did I not appear on state

25     television?  I was given only one hour for my promotion, and I won the

Page 16011

 1     entire electoral body?

 2        A.   One part of the electoral body.

 3        Q.   Isn't that the time when my popularity took off in Serbia?

 4        A.   Yes.

 5        Q.   So is all this a blatant lie?

 6        A.   Yes.

 7        Q.   So that was paragraph 13.  Let's go on, disguising all the

 8     untruths in the statement.

 9             In paragraph 14, you're talking about the time when Radical Party

10     was united with the Chetnik Movement, and you say that the Serbian

11     Chetnik Movement was preserved, but more or less the traditional military

12     wing of the future party.  In February 1991, was the Serbian Chetnik

13     Movement a military wing of the Serbian Radical Party?

14        A.   No.  It continued the traditions of Chetnik movement in Serbia

15     which dated back to the turn of the century, and we continued the

16     traditions of the Serbian movement at Ravna Gora, which was an

17     anti-fascist movement during the Second World War.

18        Q.   Was our main objecting [as interpreted] to rehabilitate the

19     Serbian Chetniks that the Communists for decades had accused that it was

20     a whistling movement?

21        A.   Correct.

22        Q.   Without any military elements contained therein.

23        A.   Of course.  There were no military actions at the time.

24        Q.   Nobody even knew that there would be a war.

25        A.   Correct.

Page 16012

 1        Q.   The political situation was tense, but nobody expected that there

 2     would be war.

 3             Is it correct that you stated, as it was recorded in

 4     paragraph 16, that Vojin Vuletic died under suspicious circumstances?

 5        A.   That was suggested to me by the investigator.  He told me that

 6     many of your associates died under very suspicious circumstances.  As far

 7     as I know, Mr. Vuletic suffered from angina pectoris, if I remember.

 8        Q.   And he died of a heart infarction?

 9        A.   Yes, as far as I know, but I'm not a medical expert.

10        Q.   Do you remember that he as a member of the democratic party?  You

11     don't remember that?

12        A.   No, I don't.

13        Q.   Who else of my associates died under suspicious circumstances?

14        A.   You have to ask the investigators.  They said that.

15        Q.   So they wanted to qualify me as a killer who killed his

16     disobedient associates.

17             In paragraph 20, it says that the decision to set up the

18     War Staff was made by Seselj, who simply decided that Ljubisa Petkovic

19     had to be the head of the War Staff.  Do you know that there was -- that

20     it was decided that Ljubisa Petkovic, as one of the vice-presidents of

21     the party, would be the head of that staff?

22        A.   It was a crisis staff.

23        Q.   Yes, but it says "War Staff" here; is that correct?

24        A.   Yes.

25        Q.   But is this a blatant lie in paragraph 20.

Page 16013

 1        A.   Yes.

 2        Q.   Does the entire Serbian general public know that this is a

 3     blatant lie, whoever knows the history of the Serbian political parties

 4     from the 1990s onwards?

 5        A.   It is a notorious fact in Serbia.

 6        Q.   Very well.  In paragraph 21, it says Minister Cvijan, it says

 7     here that personally saw him and that you visited him twice, and that you

 8     met with him in order to co-ordinate the deployment of volunteers, and

 9     that the minister had more information about the needs for manpower in

10     the field.  Isn't that a fabrication?

11        A.   In my introductory speech yesterday, I said that I did go to the

12     ministry with -- for relations with Serbs outside of Serbia with

13     Ljubisa Petkovic, but Ljubisa Petkovic went there on his private matters

14     and I was sitting outside of their office.  I was having coffee while he

15     was talking to him about his private problems.

16        Q.   You don't have to repeat what you said.  My time is limited, and

17     the Trial Chamber is always inclined to rob me even of those rights that

18     I am entitled to.  Let's not waste time.

19             The Ministry for Serbs Outside of Serbia, could they -- could it

20     be involved in any military matters?

21             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I can't accept that

22     sentence without saying something.

23             When you say that, The Trial Chamber is always inclined to rob me

24     of those rights that I'm entitled to, this is not based on anything.  I

25     know that what you are interested in is the media and the Serbian

Page 16014

 1     listeners, but I would like to say that I disagree totally with you in

 2     this regard.

 3             THE ACCUSED: [Interpretation] It's all good and well that you

 4     don't agree, but this is the main part of my defence, and this is what I

 5     intend to prove in my closing argument.

 6             MR. SESELJ: [Interpretation]

 7        Q.   In paragraph 22, it says:

 8             "After Ljubisa Petkovic received requests from local TOs with

 9     regard to the deployment of volunteers, he would turn either to the

10     Ministry for Relations with Serbs Outside Serbia or the Ministry of

11     Defence in Serbia because they have better information about the

12     situation in specific areas."

13             Is it entirely impossible for the Ministry for Relations with

14     Serbs Outside of Serbia to deal with military issues?

15        A.   No, they didn't deal with military issues.  They only assisted us

16     with refugees.  They provided us with buses and other such matters that

17     were needed for the deployment of the volunteers.

18        Q.   And food for refugees?

19        A.   Yes, food, accommodation, and so on and so forth.

20        Q.   And when was it that the Ministry for Relations with Serbs

21     Outside of Serbia provided you with buses?  Where did those buses come

22     from?

23        A.   I believe that those buses belonged to the Territorial Defence,

24     and the Territorial Defence was duty-bound to provide them.

25        Q.   As far as I know, there were sponsors, different companies.

Page 16015

 1        A.   Yes.

 2        Q.   There were transport companies which provided buses as

 3     sponsorship to the Association of Serbs?

 4        A.   They didn't have their own buses, so they could only rely on

 5     sponsors.

 6        Q.   Did the Ministry for Defence of Serbia have any resources that

 7     they could use to help us with the deployment of volunteers or with any

 8     other military matters?

 9        A.   As far as I know, no.

10        Q.   This was a formality.  Serbia had that ministry, a minister and

11     his secretary, and that was all?

12        A.   Yes.

13        Q.   The JNA was still within the competence of the federal state;

14     isn't that correct?

15        A.   Yes.

16        Q.   So this is another blatant lie, what it says here in

17     paragraph 22.

18             I've never heard before that our volunteers were sent to Lipovaca

19     for additional training, as it says here in paragraph 34.  As far as I

20     know, Lipovaca was only the collection area where our volunteers came, as

21     well as volunteers of other parties, as well as individuals who

22     volunteered.  And from there they were deployed into JNA units and units

23     of the Territorial Defence.  Is that correct?

24        A.   I never mentioned Lipovac.  I only mentioned Prigrevica.

25        Q.   First in Prigrevica before the JNA was engaged in the war, and

Page 16016

 1     then Bubanj Potok?

 2        A.   Everything went through the JNA after that.

 3        Q.   So there was no training in Lipovaca; it was only the collection

 4     spot?

 5             JUDGE ANTONETTI: [Interpretation] One moment.  The interpreters

 6     are asking you to slow down.  You're going too fast.

 7             THE ACCUSED: [Interpretation] All right, I'll try.

 8             MR. SESELJ: [Interpretation]

 9        Q.   So paragraph 24 is absolutely untruthful, too, and anyone who

10     knows anything will know that.

11             In paragraph 25, it reads that you, the Crisis Staff, knew where

12     our volunteers were, and that you monitored what was going on the ground.

13     But I'm astonished to read the Chetnik commanders came for weekly

14     meetings of the Crisis Staff to make their reports.  Is that at all

15     possible?  The commander who's in the field would come back every week to

16     make a report.

17        A.   What I said is this:  Individual Chetnik commanding officers and

18     commanders, if they happened to be in Belgrade, could come to attend

19     Crisis Staff meetings.

20        Q.   But that's not what it says here.  It says they came for weekly

21     meetings, which means they came regularly?

22        A.   Loads of things are written there.

23        Q.   Do you remember members of the Crisis Staff -- did any of you

24     members of the Crisis Staff know about it, 10 of you?  Were any of you

25     experts in military matters?

Page 16017

 1        A.   No.

 2        Q.   Only Drazilovic, who had crashed his plane and was a retired

 3     pilot of the air force.

 4        A.   To the best of my recollection, yes.

 5        Q.   And none of you even had the rank of reserve officer?

 6        A.   Correct.

 7        Q.   So you did not know tactical problems, operative problems, let

 8     alone strategy.  You were only able to assemble volunteers, organise

 9     them, and send them where they needed to be sent.  Was that your only

10     task?

11        A.   Correct.

12        Q.   And to provide them with some food, some cigarettes, arrange with

13     the JNA that they be given uniforms, weapons, et cetera?

14        A.   Correct.

15        Q.   Very well.  So you did not have and were not able to have any

16     command function?

17        A.   That goes without saying.

18        Q.   So paragraph 25 is also an outright lie.

19             Paragraph 27 says that my publicity was my greatest priority,

20     followed by quantity and quality?

21        A.   That's not exactly true.

22        Q.   Didn't I always insist on quality, then -- and publicity was my

23     third priority?

24        A.   I meant publicity for the party.

25        Q.   And it says that:

Page 16018

 1             "Seselj never told us in the Crisis Staff to familiarise

 2     volunteers with the provisions of the Geneva Conventions.  In fact, he

 3     never even mentioned it."

 4             Is this true?

 5        A.   I already denied it yesterday and explained that several times --

 6     you, several times Ljubisa Petkovic, and sometimes I, myself, gave them a

 7     lecture on how they should conduct themselves on the ground.

 8        Q.   Are you aware that there are more journalists in Belgrade who

 9     remember the sending off of volunteers, where I spoke --

10             JUDGE ANTONETTI: [Interpretation] Mr. Seselj has put a number of

11     questions to you, Witness, and you are saying the opposite of what you

12     have said so far.  Admittedly, one could believe that the volunteers

13     commander came to the War Staff every week and that this would be rather

14     complicated.

15             In the 89(F) statement which you have signed in your own

16     language, we find the following sentence.  You say --

17             THE ACCUSED: [Interpretation] Mr. President, he signed this only

18     in English, not in Serbian.

19             JUDGE ANTONETTI: [Interpretation] No, the 89(F) statement was

20     signed in the B/C/S version.  Please look at page 11, paragraph 32.  You

21     say as follows:

22             "I received reports from units of volunteers over the phone.

23     Sometimes I passed the information on directly to Mr. Seselj.  In other

24     instances, I provided the information to Petkovic."

25             So you signed this in your own language.  The fact that the

Page 16019

 1     commanders of volunteer units sent you reports, what do you have to say

 2     to this today?

 3             THE WITNESS: [Interpretation] First of all, I have to inform this

 4     esteemed Court about certain points that need to be clear.

 5             There is a huge difference between reports and information.

 6     Everyone knows what a report must contain.  Pieces of information is

 7     something of an entirely different nature.  If Mr. Seselj ran into me at

 8     the Crisis Staff, then he would ask me, Rankic, is there anything new on

 9     the ground?  Quite logically, I would tell him whatever news I had, but

10     that's no report.  A report is an official document that has to contain a

11     number of elements.

12             JUDGE ANTONETTI: [Interpretation] The English term used is

13     "reports" in paragraph 32.  In your language, how do you say

14     "information" in your language, and how do you call a report in your

15     language?

16             THE WITNESS: [Interpretation] "Information" is "informacija."

17     "Report," in the military sense, is "raport."  And "report" is

18     "izvestaj."

19             THE ACCUSED: [Interpretation] Mr. President, "raport" is used in

20     Serbian only in the military terminology.

21             MR. SESELJ: [Interpretation]

22        Q.   Is this, therefore, an outright lie, and that I didn't give --

23     sorry, when you said I didn't give any instructions on how to treat

24     women, children, civilians, prisoners of war?

25        A.   The first time the Crisis Staff was set up, you gave us

Page 16020

 1     information.  And when the War Staff was set up, you told us exactly what

 2     to convey to the volunteers on how to conduct themselves on the ground.

 3             JUDGE ANTONETTI: [Interpretation] One moment, sir.

 4             To demonstrate that Mr. Seselj has a fair trial and that he is

 5     entitled to a trial according to the Rules, I must state that in the

 6     B/C/S statement you have signed, it is the term "information" which has

 7     been used in your language.

 8             Please proceed.

 9             THE ACCUSED: [Interpretation] There was a witness who perjured

10     himself in the courtroom and who claimed that every time I came to the

11     headquarters of the Serbian Radical Party, in the morning the entire

12     War Staff lined up and that the chief or his deputy gave me a military

13     report and marched through the room.

14             MR. SESELJ: [Interpretation]

15        Q.   Is that true?

16        A.   I can only laugh at that.

17        Q.   Would that be a sign of yes or no, that it's not true?

18        A.   Of course it's not true.

19        Q.   Did Ljubisa Petkovic, who's your neighbour -- and he's now an MP

20     of the Serbian Radical Party, who had also been interrogated by OTP

21     investigators.  He gave a certain statement, and as far as I know he

22     didn't say anything untruthful in that statement, but he acted as a hero

23     and refused to testify before The Hague Tribunal, even at the cost of a

24     prison term.  The Serbian Radical Party appreciates that a lot, and he

25     showed Borislav Jovic, Aleksandar Vasiljevic, and many other Serbs what a

Page 16021

 1     real hero is, because they testified, and he didn't.

 2             Is it true that my first submission as my special defence was on

 3     400 pages quoting from my speeches and public appearances where I stated

 4     what humane treatment of prisoners of war, women, children, civilians,

 5     should be; that the enemy is an enemy only as long as he carries weapons

 6     on the front-line.  At the moment he lays down his arms, he has to be

 7     treated humanely?  Was that my standard language at every opportunity?

 8        A.   Yes, and we said the same.  In your absence, we were duty-bound

 9     to convey the same.

10        Q.   And there is television footage testifying to those speeches?

11        A.   And TV crews were present when volunteers were sent off.

12        Q.   How about your statement in paragraph 28?  You say I said:

13             "Be heroes, kill the Ustashas, fight for a Greater Serbia."

14             Is that true?

15        A.   Of course not.

16        Q.   Did you really say, as it states in this paragraph, that I'm a

17     lunatic?

18        A.   I never said that.

19        Q.   Did you say I was a fool in one of the later statements that was

20     corrected?

21        A.   I never said that.

22        Q.   You never said that, and they included it in your statement

23     against your will?

24        A.   Many things, not only that.

25        Q.   Did we ever send a criminal as our own volunteer while knowing

Page 16022

 1     that he was bent on crime?

 2        A.   We never sent anyone who was a known criminal.

 3        Q.   Do you know of a single case where a volunteer of ours committed

 4     serious criminal offences on the front-line?

 5        A.   I don't know of any such case.

 6        Q.   It says here that you stated that there were a certain number of

 7     volunteers who were possibly mental patients even before they became

 8     volunteers.  Is that true?

 9        A.   It can't be true, because all volunteers had to produce their

10     military service books to the Serbian Radical Party headquarters, and if

11     anyone had been mentally disturbed, it would have been written in their

12     service books.

13        Q.   And in paragraph 30, it says there was a case of a volunteer who

14     had killed five or six prisoners.  His nickname was Topola.  Did you say

15     that, that Topola was one of our volunteers?

16        A.   I never said that.  I don't even know who that Topola man is.

17        Q.   Well, it says here that you drove Topola from the front-line to

18     Vukovar after that incident, and after the killings, back to Serbia?

19        A.   That's the first I hear of this.

20        Q.   You have no idea how this found its way into your statement?

21        A.   No clue.

22        Q.   Did you perhaps find out later?  Because the first witness here

23     was Goran Stoparic, who has testified that Topola was a member of the

24     Leva Supoderica Unit, but already in October 1991 he was expelled for

25     lack of discipline.

Page 16023

 1        A.   Well, I didn't have a chance of knowing all the volunteers of the

 2     Serbian Radical Party.  There were thousands of them.  I knew certain

 3     commanders whom I was in touch with.

 4        Q.   He said not that he was our volunteer, but just a volunteer,

 5     because Leva Supoderica did not contain exclusively SRS volunteers.

 6        A.   Right.

 7        Q.   Did a single volunteer of the SRS, at the cost of his life, ever

 8     accept to wear a red five-pointed star on his cap?

 9        A.   Never.

10        Q.   We saw a photograph of Topola here wearing a white belt of the

11     military police and five-pointed red star on his cap.  He was recognised

12     by a general who was sent by Aleksandar Vasiljevic to Vukovar to do the

13     execution of the prisoners.

14             THE ACCUSED: [Interpretation] Do we need to show this photograph

15     to the witness again?  If there's no need, we can move on.

16             MR. SESELJ: [Interpretation]

17        Q.   It also says here that towards the end of November, after the

18     fall of Vukovar, Milan Lancuzanin, also known as Kameni, came with Katic

19     to Belgrade to describe the circumstances under which Topola allegedly

20     removed five or six Croatian prisoners from the collection centre in

21     Velepromet, and there was information available that these men had been

22     killed.  And after that - that's paragraph 31 - you went to Vukovar to

23     pick up Topola and get him back to Serbia.  Is this at all possible?

24        A.   As far as I know, Milan Lancuzanin and Slobodan Katic came to

25     Belgrade more than once.  I can't remember on what business.  Of course,

Page 16024

 1     I spoke to them, but Topola was never a subject of our conversations.

 2     When I went to Vukovar, the fighting was over.  There was no longer any

 3     need for volunteers in Vukovar, and we wanted to relocate them to

 4     Western Slavonia, where they were needed.

 5        Q.   Did the volunteers go back as soon as Vukovar fell?

 6        A.   The volunteers of the SRS, yes.

 7        Q.   On the 18th, 19th, 20th November, were they already returning?

 8        A.   Around the 20th.

 9        Q.   Is it true that Slobodan Katic remained to live in Vukovar?

10        A.   Yes, and he married there.

11        Q.   Did Little Joe stay in Vukovar to live?

12        A.   Yes.

13        Q.   Do you know anyone else who stayed in Vukovar to live?  There's

14     several more cases.

15        A.   I don't know of anyone but these two.

16        Q.   Is it true what it says in paragraph 30, that I, allegedly,

17     finding out that Topola had committed this crime, stated, when asked what

18     are we to do, What can I do now?  Disarm the man and get him back home.

19     He's tired.  Could I have said that?

20        A.   I've never heard that.

21        Q.   Did you say this to the investigators of the OTP?

22        A.   No, those are certainly not my words.

23        Q.   This is repeated through all of the five statements.  Did you

24     ever see it in that statement?

25        A.   I never read any of my statements, and therefore I don't accept

Page 16025

 1     them as mine.

 2        Q.   When these corrections were made, did you make these corrections

 3     while reading, or did they re-tell you the statement, or did they read

 4     back to you?

 5        A.   They read back to me from the laptop all my statements.

 6        Q.   It says here that in paragraph 31 you described Topola; that he

 7     was huge, dark-skinned, dark brown hair, over six feet tall, huge hands,

 8     that he had a long beard, and he was in his mid 30s.  You don't know

 9     whether he was a member of the SRS, but he was certainly a member of the

10     Serbian Chetnik Movement; is that your statement?

11        A.   I never said that.

12        Q.   We have been shown here a photograph of Topola.  He really did

13     have a beard, but it was a very neat, small beard, trimmed.  He was very

14     neatly dressed, and he had the insignia of a military policeman.  Where

15     he got them, nobody could explain.  But you have never seen him?

16        A.   No.

17             THE ACCUSED: [Interpretation] Could the Registry prepare this

18     photograph.  It is an exhibit, and I'd like to show it to the witness.

19     It was shown when that protected witness was testifying, if you remember,

20     the retired officer who recognised Topola.

21             JUDGE ANTONETTI: [Interpretation] While the Registrar is bringing

22     up the photograph:  Witness, the case put forward by the Prosecutor runs

23     as follows - this is contained in the indictment and in the pre-trial

24     brief - is that Seselj was made aware of crimes that had been committed

25     by volunteers; namely, volunteers from the Serbian Radical Party.

Page 16026

 1             In paragraph 39 of your statement, which has been signed by you

 2     in your language, you say that:

 3             "Mr. Seselj was made aware of the crimes committed by Topola, and

 4     he said, himself, 'Well, what can I do now?  Disarm him, send him home.

 5     He's tired.'"

 6             This is incriminating evidence against Mr. Seselj, and this has

 7     been signed by you.  You have been asked a lot of questions.  Ms. Biersay

 8     has put questions to you, Mr. Seselj is putting questions to you, and I'm

 9     putting questions to you also.  You signed a whole series of statements

10     and incriminating evidence.  Can you tell us why you signed these after

11     having, as is normal, read the statements?

12             THE WITNESS: [Interpretation] Your Honour, I'm really glad that

13     you have now put the right question to me, why I signed what I signed.

14             From day 1, and from my first contact with the OTP, huge pressure

15     was put on me.  I was even threatened that I would be sent to Bosnia.

16     And they told me that I was not a sweet-smelling flower and that I was

17     involved in some war crimes in Bosnia, although I don't know.  I was

18     never involved in anything.  If I had been, I would have already been on

19     trial for any such thing.  But I didn't know what my rights were.  I now

20     know that I did not have to provide any statements to the OTP, but I

21     didn't know it at the time.  They put pressure on me, and I was afraid,

22     like any other normal person would have been.  Can you imagine if

23     somebody threatened you to be -- that you will be sent to Bosnia, they

24     would provide two witnesses who would perjure themselves, and you would

25     end up in prison for 20 years?  How would you behave in my place?  I did

Page 16027

 1     not read anything.  I was not even interested in what it says in any of

 2     the statements.  I was just glad to be out of there.  They'd write

 3     whatever they wanted to write, I signed whatever they asked me to sign,

 4     and that was it.

 5             JUDGE ANTONETTI: [Interpretation] Yes, Ms. Biersay.

 6             MS. BIERSAY:  With respect to clarification, I read "they would

 7     provide two witnesses who would perjure themselves."  Is the witness

 8     telling the Court that the OTP representative said that they would have

 9     two witnesses perjure themselves in order to incriminate him?  I don't

10     fully understand.

11             JUDGE ANTONETTI: [Interpretation] Witness, you know, I'm quite

12     used to carrying out some investigations, and so I'm listening to what

13     Ms. Biersay is saying, I'm listening to Mr. Seselj, and I'm listening to

14     you.  What I would like to know is the following:  When the investigator

15     from the OTP threatened to start an investigation against you in Bosnia,

16     did he say that there would be witnesses that would support their case?

17     Is that what you were trying to say here?

18             THE WITNESS: [Interpretation] Well, yes, yes -- no, they didn't

19     tell me that they would bring two witnesses who would perjure themselves;

20     no, far from that.  It was just my way of thinking, that they could do

21     that.

22             JUDGE ANTONETTI: [Interpretation] Very well.  So you're drawing

23     your own conclusion.  It's not the investigator who said that.

24             Mr. Seselj, please proceed.

25             MR. SESELJ: [Interpretation]

Page 16028

 1        Q.   The OTP disclosed to me your resignation that you signed on the

 2     12th of December, 1991, and in which it reads:

 3             "Because of the total confusion and lack of organisation in the

 4     work of the War Staff of the SRS, as well as in the entire party, I

 5     hereby resign as the deputy chief of the War Staff of the SRS."

 6             Did you sign this?

 7        A.   Yes.

 8        Q.   That was on the 12th of December, 1991.

 9        A.   Correct.

10        Q.   And what was the immediate reason?  Did you perhaps have an

11     argument with Ljubisa Petkovic before that?

12        A.   Yes, there was a minor argument with him, but that was not the

13     reason for my resignation.  I had some family problems.  I had neglected

14     my family.  The conditions of life were hard.  I had two young children.

15     I wanted to make sure that my resignation would be accepted, and I had to

16     fabricate a very strong reason.

17        Q.   And that's why you entered into all those arguments with the

18     War Staff?

19        A.   Yes.

20        Q.   Did you ever talk to me about your resignation?

21        A.   No, as far as I can remember.

22        Q.   Did you ever work in the War Staff after you submitted your

23     resignation?

24        A.   No.

25        Q.   Is it true that Zoran Drazilovic, immediately after your

Page 16029

 1     resignation, became the deputy chief of the War Staff, and the chief at

 2     the time was Ljubisa Petkovic?

 3        A.   Yes.

 4        Q.   I have a statement to that effect by Ljubisa Petkovic and

 5     Zoran Drazilovic, and that is that he immediately took over from you.

 6     Did you -- after that, did you ever take volunteers anywhere?

 7        A.   No.

 8        Q.   Did you ever get in contact with anybody on behalf of the SRS,

 9     and especially with regard to the deployment of volunteers, once you

10     resigned?

11        A.   No.

12        Q.   And it says here that you took SRS volunteers to Zvornik at the

13     beginning of April 1992.  Is that true?

14        A.   The fact that I no longer had any duties in the War Staff of the

15     SRS speaks to the contrary.  I was not duty-bound, and nobody could issue

16     an order for me to do that.

17        Q.   Is it true that you went to Zvornik with Zuco, Zuco's brother,

18     and Miroslav Bogdanovic?

19        A.   I knew Zuco from 1991 while he was a volunteer in East Slavonia,

20     and I also know Miki Bogdanovic, who was a member of the War Staff, but I

21     never went to Zvornik with them.  I went on one occasion to Mali Zvornik,

22     but I had some private business there.

23        Q.   And you hail from Bogatic, which is close to Zvornik, on the

24     Drina?

25        A.   Not from there.

Page 16030

 1        Q.   Not far from the Drina, yeah.

 2             And can you remember for how long did Zuca remain a member of the

 3     SRS in 1991?

 4        A.   I can't remember the date, but I know that he was excluded from

 5     the party.

 6        Q.   We also have his statement provided to the Court, that he left

 7     the SRS sometime in September.  Is that correct?

 8        A.   Possibly.

 9        Q.   Did you ever hear -- actually, Zuca stated before the judiciary

10     bodies of Serbia that you came to Zvornik together with him.  However, he

11     wanted to cover up the true situation, and he mentioned your name instead

12     of the name of Milorad Vukovic.  Do you know anything about that?

13        A.   I heard from unofficial sources, but I don't know how important

14     it is to mention hearsay.

15        Q.   All sorts of hearsay is used here.  Did you hear that immediately

16     on the eve of war in Zvornik, Zuco came there, together with his brother,

17     Milorad Ulemek, Legija, who was later known as Lukovic, and Miroslav

18     Bogdanovic, and that they came across a Muslim check-point and that they

19     were arrested by Muslims?

20        A.   I did hear that, because I still had friends who were members of

21     the SRS, irrespective of the fact that I no longer had any position

22     there.

23        Q.   What would have been the reason for them to change all that, and

24     then we see a similar thing in your statement?

25             JUDGE ANTONETTI: [Interpretation] Witness, you told us that you

Page 16031

 1     resigned in December 1991, which means that you should no longer have

 2     anything to do with the movement and with the Serbian Radical Party.

 3     But, strangely enough, in paragraph 101 of your statement, in your own

 4     language, you say that in April 1992, with five members of the SRS,

 5     including yourself, you went to Zvornik.  So this is where I don't really

 6     understand things anymore, and perhaps the investigator did not pick up

 7     on this discrepancy or contradiction.

 8             You're saying, under oath, that you never went to Zvornik in

 9     April 1992?

10             THE WITNESS: [Interpretation] I was in Mali Zvornik towards the

11     end of April 1992, just passing through it, and I did come across some

12     people whom I know.  I sat down with them in Jezero Hotel.  We shared a

13     drink and chatted about the situation in Zvornik.

14             JUDGE ANTONETTI: [Interpretation] Well, that all very well, but

15     in paragraph 101, it says:

16             "At the end of April 1992, we went to Zvornik, myself included,

17     to discuss the issue of sending volunteers."

18             So you were saying that you were still active there.  But now you

19     say that you went there, but you went there as a tourist, which means

20     that you did not take part in any discussions as a member of the SRS

21     party.

22             THE WITNESS: [Interpretation] In April 1992, I did not have any

23     competencies with regard to the War Staff of the Serbian Radical Party,

24     which means that I did not have any power to talk to anybody.

25             JUDGE ANTONETTI: [Overlapping speakers] [previous translation

Page 16032

 1     continues] ... to complete, because then I will give the floor to

 2     Mr. Seselj.  But in paragraph 102, you say that you met with the

 3     municipal authorities at the Jezero Hotel in Mali Zvornik, and among them

 4     there was Pazin, there was Pavlovic, and so on and so forth.  So when you

 5     read this, you have the feeling that you really are at the heart of

 6     things.  And then you sign this statement.

 7             THE WITNESS: [Interpretation] I met with some people in

 8     Mali Zvornik, and Mali Zvornik is on the Serbian side of the Drina and

 9     not on the Bosnian side of the Drina.

10             THE ACCUSED: [Interpretation] Your Honours, did you receive the

11     English translation of Mr. Rankic's resignation letter?  It should be in

12     the binder.  I can provide you with that in the Serbian language, the

13     original.  Okay, you have it; fine.

14             MR. SESELJ: [Interpretation]

15        Q.   And now it says here, in paragraph 32 of the first statement,

16     that:

17             "One group of our volunteers, under the command of

18     Goran Vuckovic, aka Zuca, commander of the Yellow Wasps, does not

19     recognise any command ."

20             And that was alledgedly towards the end of May 1991.  Did you

21     ever hear of volunteers of the SRS having withdrawn as soon as Kula Grad

22     had fallen?

23             JUDGE ANTONETTI: [Interpretation] Witness, before you answer the

24     question, I don't want to take you by surprise.  You are challenging some

25     facts that are very clear, where other people were there.  I'm going to

Page 16033

 1     quote three of them:  Zoran Pazin, Brano Grujic, and Marko Pavlovic.

 2     Brano Grujic.  I don't know if they're still alive, I don't know if

 3     they're dead, but in this case at hand the OTP could, as early as

 4     tomorrow, send someone there to meet with those two or three people, and

 5     they could ask them, Have you met with this witness?  And they could say,

 6     Of course we met with him, because we had a meeting at the hotel on such

 7     and such topic.  And then it would show that you lied.  And in the same

 8     line, Mr. Seselj, with his associates, could actually gather the

 9     testimony of those various people, and they could confirm that they have

10     never seen you and that you never had a discussion with them.  So you're

11     aware of that, aren't you?

12             THE WITNESS: [Interpretation] Your Honour, I am absolutely aware

13     of everything that I am saying, and I am telling you I did meet with

14     those people towards the end of April.  I can't remember the exact date,

15     of course.  It was a long time ago.  We met in the Jezero Hotel, on the

16     Serbian side, not on the Bosnian side.  It was in Mali Zvornik.  We

17     shared a drink, we chatted.  It was all informal.  And then I proceeded

18     to tend to my own private business.

19             JUDGE ANTONETTI: [Interpretation] Very well.  It's in the

20     transcript.

21             Please proceed, Mr. Seselj.

22             THE ACCUSED: [Interpretation] Well, I've forgotten my question in

23     the meantime.  You interrupt me so often that I forget what I want to

24     ask.

25             MR. SESELJ: [Interpretation]

Page 16034

 1        Q.   The question, I believe, was that all the volunteers of the SRS,

 2     immediately upon the fall of Kula Grad, returned to Belgrade; do you know

 3     that?  And that was on the 26th of April, I believe.

 4        A.   I cannot say that for a fact.  I heard that.

 5        Q.   And now Zuca, could he, between 6 and 26 of April, be in command

 6     of any unit in the territory of Zvornik?

 7        A.   Repeat the date.

 8        Q.   Between the 6th and the 26th of April.

 9        A.   As far as I know, he couldn't.

10        Q.   On the 7th of April, the Muslims captured him.  Then he was

11     released, because the Serbs had promised that they would release

12     Fadil Mujic and let him travel abroad via Serbia.  It was a barter deal.

13     And then he got involved in the fighting for Kula Grad.  According to

14     what I know, he did not have a command function.

15        A.   That's the same what I heard.

16        Q.   Do you know that Igor Markovic Detachment was set up after the

17     fall of Kula Grad?

18        A.   I heard that only later when I read it in the Serbian newspapers,

19     when Zuco's group was arrested, if you remember that.

20        Q.   Zuco's group was arrested sometime the beginning of July.  It

21     doesn't really matter.  The Igor Markovic Detachment was established, and

22     then later on it was called the Yellow Wasps.  Is that correct?

23        A.   Yes, I remember that from other people's stories.

24        Q.   I have Zuco's statement proving that, and all the other

25     indicators prove that.  And you know that in Belgrade a group of people

Page 16035

 1     were on trial, they were charged with committing crimes in Zvornik.

 2     Among the accused, there were also Brano Grujic and Marko Pavlovic or,

 3     rather, Popovic?

 4        A.   Branko.

 5        Q.   Yes, Branko Popovic.  And that their proceedings were separated

 6     from the rest of the group, and it doesn't say anywhere in the court

 7     documents that Branko Popovic or Marko Pavlovic had used to work for the

 8     State Security.  And in paragraph 35 of your statement, it says that he

 9     was a member of the State Security and that you stated that.  Did you

10     state that?

11        A.   How would I be able to know that?

12        Q.   Allegedly this was told to you by Vlada Slon form Loznica.

13        A.   You know people tend to say all sorts of things.  I really don't

14     know what he was, what he did.

15        Q.   In paragraph 34, it says that I denied that that group contained

16     SRS volunteers and that they were headed by Zuco, and that you protested

17     against that.  If you remember, I supported the arrest of Zuco's group,

18     Pivarski's group, and Niska's group, and that arrest was carried out by

19     the special police of Republika Srpska.  Did do you remember that?

20        A.   Yes, I remember that all the groups that didn't recognise the VRS

21     and they didn't want to be placed under their command, you wanted -- you

22     asked for their arrest.

23        Q.   In one of the groups, there was also a volunteer of SRS.  He went

24     there of his own will, and you can see in the court documents that he was

25     first a volunteer of the SRS and then he joined the Zuco groups.  The

Page 16036

 1     Trial Chamber is in the possession of that sentence to the Zvornik group.

 2     However, here in paragraph 34, it says that you and I confronted with

 3     this regard and that you protested about the fact that I supported the

 4     arrest of that group, because you personally had taken

 5     there [as interpreted].  Did you state that?

 6        A.   I never stated that.  And, second of all, how could I have

 7     confronted you or protested against what you did?  At the time, I didn't

 8     have any position in the SRS.

 9        Q.   It says here that:

10             "This was the highest point of my conflict with Seselj, and that

11     conflict started when he became closer to Milosevic and gave up on the

12     ideas of monarchy."

13             First of all, did I ever support any monarchy and the idea of

14     monarchy?

15        A.   You know that.

16        Q.   What do you think?

17        A.   It's not for me to think.

18        Q.   A normal person who purports to be clever and intelligent and

19     educated, could such a person be a monarchist?  There are states like

20     Denmark which still cherish that tradition.  They have not been able to

21     get rid of the king, but they did have a crazy king, Edward VII, and

22     owing to him and his lack of interference with politics, Denmark is now a

23     democratic state.  And there are also other states who have gotten rid of

24     their monarchies as a relic of the past.

25        A.   There are also crazy presidents, not only monarchs.

Page 16037

 1        Q.   Yeah, but you can remove the president.  And the monarch, when he

 2     goes crazy, the only thing you can do is to kill him.  You can't remove a

 3     monarchy in a constitutional way.

 4             Very well.  Did I ever become close to Milosevic, do you think?

 5     What do you think?

 6        A.   As far as I know, only after the war, if I remember it well, in

 7     1997, on the eve of NATO bombing, a government of national salvation was

 8     set up.

 9        Q.   It was in 1998, was it not?

10        A.   Yes.  I misspoke.  It was the Government of National Unity.

11     That's what we call it.

12        Q.   And it says that after that, you resigned your position as deputy

13     chief of the War Staff and left the Serbian Chetnik Movement.  So you

14     resigned only after Zuco was arrested and after I supported that arrest,

15     the arrest of Zuco and Miski [phoen], and Stojan Pivarski.  And that make

16     it August 1992.  But we have a document, signed in your hand, that you

17     resigned on 12th December, 1991, eight months earlier.  Is it absolutely

18     untrue, the paragraph 34?

19        A.   The document is self-explanatory.

20        Q.   Are you responsible for this untruth or the OTP?

21        A.   Well, I didn't write it.

22        Q.   Then it says that I ordered that Zuco's group should be

23     transferred to Skelani.  Half of them agreed, the other half didn't, so

24     they committed crimes.  Is it even remotely the truth?

25        A.   How could I know what was going on there if I held no position

Page 16038

 1     and no duties?

 2        Q.   Well, they put it in your statement.

 3        A.   They could have put there anything they liked.

 4        Q.   This is repeated throughout the five statements.

 5        A.   I've already told you it's their statement, not mine.

 6        Q.   And then in paragraph 35, it says:

 7             "Seselj never ordered me to bring this group back to Serbia.  He

 8     simply ordered me to move them to another location in Bosnia.  That I was

 9     informed about the conduct of these people, but did nothing to prevent

10     them from committing crimes."

11             And that you confirmed that the Vuckovic brothers left Serbia as

12     SRS volunteers.

13        A.   Well, how would you be able to order me anything at that time?

14        Q.   Well, it's in your statement.

15        A.   I'm saying again, it's not my statement.

16        Q.   I'm saying to the Serbian public that they should stigmatise this

17     conduct of the Prosecution.  Did you sign this statement?

18             MS. BIERSAY:  It's not an opportunity for him to preach anything

19     to the Serbian public.  He's already stigmatised Serbs who are willing to

20     come and testify before this Tribunal, and it's really outrageous that he

21     continues to do this.

22             THE ACCUSED: [Interpretation] First of all, I'm defending myself

23     here partly because I can do so in public to some extent.  If this trial

24     were entirely in closed session, I would not represent myself at all,

25     because publicity is my only protection.  Between the Trial Chamber, who

Page 16039

 1     can't wait to take my head off, and the Prosecution, who only want it --

 2     who only want the same.  I have no one here, no legal assistants, no case

 3     managers, no lawyers.  I have no one here; I'm alone.  And I hope that

 4     you will deduct from Ms. Biersay the 14 seconds she abused.

 5             JUDGE ANTONETTI: [Interpretation] Witness, it's very simple.

 6     There are statements invoking Mr. Seselj's liability on a whole series of

 7     events.  There is a statement that you signed, personally, confirming the

 8     previous statements.  So your position is the following:  You said that

 9     you signed because you were threatened of being tried in

10     Bosnia-Herzegovina, so you decided to sign everything that was shown to

11     you.

12             Mr. Seselj, paragraph by paragraph, is making you say the

13     opposite of what is written in those statements, statements which you

14     signed, and it could last quite a while because we are still to cover

15     quite a few paragraphs.  So I'm going to put the question to you once

16     again.

17             You are saying today under oath, under oath, the truth and only

18     the truth, and you're stating that the previous statements have been made

19     because you were under duress?

20             THE WITNESS: [Interpretation] Correct.

21             JUDGE ANTONETTI: [Interpretation] Very well.

22             Mr. Seselj, please proceed.

23             MR. SESELJ: [Interpretation]

24        Q.   So you claim also what's written in paragraph 35 is also not

25     true -- shall I go on?

Page 16040

 1             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, my colleagues and I

 2     are wondering whether it's any use of you continuing on this line of

 3     questioning, because every time he will say, This is not what I said.  So

 4     I'm just asking this question --

 5             THE ACCUSED: [Interpretation] I don't know in advance,

 6     Mr. President.  What other line should I take?  Why don't you tell me in

 7     advance which line of questioning suits you best?  I'm using the line of

 8     questioning that is the most successful for me.  Do you think I'm going

 9     to pick up on what Ms. Biersay did and follow that?  No, I'm not going

10     to.  I'm interested in facts.  I want to know -- I want the public to

11     know what exactly the truth is, what the facts are.  I am --

12             JUDGE ANTONETTI: [Interpretation] Okay.  You were given

13     two hours.  Please proceed, and take your time.

14             MR. SESELJ: [Interpretation]

15        Q.   So you also say that paragraph 35 is untrue as well?

16        A.   Yes.

17        Q.   Now, paragraph 38:

18             "The commander of TO Borovo Selo was late Vukasin Soskocanin, who

19     was shot in the back and killed in mid-May 1991."

20             Is that true?

21        A.   Those were the rumours.  I don't know if it's true.

22        Q.   Then how come it's in your statement?  As far as I know, he

23     drowned in the Danube River, crossing it by boat, because there was no

24     other way the locals of Borovo Selo could communicate with Serbia.

25        A.   This is just blah-blah-blah.

Page 16041

 1        Q.   Well, he couldn't swim, and he was -- he drowned?

 2        A.   No, I'm saying that he was shot in the back.  That's

 3     "blah-blah-blah."

 4        Q.   It's in your statement.

 5        A.   I didn't say that.

 6        Q.   Soskocanin met with Seselj when the latter visited Borovo Selo.

 7     I did meet with him several times.  I agreed with him that the first

 8     volunteers of the SRS, in end April 1991, should be sent to Borovo Selo.

 9        A.   I know about one meeting, and I was present.

10        Q.   In paragraph 39, it says that you stated, allegedly:

11             "I personally think that the incident in Borovo Selo, when, on

12     the 2nd of May, 1991, 12 Croatian MUP members got killed, was

13     orchestrated by the State Security Service of Serbia.  Seselj was not so

14     powerful at that time.  His power grew only later."

15             Is that true?

16        A.   I can only know what I say.  The units of the MUP raided the

17     center of Borovo Selo and attacked the local commune when the agreement

18     to remove barricades had already been reached.

19        Q.   Which MUP?

20        A.   Croatian, of course.

21        Q.   What would the State Security Service of Serbia then have to do

22     with the incident in Borovo Selo?

23        A.   Maybe they met the MUP of Croatia and got confused.

24        Q.   It says the incident was orchestrated by the SDB, the State

25     Security Service of Serbia.  Do you know that?

Page 16042

 1        A.   No.

 2        Q.   That there was 16 volunteers of the Serbian Radical Party there

 3     and one volunteer of the Serbian Popular Renewal.

 4        A.   Yes.  He was killed at the entrance to the town hall.

 5        Q.   And he wasn't fighting?

 6        A.   No, he was reading a newspaper there.

 7        Q.   I went to attend his funeral.

 8        A.   So did I.

 9        Q.   And when the Croatian police raided, our volunteers fought back,

10     and then the JNA came in to save the Croatian policemen.  They separated

11     the two sides and helped the Croatians get out.

12        A.   Yes.  At that time, the JNA was playing UNPROFOR.

13        Q.   Is this a well-known fact to the Serbian public?  How does the

14     State Security Service of Serbia come in?

15        A.   I don't know that.

16        Q.   Here in paragraph 40, you allegedly described how Milic was

17     killed, that he was not armed, and you say:

18             "Seselj is a bit of an exhibitionist and he likes to brag about

19     things that he never did.  That's why he said the Borovo Selo operation

20     was carried out by his volunteers.  Seselj would do anything to be at the

21     center of attention."

22        A.   That's not what I said.

23        Q.   Well, how come it's written like that?

24        A.   Ask the Prosecutors.

25        Q.   Did 16 volunteers of the SRS fight with Croatian police in

Page 16043

 1     Borovo Selo?

 2        A.   Yes, led by Mladen Tersijevic [phoen].

 3        Q.   But this Mladen wasn't even involved in the fighting, because he

 4     happened to be without a weapon, but his deputy, Oliver Barrett, took up

 5     his duties and made sure that the locals get involved in the fighting.

 6        A.   That's correct.

 7        Q.   But the first to fight back were the volunteers of the SRS.  Is

 8     that what you would call bragging?

 9        A.   That's how they qualified it.

10        Q.   Who?

11        A.   Prosecutors.

12        Q.   First I brag about military successes, and then I'm a war

13     criminal.

14             And then in paragraph 48, it says that somebody very powerful in

15     the government was behind this Pekic, the president of the Association of

16     Serbs Outside Serbia.  First of all, he wasn't the president; he was a

17     member of the board.

18        A.   I really can't remember.

19        Q.   He was a national hero?

20        A.   Yes.

21        Q.   He was a partisan general from second -- World War II?

22        A.   Yes.

23        Q.   Was he a president or a high official of the Association of War

24     Veterans?

25        A.   Yes.

Page 16044

 1        Q.   Did he have enough -- didn't he have enough authority that he had

 2     to find someone in the army to whom he would say, Don't destroy these

 3     weapons, I'll take them on?

 4        A.   He did have.

 5        Q.   Were there other such generals?  Have you heard of

 6     Radojica Penezic?

 7        A.   I've heard of him.

 8        Q.   He also got involved, and many others, but Pekic played the most

 9     prominent role.

10             And it says here that Milosevic's regime was against Chetniks,

11     and that's absolutely true, but he was very happy at the first

12     opportunity to send volunteers to the front-line in order to get rid of

13     them.  Is that true?  Did Milosevic's regime send any volunteers at all?

14        A.   It all went bypassing Milosevic and his regime.

15        Q.   Did we handle the sending of volunteers until October 1991?

16        A.   Yes.

17        Q.   Did they cross the river by boats because the police was guarding

18     the bridges?

19        A.   And I was with them several times.

20        Q.   Did we clash with them several times, with the police, because

21     they would intercept these people who were not carrying weapons?

22        A.   We did.

23        Q.   Now, in paragraph 44, you say:

24             "We got some premises in Lipovac."

25             I don't remember anything like that.  There were premises for the

Page 16045

 1     Assembly of all volunteers, not specifically ours.

 2        A.   That was the assembly centre for all volunteers before they were

 3     sent on.

 4        Q.   And it says the buses were provided by the Ministry for Relations

 5     with Serbs Outside Serbia.  If that were true, the Prosecution would have

 6     found the necessary documentation in his ministry and brought it here,

 7     right?  Because you can't get any buses without travel documents.

 8        A.   Right.

 9        Q.   If a company from Serbia, as a sponsor, provides the buses, then

10     they can be used.

11        A.   Of course.

12        Q.   Can a driver get out of Serbia in a company vehicle without a

13     travel order?

14        A.   No, he can't.

15        Q.   Now, in paragraph 45, it says when you arrived with a group of

16     volunteers to Vukovar -- you went to Vukovar; I don't think it's in

17     dispute.

18        A.   I did.

19        Q.   This document by Ljubisa Petkovic, together with the list of

20     names of volunteers, was given to Milan Lancuzanin, also known as Kameni.

21        A.   Right.

22        Q.   And then it says:

23             " ... also to Stanko Vujanovic and to Stanko's wife, Nada, who

24     was the secretary of the TO."

25             Did you have three lists?

Page 16046

 1        A.   I had one list in duplicate, but one copy I had to keep.

 2        Q.   So you gave the list only to Kameni?

 3        A.   Yes.  He had to get one copy, and I had to return one copy to the

 4     War Staff.

 5        Q.   Where do Stanko Vujanovic and his wife come in?

 6        A.   Maybe I said they were present when I gave the list to Kameni.

 7        Q.   The headquarters of the Leva Supoderica Unit, was it in Kameni's

 8     house?

 9        A.   It was in Nova Street.  I don't know whose house.

10        Q.   Do you remember Stanko Vujanovic had his own unit under the

11     command of the Territorial Defence?

12        A.   Yes.

13             THE INTERPRETER:  Interpreters note:  Could we slow down, please.

14     None of the speakers have really slowed down.

15             JUDGE HARHOFF:  Mr. Seselj and Mr. Witness, again, please slow

16     down.

17             MR. SESELJ: [Interpretation]

18        Q.   In paragraph 47, it says that the commander of the Sector South

19     was Mile Mrksic.  Fine.  Veselin Sljivancanin was the operative officer

20     of the sector in charge of the TO.  Did you say that?

21        A.   No, I didn't say that.

22        Q.   Do you know what Sljivancanin was at the time?

23        A.   I know he was a major.

24        Q.   Was he a security officer of the Guards Brigade and then security

25     officer of the Operative Group South?

Page 16047

 1        A.   Yes.

 2        Q.   How can he be the operative group officer of the sector?  Did the

 3     security officer have any command over units?

 4        A.   No.

 5        Q.   Who could be subordinate to him?  Only the military police;

 6     right?

 7        A.   Right.

 8        Q.   Not always, though, but only on the orders of the commander or

 9     along the security line.

10        A.   Correct.

11        Q.   Did security officers have two lines of command; they were

12     subordinate to commanders of their unit, and they were subordinate to the

13     Security Service of the JNA?

14        A.   That's correct.

15        Q.   We're still on the first statement.  You say:

16             "Mid-November, before the fall of Vukovar, I went to Vukovar."

17             That was in the first half of November.  We also have here the

18     exact date in the transcripts; that you were there, that "a group of

19     volunteers went with me."  Is that true, when I went from Belgrade to

20     Vukovar?

21        A.   No.  A group of volunteers joined you in Sid.  They were to be

22     the escorts.

23        Q.   They met me in Sid?

24        A.   Right.

25        Q.   Do you know I was driving my personal car, a Toyota Corolla, and

Page 16048

 1     there was my -- there was Petar Panic with me?

 2        A.   Yes, your personal bodyguard.

 3        Q.   And it also says here that from Lipovaca, I went to Vukovar on an

 4     armoured personnel carrier provided by the JNA.  They gave us four APCs.

 5     Is that true?

 6        A.   I can't remember what the escort was, but there was some buses

 7     carrying other volunteers going the same way.

 8        Q.   Please, we're talking about military APCs.  It was, in fact, a

 9     combat armoured vehicle.

10             JUDGE ANTONETTI: [Interpretation] You have had one hour already,

11     and you have one hour left.  In 15 minutes, we will have a break, around

12     a quarter to 6.00.  We will have a 15-minute break then and resume at

13     6.00.  Mr. Seselj will resume.  We will see at what point he will stop

14     and let Ms. Biersay put her questions.

15             Given that we are running late, we will have to go beyond

16     7.00 p.m., because we must finish this witness today.  We should finish

17     around 20 minutes past 7.00 or 25 minutes past 7.00.  I just wanted all

18     and everyone to be informed.

19             Please proceed, Mr. Seselj.  You have a quarter of an hour before

20     the break.

21             MR. SESELJ: [Interpretation]

22        Q.   As far as I can remember, I first went to Mirkovci, near

23     Vinkovci, and then to Vukovar; is that correct?

24        A.   I can't remember the sequence, but it is possible.

25        Q.   In one part of that journey from Sid to Mirkovci, the Ustashi

Page 16049

 1     threatened the traffic, and that's why I had to use the APC.  Do you

 2     remember that?

 3        A.   I believe that the place was called Siska Planica [phoen].

 4        Q.   And when I returned from Mirkovci, I continued in my own vehicle

 5     to Vukovar because there was no danger between Sid and Vukovar.

 6        A.   Yes.

 7        Q.   A witness perjured himself here.  He said he was a volunteer.  He

 8     said that he fought from Sid to Vukovar, trying to liberate the Serbian

 9     villages around there.

10             MS. BIERSAY:  Objection, Your Honour.  The characterisation of

11     any statement made in this courtroom as perjury is only for this

12     Trial Chamber and not for Mr. Seselj to cast aspersions to other

13     witnesses about past testimony.  So we object to him using this

14     repeatedly when he discusses past evidence.

15             JUDGE ANTONETTI: [Interpretation] Mr. Seselj --

16             THE ACCUSED: [Interpretation] It is my right to qualify anybody's

17     testimony.  And when a witness perjures himself, I shall say so.  I

18     didn't say that the witness is a liar; I just said that he perjured him.

19     And it is indeed a perjury that he fought from and Sid to Vukovar.  There

20     was no fighting there ever.  Those villages were free and liberated from

21     day one.  And when there was fighting for Vukovar, Serbs had already had

22     part of Vukovar under control, because they had resided as a majority

23     population.

24             My main thesis is that all charges against me are based on

25     witnesses who have perjured themselves.  The whole process is just a

Page 16050

 1     fabrication; it's a political process, and I blame Carla Del Ponte for

 2     that.  You cannot change my thesis at your own will.  And the fact that

 3     this is not happening in other proceedings, you have to thank the lawyers

 4     for that.  They sacrificed their interest for the big bucks that they

 5     receive for their work.

 6             And now what we have in England, General Krstic almost -- was

 7     almost slaughtered in prison.  He was sentenced to 35 years, and still he

 8     had nothing whatsoever to do with crimes.  And now, instead of informing

 9     the media that General Krstic was slaughtered by Bosnian Muslims and

10     Albanian Muslims who are criminals, there is false information in the

11     media that he had been beaten up, which is nonsense.  You cannot -- but

12     the truth will out.  You cannot prevent the media from --

13             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, please get back to

14     the statements.

15             MR. SESELJ: [Interpretation]

16        Q.   And now we are on the way to Vukovar, and I stop in Negoslavci.

17     And there I met the then colonel, and later on General Mile Mrksic; is

18     that right?

19        A.   Correct.

20        Q.   Veselin Sljivancanin wasn't there, and Miroslav [as interpreted]

21     Radic wasn't there, and in paragraph 53 it says that they were there.

22     How come?

23        A.   I don't know.

24        Q.   It says that I greeted them and that our exchange lasted for five

25     minutes.  I only met with Mrksic.  We greeted each other, and then I

Page 16051

 1     proceeded towards Vukovar.

 2        A.   As far as I remember, Colonel Mrksic was there, and

 3     Lieutenant-Colonel Panic was there.

 4        Q.   Miodrag Panic, the chief of staff, who was later promoted into

 5     the rank of general.

 6        A.   Yes.

 7        Q.   And the first time I was in Vukovar, I had a very small helmet,

 8     and the officers laughed at that helmet, and Miodrag Panic gave me his

 9     own helmet; is that correct?

10        A.   Were you there?

11        Q.   Yes, I was.

12        A.   Well, there you go.

13        Q.   And now in paragraph 54:

14             "As we went on towards Vukovar, Sljivancanin was at the head of

15     that convoy.  We went straight into Nova Street, where Lancuzanin's

16     headquarters was."

17        A.   The only thing that's correct here is that the command was in

18     that street.

19        Q.   I was escorted to the front-line by Major Borivoje Tesic.  Have

20     you ever heard of him?

21        A.   Of course.

22        Q.   Was he the commander of the 1st Assault Detachment?

23        A.   Yes.

24        Q.   And I met Sljivancanin only briefly.  He was carrying a Motorola

25     in his hand, and he was yelling or shouted back at the Ustasha Commander

Page 16052

 1     Jastreb?

 2        A.   Yes, they communicated regularly.

 3        Q.   I just shook his hand and I went to the front-line.  I don't know

 4     whether Sljivancanin had ever been to the front-line.

 5        A.   I don't know.

 6        Q.   He was not in command of any of the units; he was a security

 7     officer, was he not?  Do you agree that this is another blatant lie?

 8        A.   Of course it is.

 9        Q.   Again, it says here when we arrived in the Nova Street where

10     Lancuzanin's command was, we were met by Minister Lancuzanin, Stanko and

11     his wife.  Do you know that I never met Miroslav Ljubovic [as

12     interpreted] my whole life?  Did you ever see us meet?

13        A.   I did meet him, and I don't know whether you did or not.

14        Q.   Miroljub Vujovic provided an interview to The Hague OTP.  I

15     disclosed -- I was disclosed that interview, and he confirmed there that

16     he had never met him.  I did meet Stanko.  Stanko later, in 1993, became

17     a member of the Serbian Radical Party of the Republic of Serbian Krajina,

18     and then he was elected as an MP there.  Is that correct?

19        A.   That's what I heard.

20        Q.   As for Miroljub Vujovic, I never met him in my whole life.

21             And it says here as well that Sljivancanin explained the

22     situation on the front-line to me --

23             MR. MARCUSSEN:  I apologise for interrupting, but I am not aware

24     whether or not the person whose interview the accused just referred to

25     might be a protected witness or whether or not it's a witness who hasn't

Page 16053

 1     testified yet.  So I would like to request that the name be redacted, or

 2     we redact, on this page, page 80 in the transcript, the question that

 3     begins at line 11.

 4             THE ACCUSED: [Interpretation] I'm better informed than

 5     Mr. Marcussen.  Miroljub Vujovic was never a witness here in The Hague.

 6     He was interviewed as a suspect, and then he was on trial in Belgrade.

 7             MR. MARCUSSEN:  In that case --

 8             THE ACCUSED: [Interpretation] And he was tried in open trial.

 9             MR. MARCUSSEN:  In that case, I would request -- I would

10     certainly maintain that we should redact this part so we don't reveal the

11     identity of people who have been interviewed by the OTP to the public.

12             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, if Mr. --

13             THE ACCUSED: [Interpretation] This cannot be redacted.  I did not

14     receive that as a confidential document.

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

16             If this person Miroljub Vujovic has never been the subject of a

17     decision or has never been granted protective measures, I don't see why

18     we would redact this, all the more so that he has tried and convicted,

19     and his name is in the public domain.  So why would you want to redact it

20     from the transcript?

21             MR. MARCUSSEN:  It is our submission that it is not in the public

22     interest that people who provide information and are being interviewed by

23     the OTP see their identity published.  This is disclosure material that

24     has best been provided to the accused for the purpose of the preparation

25     of his case, and people should be able to speak to the Office of the

Page 16054

 1     Prosecutor knowing that their identity is only revealed if they become

 2     witnesses.

 3             Now, I'm also not in a position to verify whether or not there

 4     might be some protective measures with respect to this, which is why I

 5     request that we redact any -- if the Court finds later on that we

 6     un-redact, then maybe we can do that.  But once the information goes out,

 7     we cannot put the cat, if I may say so, back into the bag.  So as a

 8     temporary measure, I request that we redact.

 9             JUDGE ANTONETTI: [Interpretation] I shall confer with my

10     colleagues and see what the position of the Chamber is on this.

11             THE ACCUSED: [Interpretation] Protective measures cannot be

12     applied retroactively.  That man appeared in open court in Belgrade.  He

13     was on trial there.  I am not going to deal with the "hows" of that

14     trial.  I just quoted one sentence from his interview, in which he said

15     that he never met me, and he provided that statement back in 2002 or

16     2003, and there is nothing that can either help him or go against him in

17     that.

18             JUDGE ANTONETTI: [Interpretation] One moment, Mr. Seselj.  We are

19     deliberating.

20                           [Trial Chamber confers]

21             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, could you check,

22     please, whether a decision has granted him protective measures?  You can

23     let us know after the break.  But if no decision has been taken to grant

24     him protective measures, I don't see for what reason we would redact

25     this, all the more so that this witness had a public trial and everyone

Page 16055

 1     knows this individual.

 2             MR. SESELJ: [Interpretation]

 3        Q.   Okay, let's go back to where we left it off.

 4             Major Borivoje Tesic, did he --

 5             JUDGE ANTONETTI: [Interpretation] As a precautionary measure, we

 6     will redact between now and the break.  And if you don't tell us after

 7     the break that he was granted protective measures, then this will be made

 8     public.

 9             Please proceed, Mr. Seselj.

10             MR. SESELJ: [Interpretation]

11        Q.   Who was it who explained the military situation to --

12     Major Borivoje Tesic or Major Sljivancanin?

13        A.   I wasn't there at that moment, but I would suppose that it was

14     Borivoje Tesic because it would have made much more sense.

15        Q.   Okay.  So what it says here in paragraph 54, is it a lie or not?

16        A.   It could not have been a security measure -- would have explained

17     the operative situation to you.

18        Q.   Do you know that between me and Major Sljivancanin, there was

19     always a degree of animosity, because Major Sljivancanin was in command

20     of the guards unit that was deployed around the house of flowers when we

21     attacked it and --

22        A.   Major Sljivancanin was a notorious Communist.

23        Q.   So why would he escort me to the front-line?  What did we have in

24     common?

25        A.   I don't know.

Page 16056

 1        Q.   Especially in view of the fact that I attacked his boss,

 2     Vasiljevic, in public?

 3        A.   Correct.

 4        Q.   In paragraph 55, it says that I said that our forces had to

 5     maintain courage and to hold on until the end.  I may have said it; I

 6     don't know.  It says that I wore a helmet; that's correct.  Do you know

 7     why I wore a helmet?  That was during my second arrival in Vukovar.  The

 8     first time I arrived, the officer asked me to wear a helmet in order to

 9     exert positive influence on the young soldiers who avoided that

10     obligation, and many lost their heads.

11        A.   I suppose that that was the reason.

12        Q.   And that's why I wore this helmet without a red-pointed --

13     five-pointed red star, in order to serve as a good example to the others.

14        A.   Many other regular soldiers did that.

15        Q.   Do you remember that I scraped off the red star with a bayonet?

16        A.   Yes.

17        Q.   And it says here that I wore a flak-jacket.  Did you say that?

18        A.   No, I didn't.

19        Q.   I never -- in my whole life, I never wore a flak-jacket, wherever

20     I went, however dangerous it was.  There are many such places in the

21     world.

22        A.   Me neither.

23        Q.   So why did you mention that in your statement?

24             THE INTERPRETER:  Could the witness and the accused please be

25     asked to slow down and make pauses.

Page 16057

 1             THE WITNESS: [Interpretation] We have to ask the investigators.

 2             MR. SESELJ: [Interpretation]

 3        Q.   And it says that Milosevic and Seselj were establishing close

 4     links.  Why were you --

 5             JUDGE ANTONETTI: [Interpretation] You are both going too fast.

 6     We will have our 15-minute break now and resume in 15 minutes' time.

 7                           --- Recess taken at 5.44 p.m.

 8                           --- On resuming at 6.06 p.m.

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

10             MR. MARCUSSEN:  I would like to thank the Trial Chamber for its

11     understanding with respect to the protection of the individual that was

12     discussed earlier.  As far as I've been able to determine, this person

13     has actually been a witness here, but he has testified in open session.

14     So I think the pages that were redacted can be released.  Thank you.

15             JUDGE ANTONETTI: [Interpretation] So we're going to release what

16     we had decided to provisionally redact while waiting for your position.

17             I also invite the witness and Mr. Seselj to slow down.

18     Interpreters are very tired.  Are you going too fast.

19             So, Mr. Seselj, please proceed.

20             MR. SESELJ: [Interpretation]

21        Q.   We have arrived at paragraph 56, where it says that I, from

22     Kameni's house, passed by the supermarket.  And then from the technical

23     school, we returned to the TO Command on foot.  And in front of that

24     command, there were several vehicles parked.  That's where I stopped, and

25     I said not a single Ustasha must leave Vukovar alive.  Is that true?

Page 16058

 1        A.   I didn't hear such words.

 2        Q.   So why is it in your statement, in your alleged statement?

 3        A.   I don't know.  We did invite the Ustasha to surrender, but much

 4     before you arrived.

 5        Q.   It says that at least 50 people were present.  Is that correct?

 6     Did 50 people dare to be at one place at a moment when the Croatian

 7     artillery pounded from the center of Vukovar with mortars and from

 8     Nustar, where they had proper artillery, like cannons, Howitzers, and so

 9     on?

10        A.   Yes, Howitzers.

11        Q.   Was it possible for 50 people to gather in one place for me to

12     deliver a speech to them?

13        A.   I wouldn't know that.

14        Q.   But this is in your alleged statement?

15        A.   I told you several times already I don't know what it says in

16     that statement.

17        Q.   And that there were volunteers, members of the TO, and the

18     officers of the Guards Brigade, Sljivancanin, Radic, and others.  There

19     is a slight difference between your statement from the statement of other

20     witnesses, who said that it was in Stanko Vujanovic's house, that it was

21     halfway between Vujanovic's house and Kameni's house, and so on and so

22     forth.  However, the tendency is present on the part of the OTP that I

23     said that no Ustasha should be allowed to leave alive, that the guards

24     officers were listening to that, and that's why 200 prisoners were

25     executed in Ovcara.  This is the fabrication that they put together.  Do

Page 16059

 1     you find it funny?

 2        A.   Yes.

 3        Q.   And you never knew that this was in your statement, the one that

 4     you signed?

 5        A.   No.

 6        Q.   Very well.  And that there was general euphoria, that there was

 7     celebratory shooting in the air as a sign of support, are you aware that

 8     that is also in your alleged statement?

 9        A.   I don't know.  As far as I know, nobody normal would have spent

10     ammunition in a situation like that.

11        Q.   And I went to the front-line, where some -- where a person could

12     be killed at any moment.  Do you know -- do you remember that a Serbian

13     soldier died in my vicinity while I was in Vukovar?  He was on a motor,

14     he was probably a courier, and a mine exploded and killed him on the

15     spot.  Do you remember that?

16        A.   I believe that it was two streets away from where you were.

17        Q.   Do you remember that I went to visit that family to express my

18     condolences because the soldier was from Vukovar?

19        A.   Possible.

20        Q.   What kind of a lunatic would gather 50 people in one place where

21     they could be hit by a shell or a mine?

22        A.   If I remember properly, immediately after that shelling started.

23        Q.   When the Ustasha found out that I was in Vukovar?

24        A.   Yes.

25        Q.   Do you know that I remained in Vukovar and that I spent the night

Page 16060

 1     there in a house in Kameni's neighbourhood?

 2        A.   Yes, I believe so.

 3        Q.   Do you remember that Croats used agricultural planes during the

 4     night to throw boilers full of explosives on Vukovar?

 5        A.   Yes, and gas bombs.

 6        Q.   Do you remember that such a bullet landed very close to the house

 7     where I spent the night?

 8        A.   I know that one such bullet was thrown out, but I don't know

 9     where it exploded.

10             THE INTERPRETER:  Could the witness and the accused please make

11     pauses between questions and answers.

12             JUDGE HARHOFF:  Gentlemen, you are having a private conversation,

13     and very little of it is coming to us.  So unless you speak at a pace

14     that the interpreters are able to follow, this is all in vein.  And we

15     are not entertaining the Serbian public here in this courtroom.  We are

16     on a serious trial.  So please slow down and observe a pause between

17     question and answer.

18             MR. SESELJ: [Interpretation].

19        Q.   In paragraph 60, you describe, allegedly, my departure to

20     Western Slavonia, and you say -- I mean, allegedly you say:

21             "I'm not 100 per cent sure, but I believe that during that tour

22     of Western Slavonia, Zoran Drazilovic accompanied Seselj, but my

23     bodyguard, Petar Panic, and other security men were certainly with me.

24     And I met with volunteer commanders Radovan Novacic, Slavko Nisic, and so

25     on."  But you were not present; you just know about it.

Page 16061

 1             Did you say that?

 2        A.   What I said was the following:  As far as I know, you did visit

 3     the volunteers in Western Slavonia, and if I remember correctly, it was

 4     in November.  I also went there, but those were two separate visits.  I

 5     didn't go together with you.  I went separately.  And who accompanied

 6     you, I really don't know.

 7        Q.   To this day, you don't know how I went there?

 8        A.   Of course not.

 9        Q.   If I tell you that I went by a JNA helicopter; that this,

10     helicopter was secured for me by the commander of the air force,

11     General Bozidar Stevanovic, does that ring a bell?

12        A.   I know who Bozidar Stevanovic was.

13        Q.   Do you believe that I travelled by a JNA helicopter?

14        A.   Why not?

15        Q.   And there were two air force officers piloting the helicopter,

16     and there was Ilija Sasic, minister of foreign affairs of the

17     Western Slavonia region.  Do you believe me?

18        A.   I do.

19        Q.   Do you believe that was the way I travelled?

20        A.   There's no reason for me not to believe you.

21        Q.   We took the helicopter to Banja Luka, and from there, by car, to

22     Western Slavonia.  And then after touring Western Slavonia, two days

23     later I held a rally in Banja Luka.  Did you hear about that rally in the

24     Borik Hall, where several thousands of people attended?

25        A.   I heard of that rally.

Page 16062

 1        Q.   Did you hear that after that, at the invitation of Milan Babic, I

 2     went -- travelled by night to Knin to prevent a mutiny organised by

 3     Captain Dragan against the legal Serbian authorities?

 4        A.   I was busy doing other things, but I heard about that.

 5        Q.   And at the time that Vukovar was liberated, I was still in Knin;

 6     right?

 7        A.   Well, if I remember correctly, yes.

 8        Q.   The Prosecutors have footage of my duel with Captain Dragan in

 9     Benkovac.  It was shown in the courtroom.  We'll not dwell on it.

10             JUDGE ANTONETTI: [Interpretation] Witness, I was wondering

11     whether Captain Dragan is the one that has just been arrested in

12     Australia today.

13             THE WITNESS: [Interpretation] Yes, yes.

14             THE ACCUSED: [Interpretation] That's very sad news to me,

15     Mr. President, that Captain Dragan was arrested.  I was hoping they would

16     not manage to arrest him.  Despite the fact that we did not agree during

17     the war, I cannot be happy over any extradition of Serbian fighters to

18     the Ustasha authorities in Croatia, because they cannot have a fair trial

19     there.  Nobody can have a fair trial, including here.

20             MS. BIERSAY:  Could the Court please instruct him or turn his

21     microphone off when he goes on these specific accusations that have no

22     basis in this trial.

23             JUDGE ANTONETTI: [Interpretation] Please proceed.  Mr. Seselj, we

24     are aware that Captain Dragan has been arrested.

25             MR. SESELJ: [Interpretation]

Page 16063

 1        Q.   We've come to paragraph 63.  It's about Mali Zvornik.  It says:

 2             "I did not go to Seselj with Mali Zvornik after Zvornik was

 3     captured.  But from what I remember, Seselj went there to hold a rally

 4     after the capture of Zvornik."

 5             Did you say this, that it was in the middle of April?

 6        A.   First of all, I would never say that.  I know that these are not

 7     my words for one simple reason:  I never used the term "capture."  I

 8     always spoke about liberation.  Second, I persistently told the

 9     investigators that the rally of the Serbian Chetnik Movement was held in

10     1990, whereas they tried to convince me that it was in 1992.

11        Q.   Why would I be holding a rally in Mali Zvornik while there was

12     still fighting in Veliki Zvornik?

13        A.   Well, that would have had unfathomable consequences.

14        Q.   And the volunteers had to be brought over the bridge to protect

15     me, and they were still fighting over Kula Grad until 26th of April;

16     right?

17        A.   From what I know, yes.

18        Q.   So you deny that these are your words?

19        A.   I deny the contents of the statement.

20        Q.   There's a note here of the investigator.  The investigator quotes

21     Seselj's speech from a certain paragraph of the indictment.  He quotes

22     from my alleged speech, because one false witness claimed that I held a

23     speech in Mali Zvornik in March 1992, before the fighting in Zvornik, and

24     that I called the Muslims "pagans," which is absolutely impossible.  Have

25     you ever heard me say anything nasty about the Islamic religion?

Page 16064

 1        A.   No, never.

 2        Q.   Had you ever heard me saying anything bad about the Catholic

 3     religion, set aside the fact that I always attacked Popes in their role

 4     as politicians, but did I ever insult the Roman Catholic religion?

 5        A.   No, never.

 6        Q.   Or any other religion, the Tao, the Buddhism, or any other

 7     religion?

 8        A.   Not that I heard.

 9        Q.   Could a man of my educational attainment call Muslims "pagans,"

10     when Islam is a mono-theistic religion originating from the roots of

11     Christianity and Judaism?

12        A.   No, I don't think so.

13        Q.   It's true that we had religious wars under Ottoman occupation,

14     but that's a different matter.  So you deny what's in paragraph 63.

15             In paragraph 66 they must have asked you about Ovcara, and you

16     said you never heard about the events there.  Did we in Serbia really

17     know what had happened in Ovcara until the exhumations began, until the

18     Croats and the foreigners in Vukovar disclosed that there was a mass

19     grave there?

20        A.   Of course not.  The first time I heard of Ovcara was after the

21     war.

22        Q.   Was it a closely-guarded secret kept by the Military Security

23     Service, led by Aleksandar Vasiljevic?

24        A.   It must have been secret.

25        Q.   Those who organised it and those who participated in the

Page 16065

 1     liquidations closely guarded the secret?

 2        A.   Correct.

 3        Q.   And those who had command in Vukovar knew about it?

 4        A.   That would be logical.

 5        Q.   Does it sound logical to you that the military commander of

 6     Vukovar comes here, after the liberation of Vukovar, to testify against

 7     me?  He, the town commander where Ovcara happened, and where it was

 8     covered up, to testify against me, who didn't even know about Ovcara?

 9     Does that sound logical to you?

10        A.   It's very far from common sense.

11        Q.   Since he is a protected witness, I won't mention his name.  He

12     didn't really level any charges against me or accuse me of anything, but

13     it's horrible that somebody who was involved is testifying against me who

14     didn't even know about Ovcara.

15             JUDGE ANTONETTI: [Interpretation] Just a second, Mr. Seselj.

16     I think you're going so fast, I think that we're going to break all

17     records in terms of numbers of pages of transcript.  We have to check

18     whether the city commander of Vukovar testified here under a pseudonym,

19     because if that is the case, we will have to redact.  Because everyone

20     can know who it is, especially since in the Mrkic judgement, his name

21     appears.

22             THE ACCUSED: [Overlapping speakers] [Previous translation

23     continues]... Mr. President.  Mr. President, nobody knows who that is.

24     You can take a poll.  Nobody knows.

25             JUDGE ANTONETTI: [Interpretation] But the commander of the city

Page 16066

 1     of Vukovar, during the liberation of Vukovar, it is an open secret.  It's

 2     in the judgement of the Mrkic case.

 3             THE ACCUSED: [Interpretation] Nobody knows who that is.

 4             JUDGE ANTONETTI: [Interpretation] Well, the Legal Officer will

 5     double-check on that.

 6             MR. SESELJ: [Interpretation] Let's go on.

 7        Q.   Paragraph 66 says:

 8             "Still, with regard to Ovcara, I had stories that the Arkan's Men

 9     took some Croats there and executed them.  In informal conversations with

10     volunteers, I heard nothing about the alleged involvement of Kameni or

11     other volunteers in Ovcara events."

12             Did you really hear that Arkan's men killed Croats there?

13        A.   No, never.

14        Q.   Set aside the fact that we know that Arkan's men did commit

15     crimes in other locations, they were simply not present in Ovcara;

16     correct?

17        A.   Correct.

18        Q.   Is it true that they were not present at all in Sector South?

19        A.   No, not in Sector South.

20        Q.   They were in Sector North, under the command of the Novi Sad

21     Corps?

22        A.   Yes.

23        Q.   And they could have appeared in Sector South only after the

24     fighting was over in Vukovar?

25        A.   Correct.

Page 16067

 1        Q.   But nobody ever heard that Arkan's men were killing in Ovcara?

 2        A.   Right.

 3        Q.   Were you in Zvornik in April 1992?

 4        A.   In Mali Zvornik.

 5        Q.   But not to Veliki Zvornik?

 6        A.   No.

 7        Q.   In paragraph 67, we read that you heard that some civilians had

 8     been killed in Vocin, and "I was informed about it through the

 9     volunteers."  Then paragraph 68:

10             "White Eagles were there, and after that we accused each other,

11     Bokan, the commander of White Eagles and we in the staff of the Radical

12     Party, we accused each other of these crimes."

13             Did you say that?

14        A.   No.  The truth is I read in enemy papers, and we know what enemy

15     newspapers are, what they wrote about Vocin.

16        Q.   However, we know about it because I published all my public

17     speeches, in my books.  We condemned this crime, and we blamed the

18     White Eagles.

19        A.   Correct.

20        Q.   We didn't mention Bokan.  I don't know that he was involved to

21     this day.  However, Bokan never claimed that it was the volunteers of the

22     Serbian Radical Party who had done it.  Is that true?

23        A.   From all I know, it's true.

24        Q.   You mean what I'm saying is true?

25        A.   Yes.

Page 16068

 1        Q.   Then how come your statement says that we accused each other?

 2        A.   I don't know.

 3        Q.   In paragraph 57, it says that you -- sorry, 67, it says that you

 4     went to tour Arkan's training centre in Erdut.

 5        A.   That's not what I said.  I said in the summer of 1991, I dropped

 6     by at Erdut because I had a friend who was in Arkan's unit and I wanted

 7     to bring him over to our unit.

 8        Q.   Do you know that I was there once, that I passed through, I had a

 9     look at the centre, and then went on to Borovo Selo?  Why would that be

10     strange?

11        A.   It's not strange.

12        Q.   Because the commander of Baranja of Western Slavonia and Srem was

13     Badza; right?

14        A.   Yes.

15        Q.   And I saw Arkan, what does it mean?  If I met him there and then

16     at a funeral, and at the session of the National Assembly in 1993, does

17     that mean that we co-operated?

18        A.   No, that cannot mean that.

19        Q.   Do you know that already in the 1980s I was in contact with

20     Arkan?

21        A.   I know that there were conflicts between you even before the war.

22        Q.   What if I tell you that a witness stated here that Arkan had come

23     to Zvornik in a police car of the Federal Ministry of the Interior with

24     those rotating lights on the roof; would you be surprised?

25        A.   No, not in the least.

Page 16069

 1        Q.   Did you know that Arkan worked for the Federal Ministry of the

 2     Interior for years?

 3        A.   I do.

 4        Q.   It also says here that we collaborated and co-ordinated

 5     activities with Arkan, although we acted separately.  Did you state that?

 6        A.   I'm sorry, I didn't understand.  You have to repeat.

 7        Q.   Here is what it says:

 8             "Let me clarify.  We acted separately, but we collaborated and

 9     co-ordinated our activities with Arkan.  Therefore, it was normal to me

10     to go and see Arkan, not to duplicate our presence on the ground.

11     Ljubisa Petkovic had contacts with Arkan for the same reasons."

12             However, you never saw Arkan in the War Staff.  What were we

13     supposed to co-ordinate with him?

14        A.   I never said that.  What I said was this:  It happened that our

15     units and Arkan's units happened to be in the same area.

16        Q.   That was in Tenja, but also in Zvornik?

17        A.   Yes, I heard about Zvornik.

18        Q.   Do you know how many fighters Arkan had in Zvornik?

19        A.   A small number.

20        Q.   Thirty-nine.  And do you know that his -- that the War Staff of

21     Zvornik -- or, rather, the Crisis Staff paid him to get involved in the

22     fighting in Zvornik, that he was not under the control of the JNA?  I

23     presented a statement of Colonel Tacic, who demanded that Arkan be

24     removed from Zvornik urgently.  Do you know about that?

25        A.   Nothing.

Page 16070

 1        Q.   Further on, it says in paragraph 72:

 2             "Seselj did not have a good relationship with Arkan, although

 3     they co-operated in field activities."

 4             Did you say that?

 5        A.   I said that you were not in a good relationship with Arkan, but

 6     it did happen that his and our unit shared the same area.

 7        Q.   How could we co-operate on the ground, in what possible way?

 8        A.   They were under the command of the Territorial Defence, which

 9     means that we could not co-operate with anybody.

10        Q.   So how could I co-operate with him on the ground?

11        A.   I don't know.  I'm really not clear on that question.

12        Q.   It says that Goran Hadzic came to the War Staff, as well as

13     Milan Matic.  When did that happen?

14        A.   I don't know.

15        Q.   They came to me, but not to the War Staff.  What would their

16     business in the War Staff be?

17        A.   Never.

18        Q.   Milan Martic did come, but I don't remember Goran Hadzic.  Did

19     Goran Hadzic ever come?  I can't remember.

20        A.   I can't either.

21        Q.   So how come it's in paragraph 72 of your statement?

22        A.   I suppose that somebody found this suitable.

23        Q.   Paragraph 73, Milan Babic, you didn't see him at the War Staff,

24     but it says that I and Babic were in conflict.  Where did we conflict?

25        A.   I said later on, with regard to the Babic and Martic elections.

Page 16071

 1        Q.   First of all, let me say that there was no conflict between me

 2     and Martic until the end of 1993.

 3        A.   I did say later, when Martic was elected president.

 4        Q.   Let me jog your memory.  In the 1993 elections in Republic of

 5     Serbian Krajina, those were presidential elections, we Radicals had our

 6     own candidate, Drago Leskovac?

 7        A.   Yes.

 8        Q.   And there were also Milan Babic and Martic who ran, and they went

 9     into the second round.  And do you remember that in the second round we

10     supported Milan Babic against Martic?  Were we in conflict with Martic?

11     Do you remember that Martic attacked me when I conflicted with Milosevic?

12        A.   I really forget those details.

13        Q.   Do you remember that at the beginning of 1994, Babic arrived in

14     Belgrade to agree a coalition with the Radicals?  We held a press

15     conference together at the Tanjug Press Centre.  That was a long time

16     ago.

17        A.   In 1994, I was not involved in any of the political matters.

18        Q.   You could watch that on TV.  And then Babic agreed coalition with

19     Nikolic?

20        A.   Borislav Nikolic, you mean?

21        Q.   So that was the original -- our conflict, from 1994, when he went

22     back on our coalition.  I did not have any other conflict with Babic

23     before he came to The Hague.

24        A.   I didn't mean the political conflict.

25        Q.   When he came to The Hague and made a deal with the OTP, we

Page 16072

 1     conflicted, and he ran away from me.  That's the only truth about that.

 2             In paragraph 74, it says:

 3             "Most of the requests for volunteers for the area of

 4     Eastern Slavonia came from Milan Lancuzanin, also known as Kameni, who

 5     was also a member of the SRS, and he was our contact there."

 6             Did you say that?

 7        A.   No way.  Milan Lancuzanin was a member of the SDS.  It was only

 8     later that he became a member of the SRS.

 9        Q.   Only when the war was over?

10        A.   Yes.

11        Q.   Do you know that we sent volunteers to Vukovar in agreement with

12     the JNA and in no other way?

13        A.   From the 1st of October and thereafter.

14        Q.   Do you remember that high-ranking officers of the JNA arrived in

15     the headquarters of the SRS?

16        A.   I remember that.

17        Q.   Do you remember that Ljubisa Petkovic went directly to the

18     General Staff in order to agree on things with

19     General Ljubomir Domazetovic?

20        A.   Yes, I remember that.

21        Q.   What was General Domazetovic?  Was he the deputy of the

22     secretary-general, the deputy of the chief of the General Staff?

23        A.   The deputy of the chief of General Staff.

24        Q.   I believe you're right.

25             In paragraph 75, it says that the government of SBWS decided to

Page 16073

 1     deploy our units in Dalj, which was held by Goran Hadzic, and that you

 2     went twice to the Arkan's training centre in Erdut.  Why would SRS

 3     volunteers be deployed in Dalj?  There was no threat against Dalj at that

 4     time.  Dalj had been liberated, and there was no threat after that.

 5        A.   That had nothing whatsoever to do with what I actually stated.

 6        Q.   So this is not your statement?

 7        A.   No, it's not.

 8        Q.   Very well.

 9        A.   This doesn't make sense.  Why would you send volunteers to Dalj,

10     a place that liberated amongst -- very early on amongst the first ones to

11     be liberated?

12        Q.   I agree with you.  In paragraph 77, it says that you allegedly

13     stated:

14             "In relation to the contacts between the War Staff of the SRS and

15     the representatives of the State Security of Serbia, I can say that I was

16     introduced to a person called Branko Stanisic, if that was his real name

17     at all.  He came together with Ljubisa Petkovic to the War Staff.  On one

18     occasion, Petkovic and I went to see him, to his office at the SUP office

19     at Stari Grad.  The reason for the meeting was that Petkovic needed to

20     resolve some administrative issues regarding volunteers, but I don't know

21     what the topic was, because the meeting regarding that was cancelled and

22     was held at a later stage.  I would like to add that that same person,

23     Branko Stanisic, alleged being a distant cousin of Jovica Stanisic."

24             Did you state this?

25        A.   No, not in this way.

Page 16074

 1        Q.   Do you know that he -- in prison, I shared the same block with

 2     Jovica Stanisic?

 3        A.   I know that.

 4        Q.   Jovica Stanisic says that he never heard of that Stanisic,

 5     Branko Stanisic, and that they cannot be related.  Do you believe him?

 6        A.   Ljubisa Petkovic was here.  He would be best suited to tell you

 7     who that person is.

 8        Q.   Jovica Stanisic wants to take me to court because I published

 9     some confidential documents, and there's no reason for him to state

10     anything against me.  What would be the link between the State Security

11     of Serbia and an official who had his office in Stari Grad?  Was that the

12     headquarters of UDBA?

13        A.   No, no way.  Maybe Ljubisa had something private, some private

14     matter to deal with there.

15        Q.   Very well.  Paragraph 78, you speak about conflicts between

16     volunteers and police.  That's true.  Our volunteers used to --

17     policemen, Communists, and they called them Chetniks, but those conflicts

18     all happened before the 1st of October?

19        A.   Yes.

20        Q.   When our volunteers went there in civilian clothes, without

21     weapons, and when the police officers tried to prevent that, they

22     couldn't arrest them because they didn't have either weapons or

23     uniforms --

24             JUDGE ANTONETTI: [Interpretation] I would like the OTP to conduct

25     a quick research and see whether the commander of Mostar, after the month

Page 16075

 1     of November, was granted protective measures, because I have a question

 2     mark in that regard.

 3             MS. BIERSAY:  Your Honour, do you mean Mostar or something else?

 4     In the --

 5             JUDGE ANTONETTI: [Interpretation] Vukovar.  I'm sorry, Vukovar.

 6     And I would like to know whether this person, the commander of the town

 7     of Vukovar, after it fell, had been given protective measures.  The

 8     Legal Officer is giving me a name, but I have a problem with it.

 9             MR. MARCUSSEN:  I think it would speed up the process

10     considerably if maybe we went into private session and the accused could

11     give us the name.  Then it's easier for us to do our research.  Thank

12     you.

13             THE ACCUSED: [Interpretation] I'm not going to tell you anything

14     in private session, nothing.  I will keep quiet, I will not say a word.

15             JUDGE ANTONETTI: [Interpretation] Proceed, Mr. Seselj.

16             MR. MARCUSSEN: [Overlapping speakers] ... redact the relevant

17     part.

18             JUDGE ANTONETTI: [Interpretation] I shall temporarily redact

19     page 93, which mentions the commander of the town of Vukovar.

20             MR. MARCUSSEN:  Thank you, Your Honour -- [Overlapping speakers]

21             THE ACCUSED: [Interpretation] You can redact the transcript as

22     much as you wish.

23             MR. MARCUSSEN: [Microphone not activated] We will make an effort

24     to get back to the Chamber --

25             THE INTERPRETER:  Microphone, Mr. Marcussen.

Page 16076

 1             THE ACCUSED: [Interpretation] I'll have to find medicine against

 2     attempts to threaten the public nature of these proceedings.  I don't

 3     know what the medicine will be, but there must be something.

 4             MR. SESELJ: [Interpretation]

 5        Q.   Paragraph 78, you say that the War Staff of the SRS co-operated

 6     with the State Security of Serbia, in terms of co-ordination.  What

 7     co-ordination?  What could we have co-ordinated with them in 1991?

 8        A.   I really don't understand.

 9             JUDGE ANTONETTI: [Interpretation] What comes to mind is a remedy,

10     and that would be for the Trial Chamber to prohibit the broadcasting of

11     this on Serbian Television.  This would be a good form of medicine.  This

12     is something that just comes to mind.

13             THE ACCUSED: [Interpretation] That would be a fantastic remedy,

14     Mr. President.  Why didn't you think of that three years ago?  You would

15     have been so much more successful.  You would have finished these

16     proceedings two years and eleven months ago.  Now it's a bit late, I

17     believe.

18             I'm not trying to spite you, but you seem to be trying to spite

19     me.  I don't know why.  Are you bothered because I'm defending myself and

20     doing so very successfully?  I believe that this is the main problem

21     here.

22             MR. SESELJ: [Interpretation]

23        Q.   And it says:

24             "As far as I know, we did not have any volunteers under the

25     command of the State Security of Serbia.  In any case, there was

Page 16077

 1     co-operation at all levels.  We co-ordinated our work with everybody who

 2     was present on the ground, the army, the TO, Arkan, the police.  I don't

 3     have any information about possible contacts between Seselj and

 4     Jovica Stanisic and/or Franko Simatovic.  It is possible that Seselj went

 5     to see them, but not the other way around."

 6             What does all this mean in your alleged statement?

 7        A.   I haven't a clue.  I've never heard of this before.

 8        Q.   You're not even aware of the fact that this entered your

 9     statement?

10        A.   This is preposterous.  Not only did I not know, this is

11     ridiculous.  It has nothing whatsoever to do with the truth.

12        Q.   Do you believe me if I tell you that I was never in the main

13     office of the State Security?

14        A.   I don't have any reason not to believe you.

15        Q.   Yes, I was in the Federal State Security when Mihajl Kertes was

16     appointed its boss.  Brano Crncevic was present, and Kertes gave me a

17     pistol on that occasion, a CZ-99, which I later on registered into my

18     name.  I was there once, and I was never in Jovica Stanisic's office.  Do

19     you believe me when I say that?

20        A.   Why not?

21        Q.   Which doesn't mean that I didn't know him.  I met him in November

22     1992.

23             In paragraph 79, it says that you allegedly stated:

24             "When our volunteers --"

25             JUDGE ANTONETTI: [Interpretation] Witness, Mr. Seselj has just

Page 16078

 1     said -- I shall be very brief.  I do my work as a Judge.  When I see

 2     incriminating or non-incriminating evidence, I always step in.  He has

 3     just said that he met Stanisic in November 1992.  According to the

 4     indictment, the joint criminal enterprise goes back to 1991.  So the

 5     Prosecutor states that Stanisic knew Mr. Seselj in 1991, already.  If he

 6     knew him in November 1992, then we have a problem.

 7             As far as you know, Mr. Seselj got to know Mr. Stanisic at what

 8     point in time?  Perhaps you don't know.  If you don't know, please tell

 9     me.  If you do know, tell us.

10             THE WITNESS: [Interpretation] I didn't even know that the two of

11     them were in contact at all.

12             JUDGE ANTONETTI: [Interpretation] You don't know.

13             Just one other question.  I put questions which seem to me to be

14     essential, and I avoid wasting any time.

15             Mr. Seselj testified in the Milosevic case and implicated your

16     neighbour, and he said that Mr. Petkovic had been infiltrated into the

17     Serbian Radical Party by the Ministry of the Interior, by the MUP, the

18     State Services.  What do you think of this, since you know Mr. Petkovic

19     well?

20             THE WITNESS: [Interpretation] I know Mr. Petkovic rather well,

21     but whether he was infiltrated in the Serbian Radical Party or not, I

22     wouldn't know.  Mr. Seselj would probably be able to answer your question

23     much better than I can.

24             THE ACCUSED: [Interpretation] Mr. President, you misinterpreted

25     my testimony in the Milosevic case.  I didn't say that he had

Page 16079

 1     infiltrated -- been infiltrated by the service.  We suspected

 2     Ljubisa Petkovic in 1993, that he started working for that service at

 3     that time.  In terms of partisan questions, that's my testimony in the

 4     Milosevic case, and that's when Ljubisa Petkovic was expelled from the

 5     party.  But he was rehabilitated later on.  He's heroic [indiscernible]

 6     primarily before The Hague Tribunal, and this is a -- a party matter, and

 7     this is my testimony in the Milosevic case, and you are more than welcome

 8     to check all that.

 9             JUDGE ANTONETTI: [Interpretation] Very well, we will check.

10             Ms. Biersay.

11             MS. BIERSAY:  I'm asking for a simple clarification.  It wasn't

12     captured in the English transcript.  The name that Mr. Seselj gave,

13     forgive me if I mispronounce it, but if he could say it again so that it

14     can be captured.  I believe it was Brana Crncevic, but it didn't make its

15     way into the transcript.  So if he could perhaps repeat the name.

16             THE ACCUSED: [Interpretation] Novelist Brana Crncevic was in

17     Kertes' office.  For a while, he was the head of the State Security

18     Service, and on that occasion Kertes [realtime transcript read in error

19     "Crncevic"] gave me a pistol, CZ-99, with two rounds of ammunition.  And

20     that was in 1992, sometime in June or July.  I can't remember exactly

21     when.

22             Mr. President, if you're interested, I'd like to remind you that

23     I described my first encounter with Jovica Stanisic at Jovica Stanisic's

24     request in November 1992.  He was waiting for me in a car in front of the

25     National Assembly.  I entered his car, and he informed me that an

Page 16080

 1     assassination was being prepared by Brano Micinic [as interpreted], also

 2     known as Montenegrin Arkan, in Montenegro, on the eve of my travel to

 3     Montenegro as part of my campaign, and I never saw Mr. Stanisic before

 4     that.

 5             MS. BIERSAY:  If I may, again a little transcript issue.

 6             On page 106, line 23 -- 22, it says:

 7             "On that occasion, Crncevic gave me a pistol."  I believe it was

 8     Kertes that gave the accused --

 9             THE ACCUSED: [Interpretation] The transcript is not correct.

10     Kertes gave me the pistol, and Crncevic was only there.  I found him

11     there in Kertes' office, the two of them in a conversation.

12             JUDGE ANTONETTI: [Interpretation] Proceed.

13             MR. SESELJ: [Interpretation]

14        Q.   Brana Crncevic is famous for socialising with the secret police,

15     and that's probably why he was there.  I didn't, myself, associate with

16     the secret police, but sometimes from time to time I would bump into them

17     in one way or another.

18             We have now arrived at paragraph 79, in which you allegedly said:

19             "Whenever our volunteers were transferred to the front-line in

20     Bosnia, there was never a problem.  I had with me a document that

21     consisted of three or more A4 separate pages.

22             And one would be the TO request from the field signed by the

23     local TO commander.  The second would be the approval or decision of the

24     War Staff signed by ..."

25             And so on and so forth.

Page 16081

 1             How come -- since from December 1991 you were not a member of the

 2     War Staff, why is that in your statement, since you were not a member of

 3     the War Staff?

 4        A.   How could I have done this, since I had resigned in September [as

 5     interpreted] of 1991?

 6        Q.   I know that he didn't, but how come it's in part of your

 7     statement?

 8        A.   It's not a question for me, but for the person who typed this

 9     statement.

10        Q.   The statement was typed by The Hague investigators.

11        A.   Of course.

12        Q.   You signed first the statement in English and then, by initial,

13     you signed the third one in Serbian?

14             JUDGE ANTONETTI: [Interpretation] Registrar, could you give me

15     the time that Mr. Seselj has used so that I can be informed of the

16     situation.

17                           [Trial Chamber and Registrar confer]

18             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you have 15 minutes

19     left.  You have had one hour and 45 minutes so far.  As you know,

20     Ms. Biersay has more than 30 minutes to put extra questions.  So since

21     you wanted to have the last word, you can stop now and give the floor

22     back to Ms. Biersay, or use up your 15 minutes.  You may choose.

23             THE ACCUSED: [Interpretation] You said I had a little over

24     15 minutes; right?  Let me just ask one more question, and then I'll be

25     finished with the first statement.

Page 16082

 1             No, I'd rather use all my time.  I had to fight for the right to

 2     have the last word after the Prosecution, but I don't have to exercise

 3     that right all the time.  Let me finish with this -- use up all my time,

 4     and then Ms. Biersay can ask whatever she likes, because I'd like to go

 5     through the second statement as well; whereas the third, fourth, and

 6     fifth are mainly repetition, with a number of corrections.  Let me finish

 7     this.  I don't care what Ms. Biersay is going to ask.

 8             MR. SESELJ: [Interpretation]

 9        Q.   Now, in paragraph 83, it says that:

10             "JNA uniforms were issued to us in the Vasa Carapic Barracks in

11     Belgrade in the vicinity of the Military Medical Academy."

12             Did you say that?

13        A.   I said that on one occasion, we got uniforms at that barracks.

14        Q.   What it says here, every time you got them there, and one or two

15     batches in Bubanj Potok.  I never heard of a single group got any

16     uniforms at barracks.  I know that all groups received them at

17     Bubanj Potok.  Is that right?

18        A.   No.  I personally led one group to Slavonia, and they got their

19     uniforms at the barracks Vasa Carapic, but that was once.

20        Q.   So it's not true that it was every time?

21        A.   Of course not.

22        Q.   So you got mainly your uniforms from the Bubanj Potok barracks

23     and only once in the Vasa Carapic Barracks in Belgrade?

24        A.   Yes, that's correct.

25        Q.   That I can believe, but it's certainly cannot not true, what it

Page 16083

 1     says there.

 2             Then it says that in the end of June or early July, you resigned

 3     from the War Staff and the Serbian Chetnik Movement.  It's not true, is

 4     it?

 5        A.   Of course it's not true.  You know that.  You have the paper in

 6     front of you.  I never abandoned the Serbian Chetnik Movement before it

 7     ceased to exist.

 8        Q.   So how did this come to be written in your statement?

 9        A.   That's not a question for me, really.

10        Q.   It must have suited them; right?

11        A.   Probably.

12        Q.   Let's see your statement from January 2004.  Some things are

13     typical.

14             In paragraph 11, you allegedly described the members of the

15     Central Homeland Administration of the Serbian Chetnik Movement, and

16     among others, you enumerate some people who were really there, including

17     me.  You mentioned Stanoje Djordjevic as vice-president, then

18     Maja Gojkovic, Jovan Glamocanin, Novak Savic, Nikola Poplasen, and so on.

19     Were they ever members of the Serbian Chetnik Movement?

20        A.   Some of them were never in the Serbian Chetnik Movement.  They

21     were later members of the Central Homeland Administration, but much

22     later.

23        Q.   In paragraph 12, Rado Leskovac joined later, it says.  Was he

24     ever a member of the Serbian Chetnik Movement?

25        A.   They must have confused it with the Serbian Radical Party.

Page 16084

 1        Q.   Do you remember what I'm going to say to you now?  The

 2     Central Administration was in the Serbian Chetnik Movement, whereas the

 3     Serbian Radical Party was set up later and it had a main board, and it

 4     had a main board for a long time?

 5        A.   That's right.

 6        Q.   And we abolished that section in 1994?

 7        A.   Right.

 8        Q.   And we changed the statute in 1996.  We, in the Radical Party,

 9     introduced the Central Homeland Administration to replace the main board;

10     is that right?

11        A.   I think so.

12        Q.   Let's clear these matters, because what we read here is

13     improbable.

14             Then in paragraph 15, you say that the Crisis Staff changed its

15     name into War Staff on the 1st of September.  Yesterday, you said

16     1st October, and that's the truth?

17        A.   Yes.

18        Q.   As soon as the imminent threat of war was proclaimed?

19        A.   Of course.

20        Q.   How does "1st September" appear here?

21        A.   Well, I know better.

22        Q.   We both know better, but that's what it says here.  Do you have

23     any idea how many Geneva Conventions there are?

24        A.   I meant the 1948 Geneva Convention.

25        Q.   "Geneva Conventions" is a plural.  Do you know how many there

Page 16085

 1     are?

 2        A.   I meant the rules of the Geneva Convention in 1948.

 3        Q.   But you served in the army, you did your military service.  Did

 4     all of us who served in the army, in a subject called

 5     "All People's Defence" for all arms and services, didn't we all learn how

 6     to treat prisoners of war and civilians?

 7        A.   That's true.

 8        Q.   Everybody who did their compulsory military service had to be

 9     perfectly clear about the fact that prisoners of war, women, children,

10     and civilians, must not be mistreated or tortured, that they must be

11     provided with decent living conditions.

12        A.   We did learn that.

13        Q.   Didn't all of us who served in the army know that no harm must be

14     done to civilians, prisoners of war, et cetera?

15        A.   Yes.

16        Q.   So nobody who committed crimes in this war can justify themselves

17     by saying they did not know what they were doing?

18        A.   Correct.

19        Q.   At one point here, you mention that we were sending volunteers to

20     Visegrad.  Did we ever send volunteers to Visegrad?

21        A.   This is the first I hear of it.

22        Q.   I'm skipping paragraphs.  It says somewhere else that you claimed

23     that Milan Lukic was a member of the Serbian Radical Party.  Is that

24     true?

25        A.   That's ridiculous.  I heard of Milan Lukic only after that

Page 16086

 1     incident in Strpci, after the war, when the trial began.

 2        Q.   In paragraph 85, it says that you allegedly said:

 3             "I heard that a man called Milan Lukic commanded a volunteer unit

 4     of the SRS in Visegrad, but I don't know anything about him or his

 5     activities.  His name began to appear frequently in the media after he

 6     was kidnapped by the Muslims, but before that I never heard about him."

 7        A.   Abducted by the Muslims?

 8        Q.   That's what it says here.  And as far as I know, he was not a

 9     member of the SRS in 1992.  Do you know that Milan Lukic was convicted to

10     life imprisonment here?

11        A.   I heard about that.

12        Q.   He's in the same cell block as I.  He was convicted for several

13     crimes that were ascribed to him, but the two most horrendous crimes were

14     completely fabricated.  Do you know that?

15        A.   Never heard.

16        Q.   He was convicted for burning 70 civilians in a house in

17     Pionirska Street and another 70 civilians in a house in Bikovac.  US

18     experts came to The Hague Tribunal and confirmed that there is no trace

19     of any fire whatsoever in these houses, let alone of people being burned.

20     Many of these alleged victims have been determined to still be alive.

21     Have you ever heard about this?

22        A.   No, but anything is possible here.

23        Q.   He is notorious in the Serbian public and further afield, and do

24     you know that he was paid damages for 14 months that he spent in prison?

25        A.   I don't know that.

Page 16087

 1        Q.   He was tried in absentia for the Severin incident, but the two

 2     most heinous crimes for which he was tried here were a complete

 3     fabrication.  Nobody ever heard of them.

 4             Now, you were very involved in the war, first directly, and later

 5     on you followed the situation very closely.  Did anyone ever hear that in

 6     Visegrad, in two separate houses, in two separate incidents, burnt

 7     70 civilians each time?  It's such a horrendous piece of news that nobody

 8     could ever forget it.

 9        A.   I never heard about that in my life.

10        Q.   Was the OTP clearly tendentious in trying to link me in some way

11     to Milan Lukic?

12        A.   I suppose so.

13        Q.   They must have had intentions, but they didn't manage?

14        A.   That's obvious.

15        Q.   In paragraph 57, I see they tried to link me with Goran Jelasic,

16     but it says here you said you didn't know the name at all.

17             JUDGE ANTONETTI: [Interpretation] Witness, Mr. Seselj, in

18     paragraph 57, is going to put a question to you, but I have a question to

19     put to you regarding paragraph 31.

20             In paragraph 31, there is something that -- some material

21     evidence.  For a reasonable trier of fact, it would be easy to see

22     whether you're lying or not or whether it's the Prosecutor who included

23     sentences in this statement that you did not say.  In paragraph 31, it

24     says that in April 1992, at the offices of the Serbian Radical Party, you

25     received a fax coming from the municipality -- the Serbian municipality

Page 16088

 1     of Zvornik in order for volunteers to be sent.  This is material evidence

 2     which can be easily checked if we have access to the telephone exchange

 3     and check whether a fax was sent on that day, on the 2nd or on the 3rd of

 4     April.  However, you said to us earlier on that you actually left those

 5     offices in December 1991, so you could not be there in April 1992, unless

 6     you are lying.  And if you were not there, then obviously you could not

 7     have received the fax there.  So it's either you or whoever drafted this

 8     document who is lying, because there is major material evidence here.  So

 9     what are you saying?

10             THE WITNESS: [Interpretation] Your Honours, I'm stating here,

11     under oath, that I submitted my resignation in December 1991.  Thus, in

12     April 1992, I could not have received any fax message, nor did I have any

13     duties or responsibilities in the Serbian Radical Party.

14             JUDGE ANTONETTI: [Interpretation] Very well.

15             Mr. Seselj, to conclude, you have three minutes.

16             MR. SESELJ: [Interpretation]

17        Q.   It says here that:

18             "Branislav Vakic and Oliver Dennis Barrett commanded our

19     volunteers in Herzegovina."

20             Right, that's true?

21        A.   That's what I heard.

22        Q.   I know it's a fact.  So it surprises me to read that

23     Oliver Barrett is of Jewish origin.  Did you say that?

24        A.   That's what I heard.

25        Q.   Do you know that the Chetnik vojvoda, late Oliver Dennis Barrett,

Page 16089

 1     was Albanian, his real name was Mujo Bunjaku; never heard of that?

 2        A.   I cant' remember.

 3        Q.   Now something for dessert.  The Presiding Judge Antonetti asked

 4     you about our programme, the platform of the Serbian Chetnik Movement,

 5     the idea to move out 360.000 ethnic Albanians who had driven out Serbs

 6     from Kosovo when they moved in during the Ottoman occupation.  Now, he

 7     asked, Were the Serbs supposed to return to Serbia, like Albanians were

 8     supposed to return to Albania?  Do you understand that during the fascist

 9     occupation, the Nazi occupation, those Albanians were forcibly moved into

10     Kosovo and settled in properties on land from which Serbs were driven

11     out?

12        A.   I know, and I know that Tito's regime forbade the Serbs, after

13     the war, to return.

14        Q.   Do you also know that Serbs were not forcibly resettled in

15     Slavonia and Dalmatia and other areas in Croatia; instead, the Austrian

16     emperor invited them to settle there when the Austrians drove out the

17     Ottoman Turks away from Vienna, and conquered these areas, Lika,

18     Vojvodina, Baranja, et cetera?

19        A.   Yes, they were there to protect the borders of the Austrian

20     Empire.

21        Q.   Yes, and also because Croatians fled from the Ottoman occupation,

22     and the Serbs were settled in vacant properties.

23        A.   I know that.

24        Q.   There was a border area created where Serbs were relieved from

25     taxes and their only duty was to fight for the Austrian Empire.

Page 16090

 1        A.   Yes.  It was the military krajina.

 2        Q.   Do you know that this military krajina was annexed to Croatia,

 3     with the consent of the Serbs, on the condition that Serbs be on equal

 4     footing with the Croatians as a constituent nation?

 5        A.   Yes.

 6        Q.   So Serbs could not leave their homes.  They had been settled

 7     there in empty land.  They had not driven Croats, like Serbs were driven

 8     out by Albanians?

 9        A.   Correct.

10        Q.   However, the new Ustasha regime of Franjo Tudjman drove out all

11     the Serbs from the western areas of Croatia in 1995.

12        A.   We know that after Operations Flash and Storm.

13             THE ACCUSED: [Interpretation] I don't have any more time, do I?

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you have by far

15     gone over the two-hour limit, and I did not deduct the 30 seconds that I

16     was planning to deduct from your two hours.

17             THE ACCUSED: [Interpretation] My sincere thanks, Mr. President.

18     Although you can't believe me when I say it's sincere, but it's sincere

19     this time.

20             JUDGE ANTONETTI: [Interpretation] So Ms. Biersay, you have some

21     time left.  If you have additional questions, please do so now.

22             MS. BIERSAY:  Thank you for the opportunity, Your Honour.  At

23     this time, we have no further questions for this witness.

24             JUDGE ANTONETTI: [Interpretation] Very well.  I think that the

25     interpreters would be very thankful to you.

Page 16091

 1             Witness, on behalf of my colleague -- Judge Harhoff had to leave,

 2     so he asked me to apologise on his behalf.  But on behalf of all my

 3     colleagues, we would like to thank you for having come, upon the request

 4     of the Trial Chamber, and we are wishing you all the best in the building

 5     industry, from what I believed.

 6             I'm going to ask the usher to escort you out of the courtroom.

 7                           [The witness withdrew]

 8             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I said that it

 9     would probably be the last witness before the 98 bis, but there is one

10     slight uncertainty regarding two witnesses because we are doing some

11     medical checks to see what's their state of health, and I think that we

12     will have some answer soon.  And in that case, we will not have any more

13     witnesses.

14             And as I mentioned yesterday, there are several motions that have

15     been filed, but you said you would not reply to those motions.  This

16     being said, the Chamber has to hand down some decisions, including

17     regarding the judicial notice as well as the motions regarding your

18     speeches, your statements before the General Assembly -- the National

19     Assembly, so we're going to have to look at this.  But we will not be

20     able to hand down any decision within the next 24 hours.

21             We may be able to meet again for an administrative hearing in

22     order to take stock of the situation, and, if required, you could raise

23     some new issues.  There might be some; one never knows.  And as soon as

24     we will be able to, we will issue a scheduling order for this 98 bis

25     procedure.

Page 16092

 1             Yes, Mr. Seselj.

 2             THE ACCUSED: [Interpretation] Mr. President, I have to correct

 3     you ever so slightly.

 4             In principle, I am in favour of admission, but anything that I

 5     say in the courtroom or any of my interviews should be identified.  I

 6     should be allowed to comment like we did with the video-clips.  If you

 7     admit all these documents without that, this will constitute a breach of

 8     my constitutional right.  No single document can or may be admitted if it

 9     is not on the record.  The Prosecution should say why they're tendering

10     the document, and I should be heard on whether I agree or whether I

11     disagree with the admission.

12             JUDGE ANTONETTI: [Interpretation] You are perfectly right, but I

13     do not have the motion from the Prosecutor before me.  But I believe

14     that, document by document, it must have stated the relevance and it must

15     have quoted the paragraphs of the indictment, and this motion must also

16     state what is incriminating.  And during the course of this procedure,

17     you can go through this and you can challenge formally the fact that the

18     Prosecutor attaches one of your speeches or one of your sentences to one

19     paragraph of the indictment, and you can put that in writing.  This is

20     why I said yesterday that it's going to take time.

21             I will personally have to sort out everything in chronological

22     order.  I will have to look into this.  And I did that already, and it

23     took me five hours just for that.  So this involves a great deal of work.

24     I realise that you are not getting any help.  We're not going to dwell on

25     this.  But this is something that could be very useful for us, because

Page 16093

 1     you are in the best position to tell us that the speech meant this and

 2     not what the Prosecutor was saying, it has nothing to do with the

 3     indictment, and so on and so forth.  And this is what is important here.

 4     If you're not saying anything, the Trial Chamber will look at it and they

 5     will say, Well, indeed, there is a link between this and the indictment,

 6     and there will be a decision on admitting this.

 7             Yes, go ahead.

 8             THE ACCUSED: [Interpretation] Less than half a minute.

 9             Mr. President, if this was a civil proceedings, that could be the

10     case.  But this is a criminal case, and the principle of admission in

11     court has to be respected, the principal of orality of the procedure, and

12     I insist on that.  If you do not respect that, what can I do?

13             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, do you have

14     something to say before we free our interpreters?

15             MR. MARCUSSEN:  Very briefly, now that we're on the motion.  Sort

16     of a very technical minor thing, but we filed the motion as an annex to a

17     motion for an extension of the page limit.  I'm assuming that we can just

18     take it that now that Your Honours have granted the extension of the

19     pages, we don't need to re-file the motion, we can just consider the

20     annex as the motion and proceed on that basis.  That's the only thing.

21             JUDGE ANTONETTI: [Interpretation] Of course, because we granted

22     you this extension.

23             So we will set up the date for an administrative hearing, and by

24     then I will be in a position to tell you what has been the decision of

25     the Trial Chamber as for the last two witnesses.  And I thank you very

Page 16094

 1     much, and I wish you a very good evening.

 2                           --- Whereupon the hearing adjourned at

 3                           7.15 p.m., sine die.























t that, what can I do?

13             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, do you have

14     something to say before we free our interpreters?

15             MR. MARCUSSEN:  Very briefly, now that we're on the motion.  Sort

16     of a very technical minor thing, but we filed the motion as an annex to a

17     motion for an extension of the page limit.  I'm assuming that we can just

18     take it that now that Your Honours have granted the extension of the

19     pages, we don't need to re-file the motion, we can just consider the

20     annex as the motion and proceed on that basis.  That's the only thing.

21             JUDGE ANTONETTI: [Interpretation] Of course, because we granted

22     you this extension.

23             So we will set up the date for an administrative hearing, and by

24     then I will be in a position to tell you what has been the decision of

25     the Trial Chamber as for the last two witnesses.  And I thank you very

Page 16094

 1     much, and I wish you a very good evening.

 2                           --- Whereupon the hearing adjourned at

 3                           7.15 p.m., sine die.