Tribunal Criminal Tribunal for the Former Yugoslavia

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 1                           Wednesday, 14 March 2012

 2                           [Defence Closing Statement]

 3                           [Open session]

 4                           --- Upon commencing at 2.14 p.m.

 5                           [The accused entered court]

 6             JUDGE ANTONETTI: [Interpretation] Registrar, can you call the

 7     case, please.

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

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

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

11     Wednesday, the 14th of March, 2012.  I would like to greet all the people

12     present in the courtroom, including the representatives of the OTP and

13     Mr. Seselj.

14             I would like to share with you the work undertaken by CLSS

15     relating to Exhibit P58.  This exhibit was scrutinised by the

16     interpreters and it appears that the soldiers who are chanting say as

17     follows:

18             "There will be meat, there will be meat, we will slaughter

19     Croats."

20             That is all that has been heard on this video recording.  That

21     said, the song is much longer, but this is what this sentence says.

22             While this was being chanted, one can hear the running commentary

23     of someone:

24             "The irregulars were celebrating in the streets that they had

25     fought for and singing a tribal song against the Croats."

Page 17329

 1             This is what the video P58 states.

 2             In addition, in light of the fact that we have not been sitting

 3     in the courtroom over the previous days, we shall sitting today and

 4     tomorrow morning and then again next week on Tuesday, the 20th of March,

 5     at a quarter past 2.00 and, if necessary, if we haven't finished -- we

 6     could finish on the 20th of March.  If necessary, we shall sit on

 7     Wednesday, the 21st of March at 9.00.

 8             So much for our schedule.

 9             As I have said what I needed to say, Mr. Seselj, I shall give you

10     the floor for your closing arguments.

11             THE ACCUSED: [Microphone not activated]

12             THE INTERPRETER:  Microphone for the accused.

13             THE ACCUSED: [Microphone not activated]

14             [Interpretation] Shall I start?

15             JUDGE ANTONETTI: [Interpretation] Yes, please go ahead.

16             THE ACCUSED: [Interpretation] For the whole of three days we were

17     listening to a heap of stupid sentences and words uttered by the

18     Prosecution.  In their final argument they wanted to complete their dirty

19     task, a task which did not arise from a normal perception of looking at

20     justice and serving justice.  Rather, that was a task that arose from an

21     order of the Western intelligence services that command this Tribunal.

22             This Tribunal is not legal.  It is not regular either.  This

23     Tribunal was set up by the Security Council of the United Nations which

24     does not have any competence over this Tribunal.  This Tribunal was not

25     set up in order to achieve justice, in order to preserve justice and to

Page 17330

 1     protect justice.  This Tribunal was set up in order to be a tool in the

 2     hands of the Security Council, and that organ of the United Nations uses

 3     that tool in order to establish and preserve peace.

 4             We know from the outset that there can be no word about justice

 5     here.  This is a political instrument, even a military instrument.  This

 6     Tribunal replaces the American Cavalry, the American Sixth Fleet.

 7     Instead of sending their Sixth Fleet to catch us all in Serbia and take

 8     us all to Guantanamo and try us before their military commissions, the

 9     United States of America had previously assisted the setting up of a

10     Quisling regime after the 5th of October 2005 -- 2000.

11             THE INTERPRETER:  The interpreter's correction.

12             THE ACCUSED: [Interpretation] And then that regime started

13     arrested the military, political leaders because of their participation

14     in war and because of the fact that they tried to counter and resist the

15     American dominance.  They did not have to prosecute me in that way.

16             I expressed my wish on several occasions to appear here.  I had

17     tried for ten years to reach The Hague Tribunal.  That was my life

18     desire, and I'm very satisfied with what I have achieved here.  What will

19     remain here behind me here are the transcripts from the trial.  These are

20     not going to be your personal perceptions of the proceedings.  This will

21     not be your judgement.  Someday people will probably laugh at your

22     judgement and they will laugh even more at the indictment and the closing

23     argument of the Prosecutor.  What remains is the transcript of the

24     proceedings, this wonder of all wonders that has been taking place in

25     this courtroom, and because of that, it was worth living.  This was what

Page 17331

 1     was worth living for.

 2             And obviously, although I wanted to appear here, it was not my

 3     desire that prevailed.  What prevailed was the will of political factors.

 4     Carla del Ponte in her book openly admits that Zoran Djindjic had told

 5     her on the occasion of their last encounter, "Take Seselj with you and do

 6     not send him back."

 7             Djindjic had had previous meetings with Carla del Ponte as well

 8     as the other politicians of the pro-Western traitor regime in Belgrade,

 9     and it was not only Djindjic that wanted me eliminated from the Serbian

10     political life; many others requested that.  But Djindjic's request was

11     the most remarkable one and that's why Carla del Ponte dealt with it in a

12     very remarkable way in her book.

13             Florence Hartmann, the former porte-parole for Carla del Ponte,

14     in her own book explains to what extent the Western intelligence services

15     are involved in the work of this Tribunal.  She highlights the American

16     and British intelligence services in her book, and they indeed are

17     involved.  We knew that even before her book appeared, and when the book

18     did appear, then it became blatantly obvious.

19             The fact that the indictment was issued against me over

20     nine years ago was motivated by the attempts for me to be eliminated from

21     the Serbian political life forever.  In the meantime, the

22     Serbian Radical Party should have been either destroyed or kidnapped.

23     That kidnapping should have taken the place in the following way.  It

24     would not be the same party ever again.  It would serve the interests of

25     pro-Western forces in England, Germany, the United States, the entire

Page 17332

 1     European Union, the Vatican, all of which work against the Serbian

 2     interests, and it has been demonstrated that everything was geared in

 3     that direction.

 4             For the whole of four years there was a fight going on here for

 5     me to have the right to defend myself.  The idea was for a lawyer to be

 6     imposed on me, from England, from the Netherlands, or wherever, and they

 7     would have pretended that they were defending me, and with their help,

 8     the Prosecutor would have filled up the case file with the so-called

 9     exhibits, and the trial would not have taken a long time because both the

10     Defence counsel and the Prosecution would have been on the same side.

11             That's how the Prosecution envisaged to introduce all of their

12     papers, in the same way they did it in 2010.  When you Judges saw that

13     there was no evidence against me, then you started receiving all those

14     exhibits that you had previously turned down as exhibits.  For example,

15     Milan Babic's statement, all the documents accompanying his statement;

16     then Miroslav Deronjic's statement; and God knows who else.  There are

17     some protected names.  I don't want to make a mistake, I don't want to go

18     into private session, and I don't want you to subsequently intervene in

19     the recording.

20             This is the essence.  I had to risk my life in order to win my

21     elementary right.  Hermann Goering did not have those problems,

22     Rudolf Hess did not have those problems, not a single Hitler's leader had

23     such problems.  They had the right to defend themselves.  They had the

24     right to hire any lawyer under the sun.  Nobody told them that that

25     lawyer had to be from the list of the Tribunal, that they had to speak

Page 17333

 1     English and any such thing.  This Tribunal is even worse than the

 2     Nuremberg Tribunal because the Nuremberg Tribunal, although it was not an

 3     international Tribunal in the proper sense of the word, but a martial

 4     court of the victorious parties, and not even Yugoslavia could join that

 5     Tribunal, although it belonged to the victorious parties of the

 6     anti-Hitler coalition.

 7             If this -- if that had been a true international court, it would

 8     have had both sides on trial.  It would have tried Hitler's leaders for

 9     genocide against the Jews, for causing an aggression -- an aggressive

10     war, for crimes against humanity, the violation of the customs of law,

11     and so on and so forth, but it would have also tried the Americans and

12     the Brits for the bombing of Dresden, Cologne, and many other settled

13     areas all over Germany.  Civilians were wantonly killed on both sides,

14     and a similar international court would have tried Americans for throwing

15     atomic bombs on Hiroshima and Nagasaki.

16             In order to correct the mistake made by the Nuremberg Tribunal,

17     the Hague Tribunal charges 80 per cent of Serbs and puts them on trial

18     and 20 per cent of all others, including Croats, Muslims, Albanians,

19     Macedonians, and so on and so forth.

20             The Hague Tribunal wants to show itself as an objective

21     international factor, but it actually pin-points the main culprits in the

22     war in advance.  When it comes to the Serbs, only the highest leaders of

23     the military and police hierarchy are on trial.  When it comes to the

24     others, only the second-ranking or third-ranking people are put on trial.

25     And when it comes to sentences, the story is even more remarkable.  The

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 1     Serbs are tried to life at the drop of a hat, and the Muslims, for

 2     example, you engage in very heated discussions as to whether a Muslim

 3     general is going to get two years' or three years' sentence.  The first

 4     decision is two years and then the Appeals Chamber reduces that to

 5     one year, and this is the nature of this Tribunal.

 6             When I finally won the battle for the right to defend myself,

 7     another battle started, and that was for all the other trial

 8     preconditions to be met.  Because the Prosecution had not tried very hard

 9     to work on this case.  They thought that everything would finish very

10     soon, and when they were supposed to disclose the exculpatory material in

11     my own language, they couldn't do it because nothing had been done before

12     the beginning of trial.  The trial started without the Prosecution ever

13     having met all of their requirements and the names of protected witnesses

14     should have been published one month -- disclosed one month before the

15     beginning of trial.

16             Well, that's why you Judges made the decision not to start -- not

17     to start counting the trial as having started on the 7th of November but

18     as of some date in December when the first witness appeared.  In all the

19     official documents of the Tribunal, it is stated that my trial started on

20     the 7th of November, and for the sake of a very small procedural benefit,

21     you made the decision that the trial did not start with the opening

22     statement by the Prosecution but, rather, by the appearance of the first

23     witness.

24             As we have seen in a document that was published by WikiLeaks,

25     Western intelligence services are certainly very concerned with my trial.

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 1     At a meeting which was held in December 2006, which was attended by the

 2     American Under-Secretary of the Ministry of Defence Eric Edelman, a

 3     top-notch intelligence man, and there was also an envoy of defence, and

 4     Deputy Minister of Defence Daniel Fata, and also a political officer,

 5     they met on the 1st December in Champs-Élysées with MGM, their

 6     counter-part for security in France.  He accompanied Dominique Boche, the

 7     advisor of President Chirac for the Near East; Admiral Guillaud, the

 8     presidential advisor; and then advisor for strategic affairs, Laurent

 9     Bili.  I'm not sure whether I pronounced the family names properly.

10             Who is that famous or notorious MGM?  That's Maurice

11     Gourdault-Montagne, the key person in the French intelligence service, an

12     advisor of a war criminal, Jacques Chirac.  You know that Jacques Chirac

13     was sentenced to 20 years in Belgrade for war crimes.  That is a maximum

14     penalty that a Serbian Tribunal could pronounce for war crimes.

15             According to the minutes of the meeting and the report that was

16     submitted to Washington, this MGM says that they had to do everything in

17     their power to prevent my victory in the Serbian elections.  That was on

18     the 1st of December, 2006.  I was still on a hunger strike.  My hunger

19     strike went on until the 8th of December.  I was even convinced that they

20     would let me die on them.  And then an announcement appeared by the

21     Russian Ministry of Foreign Affairs, a very serious announcement, a very

22     serious communique, and things changed rapidly immediately after that and

23     all of my requests were expressly met.  I did not even write my own

24     submission about that.  The warden of the Detention Unit came and told me

25     that his service would write that in English.  According to that, there

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 1     would be no stand-by lawyer, no lawyer would be imposed on me, I was

 2     appointed legal counsel, my wife Jadranka all of a sudden could visit me,

 3     all of the materials had to be submitted to me in Serbian on paper, and I

 4     really don't remember what else I requested.

 5             That was in December 2006.

 6             Now, the proceedings began and my impression was that both the

 7     Trial Chamber and the OTP had hoped that in view of the interests of

 8     those main instigators of these proceedings, everything was going to end

 9     successfully.  However, the first OTP witness, Oberschall, is knocked out

10     in the courtroom.  The next witness, Theunens, an employee of the OTP is

11     also knocked out in the courtroom.  The third witness, Yves Tomic, is

12     also knocked out in the courtroom.  A number of key OTP witnesses did not

13     fair well at all in the courtroom.

14             Now, what happened next?  Next they resorted to stalling the

15     process.  By the end of 2007, the OTP could definitely have heard all the

16     witnesses.  However, there was a synchronised effort on the part of the

17     Trial Chamber and the OTP and it was postponed endlessly.  The OTP even

18     asked for Judge Harhoff to be disqualified because, back in Denmark, he

19     participated in the interrogation of a witness which made him partial.

20             Mr. Mandic then asked for an adjournment so that they wanted to

21     enter into negotiations with me.  They wanted me to agree to a bargain of

22     ten years in prison, but I said here in the courtroom there is nothing

23     that I have to discuss with the OTP.  I needn't remind you how all this

24     went sloppy all the way to 2008.

25             Once they realised that they cannot defeat me so easily in the

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 1     courtroom and when they realised that the popularity of the SRS in Serbia

 2     was skyrocketing, then the foreign Western intelligence services started

 3     breaking up my party from within.

 4             Another prominent French intelligence officer played a crucial

 5     role in that, alongside the US, the British, and the German intelligence

 6     officers.  We heard from some dispatches what they personally think about

 7     Tomislav Nikolic, that he had bought his university degree, but when they

 8     meet with him face-to-face they pat him on the shoulder, told him how

 9     good he was, and instructed him to get rid of Seselj and embark on a new

10     path.

11             As for Aleksandar Vucic, they might still count on him, but it

12     seems that they have completely eliminated Tomislav Nikolic.

13     Arnaud Danjean is the name of that French officer.  He is a member of the

14     European Parliament from the list of Nicholas Sarkozy, a war criminal.

15     Why is he a war criminal?  Because of the bombing of Libya.  Of course,

16     Danjean is one of the plain proteges of Stanko Subotic, aka Cane Zabac,

17     one of the biggest Mafia figures in Serbia.  He provides protection to

18     him in the hope that he could achieve some political points in Belgrade

19     because the incumbent regime, regardless of the fact that it is

20     pro-Western and that very often it accepts the requests of the West even

21     if they are contrary to the interests of Serbia, they are not ready to

22     give in completely.  So they are trying to balance this.  You don't want

23     to accept the independence of Kosovo, then Aleksandar Vucic and Tomislav

24     Nikolic will do that.  Now that is the game that is being played.

25             And of course, Danjean is infamously known for his dirty deals in

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 1     the Balkans.  He operated as a spy in Bosnia-Herzegovina, Croatia, Kosovo

 2     and Metohija, and Montenegro.  Then in 2002 he joined the French foreign

 3     ministry and for a time he was an advisor to Javier Solana.  Then in

 4     2005, as an intelligence officer, he became an advisor to the French

 5     foreign minister for Eastern Europe.

 6             And then in, I think, 2012 or 2011, he was elected an EMP.  It

 7     was widely covered in the newspapers, for example, "Vreme" of the 6th of

 8     August, 2009, claims that Danjean is a good friend of Milo Djukanovic.

 9     And you know who Milo Djukanovic is, he's a Mafia boss, a prominent Mafia

10     boss, and there are a number of core proceedings conducted against him in

11     Italy for cigarette smuggling and he is still trying to evade that by

12     invoking his presidential position.

13             It was Danjean who allowed and make it possible for Subotic to

14     move freely.  They organised a meeting between Nicholas Sarkozy --

15     Subotic, and according to "Vreme," he helped Tomislav Nikolic in his

16     breaking up the Serbian Radical Party while at the same time maintaining

17     close contacts with Cedomir Milanovic and Beba Popovic.  Danjean, in

18     1994, was the head of the French intelligence agency in Sarajevo and he

19     is directly involved in the investigation of the Srebrenica crime.

20     Petrusic and the commander of the 10th Sabotage Detachment are not tried

21     at all - and this is Mr. Pelemis - whilst, on the other hand, other

22     people who were not involved in that at all were on trial.

23             We can see that from books wrote about this topic a huge crime,

24     the killing of at least 5.000 Muslim men were to be killed and that would

25     constitute an excuse for bombing the Serbs.  Of course I'm not excusing

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 1     anyone on the Serbian side who took part in that crime, but the Serbs are

 2     the only ones who are held accountable and it was Arnaud Danjean who

 3     framed them.  He took part in the Rambouillet negotiations, then he was

 4     one of the chief advisors of Bernard Kouchner.  We all remember the

 5     criminal Bernard Kouchner and this spy organisation, Medecins Sans

 6     Frontieres.  He was the governor of Kosovo and Metohija, and finally he

 7     was the French foreign minister.

 8             So here we have another prominent French intelligence officer

 9     who, according to all the available information, is working against me

10     and the Serbian Radical Party.  As a deputy in the European Parliament,

11     he harshly attacked Dick Marty because of his report on the organised

12     crime in Kosovo and Metohija and the harvesting and implanting organs

13     from the detained Serbs all over the world.

14             Carla del Ponte herself started to investigate this, but she

15     complained that she had been thwarted in her efforts.  And for that,

16     Danjean really attacked him in harsh terms in the European Parliament.

17     He's also one of the main instigators of an attempted coup d'etat in the

18     Serbian Radical Party.  Although I have been in detention for so many

19     years, I am more competent than Montagne and Danjean, and eventually I

20     managed to prevent all their attempts.

21             Since the OTP case started in such a sloppy manner and since the

22     Western powers realised that they cannot expect favourable results of the

23     proceedings, they started attacking my health condition.  I used to be a

24     relatively healthy person.  I had suffered from asthma and some blood

25     pressure problems, but I managed to keep it under control by taking

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 1     proper medication.

 2             First, there was an attack on my liver.  As soon as I realised

 3     that, I started an outcry because I know that only if I am noisy, when

 4     you deal with Western powers, you can do something.  After that, my liver

 5     recovered itself with no assistance.  Then they moved to my heart.  They

 6     had been attacking my heart for the past three years.  It is still

 7     working and I hope it will work until I finish my closing argument.

 8             I don't know how they're achieving this, but their attempts are

 9     both ridiculous and abhorrent, especially those of the medical personnel

10     who attribute these problems to my obesity.  My blood vessels are in

11     excellent condition, just like a young man.  I was subjected to

12     coronarography.  I never had raised levels of sugar in my blood.  I never

13     had raised levels of cholesterol and triglyceride in my blood.  Now, what

14     is the cause of this?  Electricity, how is this electricity generated

15     that is damaging my heart?  It sounded to me as science fiction until the

16     night between 8th and 9th March.

17             Back in January I had the so-called ICD implanted and this

18     defibrillator was not operating properly; it was obvious from the start.

19     However, on the night between the 8th and 9 March of this year, this

20     defibrillator simply went berserk.  I had been feeling well before that,

21     but I woke up during the night.  I had watched a movie and at quarter

22     past 4.00 I felt the first electrical shock.  I took my own device and

23     measured my pulse rate, and it was almost normal, 75.  The defibrillator

24     is programmed to cause electrical shocks only if this rate exceeds 75,

25     which means that it should intervene in order to prevent death.  However,

Page 17341

 1     there was no need for it to be activated.

 2             Then at half past 4.00, another electrical shock came and then

 3     another and another.  Eventually I pressed the alarm button that stands

 4     next to my bed, but it was broken.  I stood up and pressed the alarm

 5     button next to the door - and there is such a button in every cell - but

 6     it was broken too.  Luckily, thanks to Mr. Antonetti's efforts, I managed

 7     to be given two adjoining cells.  I went to the other one, pressed the

 8     alarm, and it finally went off.  Those who switched off the first two

 9     alarms simply forgot about the third one.

10             The guards appeared.  Between 5.30 and 5.45 I had four electrical

11     shocks that were throwing me around the cell.  Do you know how that

12     feels?  That feels as if you are crossing the street where there's no

13     crossing and you get hit by a tram.  You manage to get up somehow and

14     then you're hit by another tram, and that was repeated six times.  The

15     last one was at 6.30.

16             The guards called the doctor who arrived after 40 minutes.  As

17     soon as he realised what was going on, he called an ambulance and I was

18     taken to Leiden.  I was wondering whether anyone was going to believe me

19     that these electrical shocks happened out of the blue.  When I arrived

20     there, they found this recorded in the memory of the defibrillator and

21     there was six of them.  A nurse arrived at 8.00 and she checked

22     everybody's ICD and she told me, "I realised immediately what the case

23     was with you and I would have called the ambulance right away."

24             Now, everyone is wondering how is it possible that this

25     defibrillator was broken and then I had to undergo another surgery.

Page 17342

 1     Initially they didn't have a free bed and they postponed me for the next

 2     Monday, but somehow they managed to find a slot in their schedule and it

 3     was conducted on the Friday.  I asked many doctors if they had ever heard

 4     of the ICD going berserk without any apparent reason and causing

 5     electrical shocks.  Each and every one of them told me they heard nothing

 6     ever of such an occurrence.  This was something that was caused

 7     externally.  That was an attempted murder.  I don't think there can be

 8     other explanation.

 9             Now, so much for the political background of this trial and the

10     intentions of their main creators.  They designed to kill me sometime

11     between the closing argument and the rendering of the judgement.  This

12     was one of their attempts, and I'm sure that they will not give up so

13     easily, particularly now when there is election campaign underway and the

14     results are showing in the polls that the Serbian Radical Party is in a

15     good position and that it will achieve good election results.

16             Let us now move to what the OTP stated in their closing argument.

17     I wanted to present to you some documents, some books, even some

18     video-clips; however, I decided not to do that because I don't have

19     proper conditions to work.  I have no assistants available.  So in my

20     closing argument, I am -- I shall be focusing only on what the

21     Prosecution said.  The rest is probably not interesting enough.

22             Prosecutor Marcussen began with a theory that exactly 20 years

23     ago, on the 5th of March, 1992, I gave my word that the Serbian Radical

24     Party was prepared to obstruct the independence of Bosnia-Herzegovina by

25     all possible means, and that if that independence happens, rivers of

Page 17343

 1     blood would flow.  In his eyes, that's a key thesis, the key proof that I

 2     wanted war crimes, that I designed them, and that I later instigated,

 3     planned, prepared them, even executed them myself.

 4             How was the independence in secession of Bosnia-Herzegovina

 5     possible if the Serbian people were not agreeing with it?  Both

 6     Bosnia-Herzegovina and Croatia - like all the federal units of the former

 7     Yugoslavia - had not been constituted in a democratic way.  The original

 8     Yugoslavia was a unitarian state.  It was created through an

 9     anti-constitutional act.  Sometime in 1939, the then-government agreed

10     with Croatia that a certain part of the territory would be formed into a

11     so-called Banovina.  That was done by the Prince Regent Karadjordjevic

12     and his head of government Dragisa Cvetkovic in agreement with the

13     Croatian leader Macek.  That was completely unconstitutional and it never

14     was ratified by the parliament.

15             In any case, that unitarian Yugoslavia, by the will of the

16     communists, during and after the Second World War, became a Federation.

17     And the communists decided on those federal units completely arbitrarily.

18     They decided there would be six of them.  They invented completely new

19     nations.  Okay, Macedonians, we can say Macedonians are very close to us

20     Serbs, similar, but they are not exactly the same thing.  But they

21     invented then the Montenegrin nation.  And then 20 years after the war,

22     they made up the Muslim nation.

23             Imagine, if you can, you in France have a lot of French Muslims.

24     Imagine if they said suddenly:  We are not French people anymore, we are

25     a separate Muslim nation?  Imagine the same happening in Italy or in

Page 17344

 1     Denmark?  You would find that funny.  You would find it laughable.  In

 2     Yugoslavia, it turned out to be tragic.

 3             The Croatian federal unit was constituted by the will of the

 4     communists without any democratic procedure.  However, the communists

 5     provided guarantees that that federal unit was - as they put it - the

 6     state of both the Croatian and the Serbian people living there.  Because

 7     when the military border and the Austro-Hungarian Empire was attached to

 8     Croatia and Slavonia in 1881, the Serbs received a guarantee that they

 9     would be a constituent people on an equal footing with the Croats.  What

10     did that mean?  That means that the Croats with their numerical strength

11     could never out-vote the Serbs on key constitutional issues concerning

12     status.  Croatia should never have been able to declare independence

13     without the agreement of the constituent Serbian representatives living

14     there.  In Bosnia and Herzegovina the situation was even clearer.  None

15     of those constituencies, none of the three, had an absolute majority.

16             Serbs had the majority before the war, before they suffered a

17     genocide; but after the war, no longer.  Bosnia-Herzegovina was

18     constituted as a federal unit comprising Serbs, Croats, and Muslims.  And

19     only with the agreement of all three could their status be changed, which

20     means that the Muslims and Croats could not have just out-voted Serbs,

21     but it happened.

22             And what kind of people would we Serbs be if we had not stood up

23     for our own rights?  We were honest enough to say in advance:  You have

24     no right to abolish the Serb people's status as a constituent people.  If

25     you do that, you will cause war.  There will be rivers of blood, and the

Page 17345

 1     rivers of blood happened, not because I am clairvoyant.  Any serious, any

 2     intelligent person could see that it was in the offing.  You want to go

 3     away?  We Serbs don't.  And what are you going to do now?  Out-vote us?

 4     You have no right to out-vote us.  Because when Bosnia and Herzegovina

 5     was constituted as a federal unit, we had received the guarantee that

 6     nobody could out-vote us.  When Croatia was constituted as a federal

 7     unit, we received the same guarantee, that we Serbs would not be

 8     out-voted concerning the statehood of Croatia.

 9             And suddenly, all bets were off because the European

10     Community - later European Union - said different.  The US said

11     different.  The international swindler Badinter would say different with

12     his infamous commission.  Well, no way.  The Serbs had to oppose that,

13     and when push came to shove, they had to take up arms, and this

14     resistance was successful.  The Serbs created the Republic of Serb

15     Krajina and Republika Srpska.  Because they said if you want to secede,

16     feel free to go, but without us, without our territories.

17             Now, when a war breaks out, it is natural that everybody, every

18     warring party, wants to occupy as much territory as possible.  That's how

19     things happen in a war.  You stop calculating, we go up to here where we

20     are 50 per cent and we don't go there where we are less than 50 per cent.

21     You take as much territory as you can and then you negotiate after the

22     war.  And that's when the Americans decided to destroy the Republic of

23     Serbian Krajina, to expel, to drive out the Serbs from its western parts,

24     that was all the Americans' doing.  The Croatians were just gophers in

25     all that.  The famous US agency IMRI, employing retired high-ranking

Page 17346

 1     US officers, collaborates directly with the US defence ministry.  They

 2     started by disabling the Serbian communications system, destroying the

 3     Serbian aviation, and from then on it was easy to destroy the Serbian

 4     Krajina.

 5             But it cannot last forever.  One day the Republic of Serbian

 6     Krajina will be free again.  And my role is to leave a legacy that it

 7     must be free again one day.

 8             As for Bosnia-Herzegovina, the Muslims were certainly the

 9     greatest victims, and we had given them fair warning that the West was

10     going to protect the Croats and would just use them as cannon fodder

11     against the Serbs.  However, the Muslims embarked on that war and that

12     war resulted in many victims on all sides, but probably the most amongst

13     the Muslims.

14             The fact that Bosnia and Herzegovina - as Mr. Marcussen put

15     it - proclaimed its independence, that was completely illegal.  And

16     that's why my threat was not really a threat but a warning.  And

17     unfortunately, it turned out to be very true.  The same warning turned

18     out to be accurate and fair in Croatia, too.

19             Now, for whom was it a horrible reality?  For the small, poor

20     people who found themselves in the wrong places and suffered, but they

21     suffered not because I had said that rivers of blood would flow.  It was

22     because of those who knew that rivers of blood would flow when they

23     proclaimed independence.  And when one Serb is in danger, all of us other

24     Serbs have a duty to help them.

25             Imagine, Mr. President, if the French people in Quebec were in

Page 17347

 1     danger, were in jeopardy.  All France would be up in arms.  They would

 2     not let it happen.  How could we Serbs be expected to stand by and watch

 3     if somebody's putting in jeopardy our brothers and sisters in Croatia?

 4     We could not sit on our hands.  We had to fight to protect them.  Now,

 5     how successful we were in that fight is another matter.

 6             And another problem that's very important here, in this process

 7     of the break-up of Yugoslavia, who started killing and expelling first?

 8     The moment Tudjman came into power, his regime started persecuting Serbs,

 9     dismissing them from work, forcing them to sign oaths of loyalty, to

10     request the so-called Domovnica, a new ID document that had not existed

11     before, to humiliate them in all manners.  The Serbs started running away

12     from larger Croatian cities like Zagreb and Varazdin and many other areas

13     of Croatia as early as 1990, from Split of course.  And the first

14     killings that happened were killings of Serbs.  Urban Serbs, townsfolk

15     who had never been involved in any sort of resistance, in any sort of

16     fighting.

17             Secondly, Tudjman immediately started to restore old Ustasha

18     symbols and iconography.  We knew about Tudjman, that he used to be one

19     of Tito's generals and then found connections with Ustasha emigres.  And

20     he even brought a leading Ustasha emigre, Gojko Susak, to become his

21     defence minister.  You've heard of Gojko Susak.  He was for many years

22     the Ustasha leader of the Croatian emigre circles.  Tudjman made it clear

23     that he was a supporter and a big fan of the Pavelic regime and

24     Maks Luburic, a leading Ustasha, after the killing of Ante Pavelic.  And

25     Ante Pavelic was killed by a Serb Chetnik.  In fact, that Serb actually

Page 17348

 1     only wounded him and then he succumbed to his wounds during treatment in

 2     Spain.

 3             And then Tudjman, who made no bones about his connection with the

 4     Ustasha emigre circles, his connections with the Roman Catholic church

 5     and especially with the Herzegovina priests, Franciscan priests based in

 6     Siroki Brijeg in Bosnia-Herzegovina, the hotbed of the Ustasha movement

 7     through hundreds of years.  A deputy takes the floor in the Croatian

 8     parliament, raises his arm in the fascist salute, and shouts, "Pro

 9     patria."

10             Don't you think that it's the ghost of the Ustasha beast revived?

11     And that's what I was warning about.  That's exactly what I said.  The

12     Ustasha beast is rearing its head again.  I was blamed for identifying

13     Croats with Ustashas.

14             It's true that at the first elections Tudjman did not get an

15     overwhelming majority; he got 48 per cent, but he still got into

16     government.  But later on he was vastly supported by a great majority of

17     his people until he finished all the dirty business that had to be done.

18     When that was done and when the Americans and the European Union gave

19     guarantees to Croatia that they would get to keep their territorial

20     integrity, things started turning against Tudjman.  He was no longer

21     useful.  He needed to be chased away.  However, his death put an end to

22     all that.  There occurred changes even in his party.

23             Sanader came into power, started a process of de-Tudjmanisation,

24     but then got stuck in all sorts of corruption scandals.  Tomislav Nikolic

25     gave an interview to some foreign magazine in 2008, a Danish magazine, I

Page 17349

 1     believe, when he said he wanted to become a Serbian Sanader.  I was here

 2     in the DU with Rasim Delic, the Bosnian general.  We were on good terms.

 3     We swapped books and newspapers.  He likes to read, as I do.  And he

 4     brought to me this Sarajevo Muslim magazine, where I read this interview

 5     given by Tomislav Nikolic.

 6             And that's when it became absolutely clear to me what his

 7     political role was and for whom he was actually working.  Tudjman showed

 8     exactly who he was once more in his book called "The Lawless Roads of

 9     Reality," or something like that.  In my own book, "The Roman Catholic

10     Criminal Project of the Artificial Croatian Nation," I quoted from

11     passages from that book.  And Tudjman openly advocates genocide in that

12     book and he refers to the Bible as his main support, the Old Testament,

13     quoting or showing how God destroyed entire nations, including women and

14     children, if they stood in the way of his beloved Isaiah.

15             Tudjman uses history as a tool that has to be used when it suits

16     you and then discarded.  Tudjman resolved the problem of Serbs in Croatia

17     in the same way.  If there were 12 per cent of them in Croatia before the

18     war, he wanted to reduce them to 5 per cent, believing that they would

19     then have no major collective rights, they could be reduced to the status

20     of a national minority.

21             Therefore, in my words, in my speeches, in 1990 and 1991, there

22     was no exaggeration at all.  I presented the truth and I issued warnings.

23             However, there's something else that really makes me laugh here

24     and I must say that you, Judges, in your decision pursuant to Rule 98

25     bis, and Mr. Antonetti in his separate opinion, have provided the

Page 17350

 1     background for the Prosecution to behave the way they did.  You referred

 2     to my speeches in your decisions, my speeches from the period that is --

 3     are beyond the scope of the indictment.  Those that I delivered in 1990,

 4     1991, and then after 1993.  Or you referred to the speeches that were not

 5     even mentioned in the indictment.  There are only three of my speeches

 6     that are referred to in the indictment.  The invented, the made-up speech

 7     in Vukovar; the made-up speech in Zvornik; and the speech in Hrtkovci,

 8     that was not made-up fully but you had it before you in its entirety.

 9     And all of a sudden you referred to some other speeches.  I'm really

10     astounded, you -- you, Mr. Antonetti, you are famous in France as an

11     excellent lawyer.  Jacques Verges really commended you whole-heartedly.

12     How could you even think that some charge that is not even mentioned in

13     the indictment can appear subsequently all of a sudden out of the blue?

14     If some idiot had concluded in a previous decision issued here - in

15     Rwanda or in The Hague - that some speeches could subsequently be

16     mentioned and form the basis for a judgement, this is ridiculous.

17             You cannot issue a judgement based on anything that is not

18     mentioned in the indictment.  All the charges have to be clearly

19     presented in the indictment.  The act -- the criminal act -- every

20     criminal act has to be explained fully in the indictment because I have

21     to know what I'm defending myself against.  I tried to defend myself

22     against two made-up speeches and one real speech, and now all of a sudden

23     you are mentioning some other speeches.  But you have to write a new

24     indictment.  You have to organise a new trial, but you can't do that.

25             What you did in 2010, 2011, and 2012, and you inserted into the

Page 17351

 1     case file things that were not there before, that's useless.  I've not

 2     read any of those things to this very day because I simply have not had

 3     the time.  You mentioned a heap of documents there, those documents that

 4     have never been even mentioned in the courtroom.  A document can be bar

 5     tabled without a witness appearing viva voce, but that document has to be

 6     mentioned in the courtroom.  It has to be said explicitly:  This is the

 7     document where it said so and so, and then I have the right to answer

 8     that the document doesn't prove this or that, but rather, represent this

 9     or that.

10             This is how students in the first year of law school are

11     explained the essence of the law, but here in The Hague Tribunal anything

12     goes and you're used to it.  Whatever comes to anybody's minds,

13     everything goes, everything can be done.

14             One more thing that is very important and it has to be said in

15     the introduction to my closing argument is your referring to Nahimana

16     case.  You never provided me with that judgement.  I had to finance

17     myself its translation into Serbian.  In the Nahimana case there were

18     three accused - I believe that there were three accused - and they were

19     charged with a public and direct instigation and call to genocide.  It is

20     only with genocide pursuant to the convention on genocide even public

21     appearance and calling people to genocide is punishable, although no

22     genocide was ever attempted.

23             For example, you may say I am inviting you to destroy this or

24     that ethnic, racial, or religious group.  This is already punishable

25     pursuant to the convention on genocide.  However, this applies only to

Page 17352

 1     the crime of genocide as a crime above all crimes.  This cannot apply to

 2     either the Geneva Conventions or the violations of the customs of war.

 3     This cannot apply to crimes against humanity.  In all the other forms of

 4     instigation, instigation has to largely contribute to the execution of

 5     crime.  Instigation does not have to be an irreplaceable factor of the

 6     crime.  Maybe the crime would have happened without any instigation.

 7     However, if there had been instigation, then that instigation has to be

 8     substantial contribution to the execution of the crime itself.  And here,

 9     the Prosecution refers to my speech given in the centre of Belgrade and

10     links it to a crime that happened in Kozluk or in some other village in

11     the municipality of Zvornik because they happened more or less at the

12     same time.  This could not be seen as instigation.

13             What other stupid things were done by the Judges in the appeals

14     judgement in the Nahimana case?  They sentenced to very long imprisonment

15     because of direct and public call to genocide, and they say in the

16     judgement because of the same actions, this was not only a call to

17     genocide but it was also a call to extermination.  Hold on, what is a

18     difference in principle between genocide and extermination?  The number

19     of people?  Everything else the two crimes have in common, there's no

20     difference.

21             If something has been proclaimed genocide, you cannot proclaim it

22     some other crime at the same time.  For example, you have murder as a

23     form of persecution or you can say this is persecution per se.  If

24     somebody is condemned and -- for genocide, then that's enough.  There

25     could be no other crimes involved with that.  For example, somebody kills

Page 17353

 1     a man with a knife, gives him three blows with a knife, and one blow just

 2     scratches his arm, the other blow is in the stomach, and the third blow

 3     is in the heart.  What crime is that?  What crime are we talking about?

 4     This is the crime of murder, of homicide.  What kind of a homicide or

 5     murder this is?  It's a different story, whether it's just a homicide, a

 6     murder, a killing, a manslaughter.

 7             Now, imagine a Trial Chamber that would say this is a murder and

 8     also a serious bodily harm and also a slight bodily harm all at the same

 9     time.  Now, such a Trial Chamber would be the laughing stock of the

10     entire world, and if Nahimana with his associates was charged and

11     convicted of genocide and instigation to genocide, this is enough.  You

12     don't have to try him for anything else.  However, unfortunately this

13     Tribunal and the Tribunal for Rwanda, which have one and the same Appeals

14     Chamber, there are a lot of illiterate and uneducated people among the

15     Judges, among the Prosecutors, so anything goes.

16             Maybe my problem is the fact that I have read almost all the

17     sentences issued here in The Hague and two or three more issued by the

18     Tribunal in Rwanda, that I am not afraid of the lawyers whose main

19     concern is not to be in the good book of the Registry because they are

20     expecting favours from them.  I am going to say everything.  I'm going to

21     hit you where it hurts the most.  I'm not even remotely interested in

22     your judgement.  I have told you that already a hundred times.  Whatever

23     you give me, whatever sentence you give me, it will mean life for me, a

24     life sentence.  So why should I care about your judgement?  Why should I

25     care about your final sentence?

Page 17354

 1             The OTP, topsy-turvy, presents its thesis, elaborates certain

 2     crime locations and crime bases, and at the outset Mr. Marcussen started

 3     with Zvornik.  I'm not going into all the details of what he said.  There

 4     had been a lot of words about that when particular witnesses appeared in

 5     the courtroom here.  I have to repeat only the most important things.

 6             The volunteers of the Serbian Radical Party participated in the

 7     liberation of Zvornik.  Why do I say "liberation"?  Because previously

 8     Zvornik had been occupied by the Muslim paramilitary forces armed to the

 9     tooth, and they also distributed weapons to the Territorial Defence and

10     the local police stations.  Among those Muslims, there was a large number

11     of well-known criminals from Zvornik.  They were the first ones who took

12     Zvornik, and the Serbs had to flee the town and they did not take any of

13     their assets with them.  They simply took their children in their arms.

14     They fled across the Drina to the other side of the Drina River in order

15     to save themselves.  And then what happened was a Serbian counter-attack.

16     And I'm very proud that the volunteers of the Serbian Radical Party

17     participated in that counter-assault.

18             The counter-assault was carried out by the JNA under the command

19     of the Operative Group Drina that was at Vucevo, and the most serious

20     force among them was the tank brigade that had arrived from Jastrebarsko,

21     near Zagreb, under the command of Colonel Tacic.  The JNA did not have

22     enough troops.  The Territorial Defence was mobilised in the area of

23     Zvornik.  The Territorial Defence was also mobilised on the right bank of

24     the Drina in Serbia, Loznica, Mali Zvornik, and some other adjacent

25     municipalities and the reserve forces of the police were mobilised.  They

Page 17355

 1     were joined by a unit of some hundred members of the Serbian Radical

 2     Party under the command of the judge from Loznica, Dragan Cvetinovic.

 3             There were other members of the Serbian Radical Party that

 4     participated in the fighting, but not as members of the volunteers.  They

 5     had gone there of their own will.  They were from Mali Zvornik, they were

 6     radicals who testified here, and some of them had been mobilised directly

 7     by the JNA.  One of them was Zoran Subotic who served as the commander of

 8     the Territorial Defence in the liberated Zvornik for a while.

 9             That unit participated in fighting until the moment Kula Grad

10     fell.  Until the 26th of April when Kula Grad fell, Seseljevci were there

11     and there is official proof of that.  Dragan Cvetinovic then came back

12     with his unit and continued working as a judge in Loznica.  A year later

13     I bestowed upon him the title of the Serbian Chetnik Vojvoda to credit

14     him for his services during the liberation of Zvornik.

15             There may have been some individuals who stayed on of his own

16     will.  Perhaps Slavkovic was a member of that.  Later on he was tried in

17     Belgrade.  He probably stayed on of his own will.  After the 26th of

18     April, completely new units were set up there.  Igor Markovic was the

19     first one.  Then later on Yellow Wasps.  Then Pivarski set up his own

20     unit, it had no more than ten men and it was linked to the police.  Then

21     Niski had his own unit and in his statement he said himself that he was

22     an Arkan's man.  Gogic was also an Arkan's man.  Gogic may have been in

23     Cvetinovic's unit after the 26th of April.  However, Cvetinovic was no

24     longer there, after that day he was never there.

25             At one moment I was prone to start thinking that Miroslav

Page 17356

 1     Vukovic, Cele, was a commander there, but then I saw his statement.  He

 2     had argued with Ljubisa Petkovic and he had not gone with the volunteers.

 3     He went of his own will to provide security for a factory there.  And

 4     then, together with me, he was in Podgorica when he was assassinated,

 5     when 62 of us were wounded there, and he was one of those -- he wasn't

 6     assassinated, he was wounded.  He was the most -- one of those who were

 7     the most seriously wounded.  He still has shrapnel in the lower parts of

 8     his leg and the stomach.  And after the 25th of May, there was no chance

 9     that he could be in Zvornik.

10             You mentioned that there was some somebody called Celo who was

11     also called Vojvoda and you say that he was Celo -- Cele is one thing,

12     Celo is another thing.  Nobody identified that Celo of yours as

13     Miroslav Vukovic.  The witnesses themselves told you that he sported the

14     kind of slippers worn by elderly women, they're called "Zepe."  The

15     entire Serbian population is familiar with this type of woollen slippers

16     usually worn by elderly women.  They are worn -- sometimes they are worn

17     indoors, sometimes outside.  Some elderly women even wear them into town.

18     And all of a sudden you say that Celo was a Chetnik Vojvoda and -- can

19     you imagine a Chetnik Vojvoda wearing those woollen slippers called

20     "Zepe," a Chetnik Vojvoda in Zepe?  Nobody was a Chetnik Vojvoda before

21     me, before May 1993.

22             You say that you have proven beyond reasonable doubt all the

23     crimes charged in the indictment.  You did not because they were never

24     seriously contested.  I did not have an opportunity to deal with that.  I

25     didn't have an opportunity to discuss whether crimes happened or not.

Page 17357

 1     The Trial Chamber has denied me the right to finance my defence.  The

 2     assistance that I had was very limited and very restricted, so I really

 3     could not deal with that at all.  I could do it to the extent which the

 4     OTP has some -- wittingly or unwittingly or sometimes by mistake has

 5     provided me with a certain quantity of documents, to see whether things

 6     did happen, how they happened, if I could.

 7             Arkan was in Zvornik.  We have clarified that.  First of all, we

 8     had a witness who stated that Arkan was paid to participate in the

 9     liberation of Zvornik and that that was done by Biljana Plavsic.  He came

10     with 20 or 30 men and he had started from Karakaj.  He had some

11     casualties.  His wrists were slapped.  And then he had to give up.  And

12     it was only in the afternoon that the JNA actually launched the attack

13     together with the volunteers of the Serbian Radical Party.

14             The crimes that happened in Zvornik were ascribed Arkan, the

15     crimes that happened before the 26th of April.  There is no single piece

16     of indicia that a volunteer of the Serbian Radical Party committed a

17     crime.  The JNA sent its pathologist from the military medical academy to

18     carry out preliminary investigation after the crimes.  You had an expert

19     here, Zoran Stankovic, who described that for us.  The JNA wanted to

20     process those crimes; however, under the ultimatum, on the 19th of May,

21     it had to withdraw from Bosnia-Herzegovina.  That's why the crimes were

22     never processed.

23             And who can you ascribe that to, the fact that the crimes were

24     never prosecuted?  You wanted to ascribe it to me.  You say according to

25     the third category of the JCE, according to that category you, yourself,

Page 17358

 1     can be prosecuted, the OTP, the Judges, you can all be prosecuted for my

 2     attempted murder, for example.  You willingly agreed, for example, to

 3     take part in a JCE, whose aim is to remove me from the political life of

 4     Serbia.  However, you believe that that could be done through court

 5     proceedings without shedding blood and that you can achieve the best

 6     possible results.  However, some of the members of your JCE - notably the

 7     American, the British, and the French intelligence services - tried to

 8     assassinate me on the night between the 8th and 9th of March.  They might

 9     have been successful in that, but you didn't know that they were planning

10     this murder, but you knew them and you could have predicted that -- the

11     killing of me by these services could only have been a logical

12     assumption.  And that is why you can be included into the category 3 of

13     JCE.

14             I like to describe things in the most absurd manner because only

15     in that manner can things become crystal clear.  It is my fault that

16     Arkan committed crimes.  So I started with Zvornik simply due to the fact

17     that Mr. Marcussen started with Zvornik.  However, I would have preferred

18     to start with Vukovar.

19             Am I right that we're going to take a break very soon?  Okay.

20     I'll say a few words about Zvornik and then I'll move to Vukovar after

21     the break.

22             Crimes were committed in Zvornik towards the end of May and in

23     June, but there was chaos in Zvornik, utter lawlessness.  At one point,

24     the Yellow Wasps arrested Brano Grujic, the president of the

25     municipality, and dragged him through town.  On the 15th of May, the

Page 17359

 1     Muslims attacked a JNA column which resulted in the death of about

 2     150 soldiers.  This is what the newspaper said.  The killing of these

 3     soldiers caused the eruption of hatred on the Serbian side and especially

 4     after an influx of refugees came, Serb refugees, came to Zvornik because

 5     they had no place to go.  And there was no need for any harsh words to be

 6     exchanged or harsh looks.  The very fact that so many people came there,

 7     people expelled from their homes, was a disconcerting fact for the

 8     Muslims.  So many of them left for Tuzla, those who didn't want to fight,

 9     some of them went to Hungary, and there was a witness here who testified

10     to that and I heard that he died the other day.

11             So as I said, they decided to flee rather than fight and they

12     went abroad.  Now, this left Zvornik without any authorities.  There was

13     no one who could control the situation.  Now, who's to blame for that,

14     that you have anarchy all of a sudden?  And this is a good breeding

15     ground for crimes.  Some of them were really monstrous and pathological.

16             You often suggest to the witnesses only after the fact that

17     Seseljevci took part in those crimes, but we have statements that Muslims

18     and injured parties gave to the Muslim authorities in which there is no

19     mention of either Seselj or his party.  You included Seselj's name in the

20     statements that you wrote yourselves because all the statements submitted

21     here by the OTP are the statements not written by the witnesses.  They

22     were written by the OTP and they were fashioned to suit their needs and,

23     more often than not, the witnesses didn't know what they were signing at

24     all.  Even if you speak about persons who have only basic

25     education -- and sometimes those with university degrees are unable to

Page 17360

 1     understand what you have inserted.  It might look quite benign but then

 2     after they sign it, it turns out to be something else.

 3             So you try to attribute to me the events in Zvornik.  Not a

 4     single volunteer of the Serbian Radical Party prior to the 26th of April

 5     was either suspected of or indicted.  If Slavkovic remained there with

 6     the volunteers, it's his problem.  I couldn't be his keeper or nanny.  If

 7     another member of the Radical Party became a volunteer and gathered a

 8     small group from Ruma and went on the front line, do you expect me to

 9     think about his whereabouts or what he was doing?  I never heard of him

10     being in Zvornik at all until I saw that in the documents disclosed to

11     me.

12             And, most importantly - and I'm going to finish with this - it

13     was you who provided me with a pile of original documents that speak

14     about the structure of the Serbian armed forces in Zvornik after 26th of

15     April until the end of June or beginning of July.  I have lists of all

16     these soldiers and policemen, and there is no indication to say that

17     those were members of Seseljevci or Radical Party.  Each and every unit

18     has its name there, but there is no name of Seseljevci.  You admitted or

19     you tendered into evidence these lists.

20             Now, what am I supposed to do?  Do I have to ponder whether each

21     and every individual there did something or not?  I can't do that.  And

22     you are even ridiculing the fact that when Zuco's group was arrested,

23     that I condemned that at a press conference in Belgrade.  You said that

24     my intention was to distance myself from me [as interpreted], and you

25     also provided a lie that I arranged for Zuco to be transferred to

Page 17361

 1     Skelani.  I never went to Skelani, but in that place we had quite a few

 2     volunteers of the SRS because that was the road that led to Srebrenica.

 3             You also referred to an election rally held on the 28th of May in

 4     Belgrade when I said that we still have to mop-up the left bank of Drina

 5     and to open a corridor towards Banja Luka.

 6             Now, what does the term "mopping-up" in military terms mean?

 7     What does it mean in our speeches?  It never implied that Muslims should

 8     be cleansed.  They had another three strongholds in that area and my idea

 9     was to mop-up these three strongholds so that they cannot jeopardise the

10     dams on the Drina, particularly the Crveni Mulj Drina, the destruction of

11     which would have been disastrous.

12             Srebrenica and Zepa and Gorazde, had they been liberated

13     immediately, we wouldn't have had all these ordeals with the

14     international community and there wouldn't be any need to declare them

15     safe haven.  And all those who failed to listen to me, it turns out that

16     they were in the wrong.  I can only regret that I didn't hold such a

17     position of power in which I could have forced them to listen to me.

18     This is my sole regret.  And if they had been forced to heed my warnings,

19     many things would have been avoided and the Serbs would not have been

20     defeated in such a --

21             JUDGE ANTONETTI: [Interpretation] We shall have a 20-minute break

22     and resume in 20 minutes' time.

23                           --- Recess taken at 3.46 p.m.

24                           --- On resuming at 4.14 p.m.

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

Page 17362

 1     We broke for a little longer because the doctor told us that we needed to

 2     have 30-minute breaks every hour and a quarter.  So we complied with his

 3     instructions.  So we had a break that lasted 30 minutes, but now you can

 4     resume, Mr. Seselj.

 5             You may proceed.

 6             THE ACCUSED: [Interpretation] I announced that I'm going now to

 7     speak about the issue of Vukovar.  In all this abundance of submissions

 8     and counter submissions and statements and counter statements, the OTP

 9     insists that I was the leader of the Serbian Chetnik Movement, the

10     Serbian Radical Party, and that I introduced myself as such.  Here it has

11     been proven that there were at least two stages of sending SRS volunteers

12     to the front lines.

13             The first stages took place before the JNA became involved in the

14     armed conflict.  Ergo, that was the stage when we were sending SRS

15     volunteers to protect the Serbian villages in Slavonia.  And indeed, I

16     was the commander at that time.  There was no one above me.  We had to do

17     that in secrecy, hiding from the Belgrade regime, and we already

18     explained how our volunteers were issued with weapons with the assistance

19     of General Dusan Pekic, a legendary commander from the Second World War

20     and who was also in the Federal Association of Veterans and he had quite

21     a strong influence in the Main Staff.  There was also General

22     Radojica Nenezic and a number of other retired generals and officers.

23     Although they were all retired, they were able to contribute to

24     organisation and efforts to procure weapons.

25             Now, in order to conceal the real source of the weapons, we tried

Page 17363

 1     to mislead them.  Once we said - I said in public - that we received the

 2     weapons via Hungary, which caused havoc there and there was a major

 3     investigation.  My idea was to wreak havoc there and let the Hungarians

 4     deal with it.

 5             We also got hold of the weapons written off by the JNA and that

 6     had to be demolished.  Those were Second World War US Thompsons, M-48

 7     rifles, Russian automatic rifles Spagin from the Second World War, and

 8     automatic rifles M-56.  Those were mainly the weapons that we managed to

 9     procure for our volunteers.  And it is nonsense to mention any other

10     sources such as MUP.  It is a real treat for me if I could manage to

11     cause harm to the MUP and the DB, but they didn't have those weapons.  It

12     was the JNA who took over the weapons from the TO depots and was

13     intending to destroy it.  However, General Pekic managed to deliver those

14     weapons to me.  I know that these weapons feature as written-off stocks

15     in their books.

16             In the indictment there is no charge relating to the crimes in

17     Slavonia.  So what do you want now?  That was before the 1st of August

18     and after the 1st of August, and you had an opportunity to see the

19     circular letter instructing all the volunteer groups to withdraw the

20     groups that were deployed in the Serbian villages because, in September,

21     we already agreed to have our volunteers integrated into the JNA and that

22     it would be the JNA who would deploy them wherever it was necessary.  And

23     that is the truth.

24             The OTP, however, says that volunteers of the Serbian Radical

25     Party in Borovo Selo killed about 12 Croatian policemen on the

Page 17364

 1     2nd of May.  We killed them?  No.  We defeated them.  I personally sent

 2     our volunteers to Borovo Selo at the request of Vukasin Soskocanin, the

 3     commander of the Borovo Selo TO, because they thought that they were too

 4     exposed to Croatian attacks and that they needed assistance to defend

 5     themselves.  The volunteers were billeted at the culture centre in the

 6     centre of Borovo Selo.

 7             What followed were negotiations with the Croatian authorities,

 8     the cessation of hostilities was agreed, and it was agreed to remove all

 9     the roadblocks.  The Serbs removed all the roadblocks, and on the 2nd of

10     May the volunteers were quite simply without their weapons in their

11     hands.  Some of them were still asleep, and at that point, busloads of

12     Croatian regular and reserve policemen came to Borovo Selo.  As soon as

13     they alighted from the buses, they opened fire.  And the first victim of

14     that clash was a Serb, not a Croat.  His name was Vojislav Milic.  He was

15     killed while he was sitting on the stairs of the cultural centre unarmed.

16             Now, what a coincidence.  He was not a volunteer of the Serbian

17     Radical Party.  He was a member of the Dusan Silni unit -- volunteer unit

18     that had been formed by the Serbian National Renewal.  He was the only

19     one at the time, although Mirko Jovic used to say that he had 700 of his

20     men in Borovo Selo.  This is rubbish.  There were volunteers from the

21     Serbian Radical Party, and as soon as they heard shots, they grabbed

22     their weapons and returned fire and were victorious.

23             The population of Borovo Selo were out working the land.  I think

24     that was the sowing season because it was the 2nd of May.  And as soon as

25     they heard the shots, they ran trying to get hold of their weapons.  And

Page 17365

 1     that is how the Croats were defeated, and after that they pleaded with

 2     the JNA to come and to rescue them from the encirclement.  An armoured

 3     unit of the JNA came and took them out of Borovo Selo, and as soon as

 4     that happened, the Serbs stopped shooting.

 5             According to our records, more than 12 Croatian policemen were

 6     killed; however, later on we found out that those were Kurdish

 7     mercenaries and that the Croats never registered them as war losses.

 8     They just buried them in an unknown location without reporting this to

 9     anyone.  At Ovcara there were also seven Kurdish mercenaries and I

10     presume that they were never identified.  You could hear that when this

11     Croatian expert - what was his name? - I don't know testified here.  He

12     confirmed that there were seven victims that were never identified.  Yes,

13     his name was Davor Strinovic.

14             So we achieved a great victory in Borovo Selo and it makes us

15     proud to this day.

16             Our volunteers did not attack a Croatian village.  They did not

17     kill Croats there.  Instead, our volunteers defended a Serbian village,

18     and in the course of the fighting - and I underline in the course of

19     fighting - they killed 12 Croatian police officers.

20             Serbs did not attack Croatian villages at that time anyway.  They

21     were only concerned about defending their own villages.  They did not

22     recognise the departure of Croatia from Yugoslavia.  They did not

23     recognise the Croatian move to strip them of the status of a constituent

24     people, and they didn't want to see the Ustasha regime chequered flag

25     becoming an emblem on the police uniforms.  They didn't want to agree to

Page 17366

 1     that.  So now what?  It turns out the Serbs are the criminals simply

 2     because they were defending themselves.

 3             When we made an agreement with the JNA, when the JNA joined in

 4     the fighting - and that is the start of the indictment period, from the

 5     1st of August onwards - you can throw down the drain all the charges

 6     before the 1st of August.  Anything before the 1st of August cannot come

 7     under the indictment and you cannot make a judgement on the basis of

 8     that.

 9             You can draw your own conclusions, of course, how bad a person I

10     am.  You may believe that I am the worst person in the world or one of

11     the worst.  What do I care?  God forbid that you should praise me or have

12     a good opinion of me.  That would be a problem.

13             As early as 1984 I was convicted to eight years in prison for the

14     same ideas.  I wanted the artificial Muslim nation abolished.  I wanted

15     the artificial Montenegrin nation abolished.  I wanted the number of

16     federal units in Yugoslavia reduced.  And I demanded that the personality

17     cult of the communist dictator Tito be toppled.  That was the gist of my

18     manuscript that was seized from me as a manuscript, and for that I

19     received a sentence of eight years' imprisonment.  Do you think that that

20     could turn me?  The prison in Zenica was much harder than this one in

21     Scheveningen and it still could not shake my views and beliefs.

22             There is continuity in that as well.  You in the Trial Chamber

23     and the Prosecution, when you look in my earlier speeches for a basis for

24     your charges, why don't you look in 1984, when I was fighting the

25     communist regime?  You can even start before 1981, when I was some sort

Page 17367

 1     of local semi-dissident.  That is my life path.  It follows a certain

 2     course, and your judgement cannot put a stop to it, and I'm proud of it.

 3     If I were to be born again, I would take that path once more.

 4             So when we made this agreement with the JNA that we should send

 5     volunteers to their units or TO units that were integrated into the

 6     JNA -- because wherever JNA was involved in the fighting, it took over

 7     command over the entire Territorial Defence.  That's how the laws worked

 8     at the time.  We honoured our civic duty.  We were not creating a joint

 9     criminal enterprise to stop Croatia and Bosnia and Herzegovina from

10     seceding.  Instead, the Croatian authorities and the Muslim authorities

11     of Bosnia and Herzegovina entered a joint criminal enterprise to tear

12     away those two federal units from Yugoslavia, knowing full well that that

13     would lead to armed conflict, to a civil war, and that there is nothing

14     bloodier than a civil war, that civilians are the first victims of civil

15     wars.  They knew that it would lead to all of the rest that happened.  I

16     knew it.  I warned about it.  I threatened.  I begged.  I pleaded.

17             You can look at a wide range of my efforts for that purpose.  At

18     a large rally in Banja Luka in November 1991, during a two-hour speech,

19     two-hour speech, I never ceased warning Muslims that they should not go

20     into conflict with Serbs, that they should not try to secede and tear

21     away Bosnia and Herzegovina, and I tried to give them a graphic depiction

22     of what would happen in case of conflict.  And so what?  Is it my fault

23     that it really happened, that I warned that that would be the outcome?

24     Am I to blame that I called upon Serbs to resist?  I'm proud of that, but

25     in your eyes I am to blame because it's your countries who bombed the

Page 17368

 1     Serbs and the Serbian people.  We were not able to respond then, but

 2     maybe one day we will.  And we will remember what you did to us in 1995

 3     and 1999 and we'll pay you back.  It's not impossible.  Anything is

 4     possible in history.  But we will never forget it.

 5             In Slavonia, we continued to have a large number of volunteers,

 6     not only in the Operation Group South.  The indictment covers only the

 7     area of the Operation Group South, whose cornerstone was the armoured

 8     motorised brigade.  We had several volunteer group also in the

 9     Operation Group North and their backbone was the Novi Sad Corps.  We had

10     a volunteer group on the Trebinje road, in Tenja, and in a few other

11     places.

12             THE INTERPRETER:  Trpinja road, interpreter's correction.

13             THE ACCUSED: [Interpretation] The indictment covers only the area

14     of the Operation Group South, but you keep stressing that we had

15     volunteers here and there.

16             In September, October, November Arkan did not have any training

17     centre in Erdut.  Erdut housed a training centre for the

18     Territorial Defence on the Slavonia, Baranja, and Western Srem.

19     Radovan Stojicic, Badza, controlled that, the one who later became the

20     police minister in Serbia.  He had been sent to Slavonia at the time and

21     he was appointed commander of the Territorial Defence there.

22             The JNA had everything to do with the appointments of

23     TO commanders, and Radovan Stojicic, Badza, was under the command of the

24     Novi Sad Corps of the JNA.  The first commander of that corps was

25     General Bratic during the war.  Bratic was killed in the fighting.  He

Page 17369

 1     was hit by a Croatian grenade and then he was replaced by General

 2     Andrija Biorcevic.  Andrija Biorcevic died several years ago so I can

 3     state his name in public.

 4             My principle is when you can harm somebody or denounce them to

 5     the current authorities in Serbia, better not mention their name, either

 6     when it concerns people who deserve a lot of credit or people who are

 7     responsible for wrong-doing.

 8             I was in Erdut at the time and Radovan Stojicic, Badza, received

 9     me very nicely.  We had several volunteer groups that came to his centre

10     to be trained, but not through Arkan's units.  Arkan took over Erdut only

11     when the JNA withdrew from the Republic of Serbian Krajina.  It was then

12     that he built his base in Erdut, got involved in business, opened petrol

13     stations, made vineyards and wineries, God knows what else he did.  You

14     could not find a single crime that the volunteers of the Serbian Radical

15     Party committed in the area of the Novi Sad Corps, that is to say, the

16     Operation Group South.  And you are trying something now with the area of

17     the Operation Group South, having found nothing in the area of the

18     Operation Group North.

19             On the 1st of October, the state of immediate threat of war was

20     proclaimed.  That state implied certain obligations for all players in

21     the political system, both organisations and individuals.  According to

22     the laws of the SFRY that were taken over and that were still in legal

23     force, every social and political organisation had its own place in the

24     defence of the country.  And it was the constitutional obligation of all

25     organisations and citizens to fight with all possible means to preserve

Page 17370

 1     the territorial integrity and unity of Yugoslavia.  We did not take part

 2     in the fighting to preserve that integrity, not because I wanted to

 3     preserve that integrity.  I personally believe that the creation of

 4     Yugoslavia was a mistake that brought us only misfortune.  But I was

 5     aware that the constellation of international forces was not to our

 6     advantage at the time and it was only through fighting for preserving

 7     Yugoslavia that we could preserve our interests.  That was the only

 8     political lever we could use.  And that's why we started sending

 9     volunteers to join the Guards Brigade.

10             When the Guards Brigade came to Vukovar, it found there three TO

11     units.  One was the unit commanded by Stanko Vujanovic.  It had suffered

12     huge losses in some fights and was decimated.  The unit that remained was

13     commanded by Vujovic and the unit of Leva Supoderica was just in the

14     process of being established and Milan Lancuzanin, Kameni, was proclaimed

15     its commander.  You called him "Vojvoda."  He was not Vojvoda at the

16     time.  He was given the title of Vojvoda in 1993.  And I first met him

17     sometime in October 1991, when I came to Vukovar to visit the

18     Operation Group South.  I had never seen him before.  And he was not a

19     member of the Serbian Radical Party.  During the war he was one of the

20     founders of the Serbian Chetnik Movement in Vukovar, together with

21     Slobodan Katic.  Then after the war he joined the Serbian Radical Party

22     too.

23             The staff of the Motorised Guards Brigade decided that the

24     volunteers of the SRS should join the Leva Supoderica unit, which at one

25     point had 400 or even 500 men, I couldn't tell now.  The bulk of the

Page 17371

 1     volunteers were from the Serbian Radical Party, but not all of them,

 2     however hard you are trying to portray it that way.

 3             Somebody who carried -- who wore the five-pointed star on their

 4     cap throughout the war could not possibly be a volunteer of the

 5     Serbian Radical Party; that's impossible.  I, as the first openly

 6     self-declared anti-communist dissident, even before Djilas, who never

 7     declared himself as such, I was the first one, how could I allow that

 8     somebody wearing a five-pointed red star on their cap join the volunteers

 9     of the Serbian Radical Party?  And such a star was always worn, for

10     instance, by Predrag Milojevic, Kinez.  But after the war, Kinez

11     denounced it and stopped wearing it, and then he joined our party.

12             You also said a certain Topola was a member of the Leva

13     Supoderica unit.  And the first Prosecution witness, Goran Stoparic --

14     remember, he was coached by Natasa Kandic herself.  He lived in her

15     apartment while he was preparing to testify in this case and in some

16     other cases, and then he was given residence in one Western country,

17     given a job.  You rewarded him generously for his testimony.  However,

18     you didn't treat everyone so well, so you fared badly with some other

19     Prosecution witnesses and they turned against you.

20             Goran Stoparic confirmed here that Topola was a member of that

21     unit, that he was undisciplined, and that Kameni had expelled him from

22     the unit, after which he wandered around Vukovar under nobody's control.

23     There was also a witness number 051, who claimed that Topola was already

24     a Vojvoda when he was in Vukovar.  And he made up some sort of conflict

25     between them.  Topola was going around killing people and number 51 was

Page 17372

 1     trying to stop him.  And then when we showed this false witness, 51,

 2     Topola's photograph, he confirmed his identity, whereas Topola was

 3     wearing a military police uniform with a five-pointed star on his cap.

 4     How could he be a Vojvoda in a military police uniform wearing a

 5     five-pointed star?  How absurd.

 6             When I was in Vukovar for the first time I was received by

 7     General Mrksic, who was a colonel then.  I stopped by his headquarters in

 8     Negoslavci first and then I went to the front lines and returned to

 9     Negoslavci in the evening, where Mrksic treated me to a military dinner.

10     There was General Colonel Panic there and a group of guards officers.  We

11     had beans and sausage, the army way.  Don't think that it was some sort

12     of roast lamb or something.  We stayed until the small hours, and then I

13     returned to Belgrade.

14             The second time I was in Vukovar was on the 8th of November,

15     perhaps a few days earlier or later, it doesn't matter.  It could have

16     been the 8th November.  I did not stop to see Mrksic at all on that

17     occasion.  I only toured the front lines.  I spent several nights on the

18     front lines.  I spent the night in the house of Milan Lancuzanin, Kameni,

19     and during that night, a Croatian aircraft dropped a full boiler of

20     explosives on that house.  It missed.  This boiler fell into the yard and

21     exploded.  I was accompanied by Misa Bijanic [phoen], president of some

22     Serbian organisation from Kosovo.  He walked around the rest of the

23     night.  He couldn't sleep anymore.  I just turned over and continued

24     sleeping.  I took a shower, naked to my waist, in the yard the next

25     morning, and I was photographed doing that by Tomislav Peternek, a

Page 17373

 1     well-known photographer.  That photograph was published in the Yugoslav

 2     magazine "Nin."

 3             So I was in the front lines all the time.  But you first made up

 4     that I had a meeting with officers at the house of Stanko Vujanovic and

 5     then you brought a false witness, number 027, to confirm that.  From his

 6     memory, but mainly based on his notebook, he confirmed I was at that

 7     meeting and that I said that, among other things, not a single Ustasha

 8     could leave Vukovar alive, which constituted an instruction to kill all

 9     Ustashas.  However, that meeting did not happen.  And it was obvious that

10     this false witness had used a different pen to add the passage containing

11     that statement of mine.  On whose instructions?  General Vasiljevic's, of

12     course.  That false witness was disqualified in the Mrksic et al. case.

13     They found him unreliable.  However, here he was found reliable.

14             The Mrksic, Sljivancanin, and Radic judgement does not know

15     anything about such a meeting where I instructed the officers of the

16     Guards Brigade to kill prisoners under the pretext that it was the

17     Ustasha who were being killed.  Let's put that aside.  Let's put aside

18     the fact that I really couldn't say anything nice about the Ustasha.  I

19     really would like to see all the Ustasha dead.  And perhaps somewhere in

20     Belgrade or somewhere in Zajecar or somewhere in Leskovac or in Vranje I

21     indeed did state something to that effect, but I never held a meeting in

22     Vukovar.

23             And when that fell through, then you presented two or three

24     witnesses who spoke about rallies on the streets of Vukovar, where I

25     allegedly said that no single Ustasha should leave Vukovar alive.  How

Page 17374

 1     can anybody hold a rally in Vukovar under the constant barrage of

 2     Croatian artillery fire from Mitnica and Nustar.  Mitnica is one part of

 3     Vukovar which was the main stronghold of the Ustasha forces and Nustar is

 4     a village a little bit outside of Vukovar close to Vinkovac where the

 5     Croatian artillery was stationed, and from there they opened fire from

 6     cannons and howitzers.  And all of a sudden that's -- there's me holding

 7     rallies under artillery fire.  How can the OTP be so stupid?

 8             What does this mean, rallies under artillery fire?  No group

 9     could have more than five men in it when we were touring front lines, and

10     I did tour all the front lines.  On one front line I even opened fire

11     from an automatic rifle towards the Croatian positions.  I don't know if

12     I hit somebody.  I wish I had, but you can't see that in a real war

13     situation.

14             And now when it comes to the crimes in Velepromet, those crimes

15     can have absolutely nothing to do with either the Serbian Radical Party

16     or the Leva Supoderica unit because Velepromet was held by the military

17     police.  That was a collection centre for detainees.  There was also an

18     arms and ammunition depot there.  Our volunteers had nothing whatsoever

19     to do with that.  I don't even know whether any crimes happened there

20     because the statements of various witnesses are very contradicting in

21     that respect.

22             A crime that certainly and surely happened was the crime at

23     Ovcara.  You, as the OTP, instead of shedding light on that crime, all

24     that time you tried to put as much of it under the carpet, and that's

25     your additional problem.  You falsely represented the organisers and the

Page 17375

 1     perpetrators of that crime.

 2             First of all, when did that crime happen?  Vukovar fell on the

 3     18th of November, and the crime happened during the night between the

 4     12th and the 13th of November -- between the 20th and the 21st of

 5     November.  Hence, three days after the fall of Vukovar.  A large number

 6     of the volunteers had already gone back.  You have heard many bus drivers

 7     who drove them back, and the Leva Supoderica unit had been reduced to

 8     less than 40 members, mostly locals, Stoparic was there, Slobodan Katic

 9     who got married in Vukovar and became the Chetnik commander of the

10     village, that's the title they gave him.  Marko Ljuboja also stayed

11     behind and a few others.  However, Leva Supoderica at the moment when

12     Mrksic issued an order about its re-assignment, it had less than

13     40 combatants, and your witnesses said that in the courtroom.  This is

14     not my thesis.  I heard that from them, the first time here in this

15     courtroom.

16             What happened in liberated Vukovar?  First of all, the military

17     security service got hold of a large amount of money from the Vukovar

18     bank, most of it in hard currency, and that money was handed over to

19     General Aleksandar Vasiljevic.  Aleksandar Vasiljevic was in Vukovar in

20     the evening on the 20th of November, and he stayed there almost the

21     entire night together with Lieutenant-Colonel Tumanov, who later became a

22     general, and at that time he was his deputy.  They had brought Colonel

23     Bogdan Vujic, Colonel Tomic and Colonel Kijanovic with them.  We're

24     talking about three people who had already been retired for a long time.

25     They had been reactivated, they had been re-called from retirement

Page 17376

 1     without any papers.  They put on uniforms.  They took pistols and they

 2     set out in the direction of Vukovar and their task was to do the triage

 3     of detainees.  Why would they have done the triage there?  Up to then the

 4     triage of all the detainees was carried out in Sremska Mitrovica.  A part

 5     of that prison had been turned into a prisoner of war camp.  They had

 6     actually arrived in order to carry out the execution of the detainees

 7     pursuant to an order by Aleksandar Vasiljevic.

 8             On the 20th, in the evening, nobody from the JNA had entered the

 9     Vukovar Hospital.  It had been encircled.  There were several armed

10     Croats in the hospital.  There was some wounded and some of those who

11     pretended to be wounded.  And then Vesna Bosanac arrived at the command

12     in Negoslavci.  And together with the security officers, they -- she

13     carried out the triage because she knew exactly who the people in the

14     hospital were.  A triage was carried out in order to select the 200 who

15     would be executed.

16             Who had Aleksandar Vasiljevic talked to in order to carry out the

17     execution?  I'm sure that he had discussed that with a Croatian

18     intelligence service because after the crime in Gospic, Croats needed a

19     major crime against their population in order to speed up the process

20     leading to the recognition of Croatia.

21             The selection was carried out.  207 detainees were brought to

22     Ovcara.  When the lists had been double-checked, what was noticed was a

23     surplus of seven, and they were liberated, among them Cakalic, Berghofer,

24     Vilim Karlovic, and some others.  Exactly 200 were executed, a very

25     precise figure, and the officers were there all the time.  And you are

Page 17377

 1     trying to attribute that crime to Goran Hadzic.

 2             I was in conflict with Goran Hadzic for over ten years.  I spoke

 3     badly about him.  It was only when he appeared here, in The Hague, our

 4     relations have improved and now they're fair.  They have been -- they

 5     were fair until the moment when the Detention Unit forbade us to contact

 6     each other because the Prosecution was afraid that I would spill the

 7     beans before Goran Hadzic about the operation in Vukovar.  Because the

 8     JNA is claiming all the time that they had handed over the detainees to

 9     the civilian authorities, but that is a fabrication.  The civilian

10     authorities had never taken over the detainees.  They did request that at

11     the session of the government at Velepromet.  That meeting took place in

12     the morning on the 20th of November.  They wanted to try them in Vukovar.

13     That's why they wanted the detainees to be handed over to them.  At that

14     meeting of the government among the present were Bogdan Vujic, the

15     then-Lieutenant-Colonel Panic, who then became general.  There was Arkan

16     as well and God knows who else.

17             However, that hand-over was never implemented.

18             And now the Registry issued an order to Goran Hadzic's Defence

19     counsel to warn his client not to contact me, and nobody ever told me

20     anything about that.  Previously I had had a ban on contacting Milosevic

21     for a year.  That was during the -- my initial time there.  And then the

22     ban was lifted and I was moved to the same floor as Milosevic.  They

23     probably expected that we would quarrel and that they would benefit from

24     that, and just the opposite happened.  Milosevic and I became friends

25     here.

Page 17378

 1             There was also a ban on contacts with Karadzic, that was a

 2     written ban.  And when I raised an outcry here in the courtroom, that was

 3     abolished.

 4             I was never officially informed there was a ban on my contacts

 5     with Goran Hadzic, until the moment when my legal advisors arrived

 6     sometime at the end of February.  We were put in a visitors' room.

 7     Goran Hadzic was in the big room with his family.  I wanted to say hello

 8     to him and his family members.  The guards prevented me from doing that,

 9     and then me and my legal advisors were kept under lock the whole day and

10     we had to press a special button if we wanted to go to the toilet or if

11     we wanted to go to the vending machine to buy some refreshments or

12     something for that -- or something like that.  And it was only then that

13     I learned my contacts with Goran Hadzic had been restricted.

14             You want to try Goran Hadzic.  You want to say that his

15     government had taken over the prisoners and executed them although he had

16     nothing whatsoever to do with that.  You want to protect Aleksandar

17     Vasiljevic.

18             You say that Seseljevci participated in the execution.  You're

19     lying.  In Belgrade there was a trial against some real perpetrators and

20     some fabricated perpetrators of crimes at Ovcara.  Milan Lancuzanin,

21     Kameni, Kameni; Ceca, whose name I can't remember at the moment.  I was

22     not in a position to prepare all that because I have not been able to do

23     much since the beginning of December, even watching television sometimes

24     is hard.  But I'm not complaining.  That's what you wanted.  You wanted

25     me to have no defence.

Page 17379

 1             Marko Ljuboja and Slobodan Katic were also on trial.

 2     Slobodan Katic and Marko Ljuboja as volunteers of this SRS were

 3     immediately set free.  Kameni and Ceca were sentenced that 20 years.

 4     However, at the repeated trials, all the charges for murders were dropped

 5     and therefore they were sentenced to five or six years on account of

 6     having ill-treated prisoners of war.

 7             And Kinez was sentenced to 20 years.  Yet again he had sported a

 8     five-pointed star and then he became a member of the Serbian Radical

 9     Party.  I don't want you to think that I'm giving up on him.  He was a

10     fantastic fighter.  I was bothered by his five-pointed star during the

11     war.  He was sentenced to 20 years because a false witness - who had

12     participated in a crime, who had admitted he had participated in a crime,

13     who also appeared in this case - he claimed that Kinez was standing on

14     the brink of the pit and that he was there to fire from the Magnum

15     pistol, to shoot in the heads of those who were not dead.

16             Davor Strinovic demonstrated here in this courtroom that not a

17     single casing or a bullet from Magnum was found on the crime scene.  They

18     did the identification, a very correct one, in order to establish what

19     arms were used.  Predrag Milojevic, Kinez, is still in prison as a result

20     of false testimonies by false witnesses who were never punished.  One of

21     them is even receiving monies from the budgetary funds for that.

22             There you have it.  This is your justice these -- this is the

23     result of your pressures put to bear on the current regime in Serbia.

24             Aleksandar Vasiljevic never messed a hair from his head.  And

25     now, Judges, I'm sure you will remember how many times I already

Page 17380

 1     explained all that in the courtroom when I examined various witnesses.

 2     If you don't remember, never mind, it's neither here nor there.

 3             On the 20th of February this year, 20 days ago, that is, I

 4     received from the OTP a confirmation under number 670 about the

 5     disclosure of documents pursuant to Rule 68(i).  They submitted

 6     information from the Croatian sources about those people who were the

 7     main culprits for crimes at Ovcara, at the top of that pyramid for

 8     massacre at Ovcara.  And they put Aleksandar Vasiljevic on the top of

 9     that pyramid.  And the Croats say that on the -- they say that on the

10     9th of November he came to Negoslavci, the triage was carried out between

11     the 20th and the 21st of November, and in -- in The Hague and he -- in

12     Belgrade he testified as a Prosecution witness for Ovcara.  Under two,

13     they say that Bogdan Vujovic, Vasiljevic's friend, he was reactivated

14     from retirement in September 1991.  He was an experienced

15     counter-intelligence officer.  He arrived with the first one on the same

16     day from Belgrade.  They mention several other lower-ranking officers.

17             They know everything.  They know about the role of Vesna Bosanac.

18     She marched through the courtroom here and you never allowed me to

19     examine her because she was a 92 bis witness and I don't examine

20     witnesses like that.  I testified -- I examined only viva voce witnesses

21     because testimony based on OTP statements cannot be admitted anywhere

22     else in the civilised world.  It can only be admitted here, in The Hague

23     Tribunal, and only proves that this is not a regular Tribunal.  The whole

24     world acknowledges only viva voce testimony and not testimony through

25     statements prepared by the Prosecution.

Page 17381

 1             Now, the Prosecution alleges that at -- this meeting with

 2     security officers was attended by the then-Major Veselin Sljivancanin.

 3     There was no meeting in the house of Stanko Vujanovic, there was no

 4     officer present there.  I did meet Sljivancanin in Vukovar, but we

 5     couldn't stand each other, not even here in the Detention Unit.  To this

 6     day, he is a fan of Tito and he declares himself a Montenegrin.  And in

 7     my eyes, the greatest treason in the history is the forming of the

 8     Montenegrin nation.

 9             In 1991 my memories about the 4th of May were still fresh and the

10     meeting that the SRS held in Belgrade and we called a meeting, "Assault

11     on the House of Flowers."  This is where Tito was buried, and those fools

12     from the DB thought that we were really going to make this assault.

13     Veselin Sljivancanin himself installed machine-gun nests around his

14     grave, lest we should attack it.  Listen, we regularly informed the

15     police about this meeting.  We told them how many people were going to

16     attend.  We organised all the medical help, the water tank, et cetera,

17     whilst, on the other hand, they put machine-gun nests plus installed

18     sharpshooters on the roofs of the surrounding buildings.

19             I couldn't forget any of this when I met Sljivancanin, but I did

20     shake his hand.  At the time, he was constantly in contact with the

21     Croatian leader Jastreb over his hand-held radio set.  So that was the

22     only contact that I had with Sljivancanin in Vukovar.  Of course, that

23     was not a good time for me to raise the issue of his defending Tito's

24     grave by putting machine-gun nests.  However, you claim that I held a

25     meeting with a group of officers and that I instructed them to execute

Page 17382

 1     the prisoners.  What nonsense.

 2             Once Vukovar was liberated, military authorities were the first

 3     to be set up because the government of Slavonia, Baranja, and

 4     Western Srem were not capable of doing that.  They were understaffed.

 5     They had organisational problems and a host of other problems as well.

 6     Colonel Vojinovic was appointed commander of Vukovar.  Before that, as

 7     commander of the 80th Motorised Brigade, Colonel Vojinovic was the town

 8     commander, which included three villages and Ovcara and an area in the

 9     vicinity.  Before the executions began, it was his police who guarded

10     Ovcara.  Once he pulled out his police officers, the executions

11     commenced.  They provided a list and they started shooting people.  A big

12     pit was dug out during the day.  They used an army excavator and that was

13     done on Vasiljevic's orders.

14             Now, instead of indicting Colonel Vojinovic as town commander for

15     these executions, you bring him here to this courtroom to testify against

16     me.  He couldn't place any blame at my door-step.  He tried to defend

17     himself in every possible way, and since he testified as 92 bis - and you

18     did that on purpose - you deprived me of an opportunity to cross-examine

19     him that would be devastating.  Imagine him coming here to testify

20     against me, who is still held responsible for Ovcara.

21             After the liberation of Vukovar, pathologist teams from Belgrade

22     arrived on the spot, and they exhumed bodies from several locations.

23     During the war, both the Croatian and the Serbian sides buried their dead

24     wherever it was convenient.  It was impossible to burn the bodies, as one

25     of your false witnesses claimed, that I had said that some seven dead

Page 17383

 1     Croats should be burned.  You know what stench exudes from burning

 2     bodies?  That would be something like a chemical warfare and I don't know

 3     who would be more in danger by that, whether it would be the Croats or

 4     the Serbs.

 5             So the people were buried in various places.  Sometimes the

 6     places were marked, sometimes not.  This team of pathologists conducted

 7     exhumations properly and they buried all the Croats and the Serbs at the

 8     Vukovar cemetery.  Those who they could not identify, they marked them

 9     with a number.  However, no one came even close to Ovcara.  Now it seems

10     that it was I who organised the executions in Ovcara, while

11     Colonel Vojinovic didn't even know about it.

12             Listen, all the officers knew about the shooting the next day.

13     Did anyone do anything to investigate this matter?  It was the officers

14     who took over the prisoners according to a list, and then all of a sudden

15     200 prisoners just disappeared.  They had a receipt for them but they're

16     just gone.

17             And now General Mrksic is the scapegoat here.  He testified as a

18     Defence witness in the trial against the Croatian General Ante Gotovina,

19     albeit under subpoena, but he did not want to testify in his own case.

20     Do you know why?  That is because before he surrendered himself to

21     The Hague he spent about a month in a summer residential house near

22     Belgrade, and security officers coached him every day for two or

23     three hours how to conduct himself here and the rest of the time he spent

24     hunting and having a good time.  And Mrksic kept silent here and he was

25     given a 20-year sentence.  He's now waiting for the mercy of this

Page 17384

 1     Tribunal to reduce his sentence by one-third.  And after that, he hopes

 2     to go home.

 3             He didn't dare utter a word.  You know why?  Because

 4     General Vasiljevic had threatened that he would kill his whole family if

 5     he would speak about what he knew about Ovcara, and that's why Mrksic

 6     kept quiet.

 7             You brought Vasiljevic here to give false testimony in various

 8     cases.  In this case you even attempted to tender into evidence a

 9     document that had no designation, no number, no date, no authorship, no

10     signature, no stamp.  And when I objected, the Trial Chamber rejected

11     this admission because I immediately recognised that it was a paper -- a

12     document written by General Vasiljevic, and then you admitted that that

13     was indeed compiled by Vasiljevic.

14             Well, you did it nicely, but the Serbian people have a saying

15     that says that all secrets were eventually be revealed.

16             Ergo, the role of the military security will eventually have to

17     be revealed and what the role of Vesna Bosanac was and some other people

18     as well.

19             Now, what was Vesna Bosanac doing on the night between the

20     18th and 19th November at the headquarters of the motorised brigade in

21     Negoslavci?  What was she doing meeting Vasiljevic, Sljivancanin, and the

22     others?  I won't mention that she had to sleep in the bed of the

23     then-Colonel Pavkovic who is now general.  Now, let me tell you once

24     again that Pavkovic was not there at the time, she just slept in his bed.

25             What was the purpose of her visit to Negoslavci at all?  Why

Page 17385

 1     didn't she stay at the hospital with her wounded and her patients?  Why

 2     didn't she wait for the authorities to come?  Why was everybody waiting

 3     for a whole three days to evacuate the sick and the wounded from the

 4     hospital?  Vukovar fell on the 18th.  Why waiting?  Well, that was done

 5     in order to properly organise a major crime that would be attributed to

 6     the Serbs.  The Serbian people have nothing to do with this crime.

 7             It was easy to find a few direct perpetrators.  It's never

 8     difficult.  It was done in Ovcara, it was done in Srebrenica.  You can

 9     always find someone who lost all members of his family, whose children

10     were killed, and who was ready to kill other people for revenge.  That's

11     not a problem at all, but you never wanted to establish who masterminded

12     that.  And even the Belgrade regime is reluctant to delve into that

13     matter.  Recently Snjezana Malovic, our minister of justice, told a high

14     official of the Serbian Radical Party the following, "You are absolutely

15     right about Aleksandar Vasiljevic, but we are not able to set things in

16     motion."

17             So you see what's happening.  General Vasiljevic's two daughters

18     are living in Canada.  He also wanted to emigrate to Canada but he hasn't

19     finished his business in Belgrade yet.  In other words, your daughters

20     are welcome, but your hands are too dirty, we cannot accept you, but we

21     are going to use you again.

22             Did we pass the time of one and a half hours?

23             JUDGE ANTONETTI: [Interpretation] Oh, I thought you still had

24     another 12 minutes.  We're going to work until 5.30 or would you rather

25     have a break now?

Page 17386

 1             THE ACCUSED: [Interpretation] I am a bit tired.  Maybe it's

 2     better if we took a break now and then in the next session I will speak

 3     more -- for more than an hour.

 4             JUDGE ANTONETTI: [Interpretation] We're going to have a break now

 5     for 30 minutes.

 6                           --- Recess taken at 5.19 p.m.

 7                           --- On resuming at 5.48 p.m.

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

 9             You may continue, Mr. Seselj.

10             THE ACCUSED: [Interpretation] When some of the locations pursuant

11     to a ruling of the Trial Chamber were removed from the indictment, the

12     Prosecution was given permission to present evidence relating to these

13     locations possibly within the context of JCE or state of mind.  However,

14     the Prosecution presented evidence relating to these locations only as

15     crime bases, but that was not permissible according to the

16     Trial Chamber's ruling.  And based on the evidence on crime bases, they

17     are subsequently trying to draw certain conclusions.  However, these

18     locations cannot confirm the existence of the JCE, nor can they confirm

19     that it constitutes a universal pattern of crimes perpetrated by Serbian

20     forces in various places.

21             Let's first look at Western Slavonia.  There was a spontaneous

22     uprising of the Serbian people in Slavonia against Tudjman's regime which

23     was prompted by the violation of the rights of Serbs because there were

24     threats.  The Serb people felt insecure.  There was an atmosphere of fear

25     and angst, et cetera.  This Serbian uprising had been in progress for

Page 17387

 1     more than two months before the first Serbian volunteers arrived there.

 2     The JNA didn't have enough troops to cover the whole area, and that was

 3     the reason why volunteers were being sent there.  The volunteers were

 4     dispatched from the JNA barracks in Bubanj Potok, already issued with

 5     uniforms and weapons.  They were transferred in convoys of buses and

 6     escorted by military police.  Volunteers of the SRS fought there bravely

 7     and there is not a single shred of evidence that any of them committed

 8     any crimes.

 9             The Prosecution brought false witnesses here, even witnesses who

10     were in power of the Serbian Autonomous District of Slavonia who tried to

11     clear their names because they remained living in various Croatian towns.

12     You had an opportunity to see how successfully I shattered those

13     witnesses and how I managed to establish a link between them and certain

14     crimes.  Since those were protected witnesses, I cannot mention their

15     names now, but hopefully you remember who they were.  And of course, I

16     don't remember their numbers because it is only stupid people who have no

17     problems memorising numbers.

18             The crimes occurred spontaneously after the defences fell down as

19     a result of a major Croatian offensive.  The crime in Vocin, as you saw,

20     was the crime whose perpetrators were identified by Croats themselves.

21     The OTP played a video-clip here in which we saw a Croatian officer

22     saying that this crime was committed by White Eagles, and upon that the

23     Prosecutor said those were Seseljevci.  How is that possible?

24             The Prosecutor says that I was in Benkovac and I explained to our

25     volunteers that our members were wearing helmets in Vukovar and instead

Page 17388

 1     of the five-pointed star they put stickers with white eagle images.  Now,

 2     the Prosecutor - either intentionally or out of ignorance - is mixing up

 3     white eagles and other emblems.

 4             A two-headed eagle is -- has been the symbol of Serbs ever since

 5     the Middle Ages.  It had been adopted from the Byzantine tradition.  And

 6     the two-headed eagle was worn on the Serbian uniforms in the

 7     19th century, during the First World War, and during the Second World War

 8     too.  That was the emblem worn by the royal army commanded by

 9     Drazen Mihailovic.  The two-headed white eagle is still on the coat of

10     arms of Serbia, it is on the official flag of Serbia.  Is that also part

11     of a paramilitary formation of the White Eagles?

12             I was explaining to our volunteers in Benkovac and other fighting

13     men -- you remember when I said I'm used to being listened to carefully,

14     to having others shut up when I speak.  The Prosecutor calls it a display

15     of authority, but what can I do about it?  From my earliest stage I've

16     always been a leader and in every group I've ever been into, I've been a

17     leader.  From childhood play with other children to later days.  But I

18     was explaining to our soldiers that it's necessary for them to wear

19     helmets.  Especially in Benkovac, Lika, and other areas, many soldiers

20     were killed or seriously wounded by explosions that detonated on the

21     rocks around them and then the rocks hit them in the head.  People were

22     reluctant, by the way, to wear helmets because the helmets had the

23     five-pointed star.  I told them to cover the star with the eagle sticker

24     and wear the helmet nevertheless.  Even I wore the helmet from the moment

25     when officers told me what this failure to wear helmets was doing to the

Page 17389

 1     soldiers.

 2             Now, the Prosecution is trying, based on that, to identify our

 3     volunteers with the group of White Eagles.  There were some elements

 4     together with our men in the liberation of Zvornik.  They had come from

 5     Kraljevo and they were with our volunteers until the fall of Kula Grad

 6     and then they dispersed.  From 26 July on in Zvornik, there was no unit

 7     called White Eagles.  Did I say Vukovar?  I have to check the record.

 8     No, it's fine, it's Zvornik.

 9             In Vocin, the Catholic church was blown up, but it exploded

10     because it housed a depot, a stock of ammunition.  It was vacant.

11     Somebody decided to store ammunition there.  And during the Croatian

12     offensive maybe somebody intentionally caused the explosion or the -- or

13     a stray grenade did.  I don't know.  Was it proper to store ammunition in

14     a place of worship is another matter.  But that is why the church

15     exploded.

16             The volunteers of the Serbian Radical Party were not there at

17     all.  They were mounting a blocking defence in a village called

18     Masicka Sagovina.  It had some tactical importance.  The SRS volunteers

19     made it possible to evacuate all the civilians from there thanks to their

20     defence.  11 SRS volunteers were killed there in a single day.  Some were

21     wounded, others were captured, and those who were captured, although they

22     had suffered a lot in Croatian prisons, were freed later and not a single

23     one of them was prosecuted or charged with any crime.

24             So there is no pattern of conduct from which you could conclude

25     that I sent volunteers somewhere to commit crimes, that I instigated,

Page 17390

 1     ordered, planned, or supported these crimes because there is absolutely

 2     no contact between the crimes and the volunteers.

 3             Now about Samac.  A group of soldiers came from the training

 4     centre in Bajdos -- in Pajzos.  They were sent there by the JNA.  There

 5     was a volunteer known as Debeli there and a part of our volunteers who

 6     had fought in Slavonia previously, but they did not go there, they did

 7     not arrive there as a volunteer unit of the Serbian Radical Party.  They

 8     came there as a JNA unit which was part of the 17th Tactical Group and

 9     they fought in Samac as such.

10             And nobody can ascribe a single crime to Srecko Radovanovic.

11     What is being attributed to Lugar is probably true.  Lugar has been dead

12     for a long time.  We can't examine him.  But at that time Lugar was not a

13     member of the Serbian Radical Party.  He became a member later, but he

14     was soon expelled sometime in 1993 because he had slapped the president

15     of the Municipal Board of the Serbian Radical Party in Kragujevac,

16     Jovo Savic.  And the entire city of Kragujevac knows that Jovo Savic was

17     the president of the Municipal Board of the SRS and that Lugar slapped

18     him and that's why he was expelled.  Do I care what you are going to say

19     about that, what you are going to think about that, or what some other

20     town in Serbia is going to think?  Kragujevac knows what happened.

21             Concerning Brcko, we didn't send any volunteers from Belgrade

22     there.  Mirko Blagojevic was there with the volunteers of the SRS from

23     Bijeljina after Bijeljina was liberated, and you cannot ascribe a single

24     crime to Mirko Blagojevic.  He even came to the POW camp, asked for a

25     certain number of prisoners to exchange them for some of his soldiers or

Page 17391

 1     dead soldiers.  And he got them against receipt.  And he brought biscuits

 2     and sweets to the detained Muslims.  Then later that evening somebody

 3     came and mistreated those Muslims and you decide that it was

 4     Mirko Blagojevic.  During the day he was distributing food and treats to

 5     them and the same night he came back to mistreat them.  Where is your

 6     logic?

 7             In the area of Brcko they did not have volunteers, but at the

 8     time the corridor was being opened there was Branislav Vakic and some

 9     others.  I can't remember all of them.  Their task was to open up the

10     corridor, to link the western part of the Republic of Serbian Krajina

11     with the western part of Republika Srpska with Serbia.  That corridor was

12     a life-line for the Serbian people.  The Army of Republika Srpska was

13     involved and the Army of the Republic of Serbian Krajina under the

14     command of Milan Martic, et cetera.

15             Bijeljina, the greatest number of absurd statements have been

16     heard on Bijeljina, and the Prosecution is making closing arguments as if

17     we had never heard all of that, as if all of his witnesses had not been

18     absolutely demolished here in the courtroom.  They keep saying that I was

19     sitting there in some cafe saying how all the Muslims need to be cleansed

20     from Bijeljina, whereas a Muslim was sitting at the table next door, next

21     to ours, overhearing all that.

22             Now, what must be the IQ of Mr. Marcussen if he can't make this

23     distinction?  I don't know what the difference between his IQ and mine

24     is.  Maybe it's in his favour.  How stupid do I have to be to sit with

25     Mirko Blagojevic in a cafe and discuss with him openly what we were going

Page 17392

 1     to do with the Muslims?  Such rubbish.

 2             And we established here based on Prosecution witnesses'

 3     testimony -- because you didn't allow me to present a single of my own

 4     witnesses, you violated Article 21 of the ICTY Statute and did not give

 5     me funds to present my defence.  So based on Prosecution witnesses we

 6     established how the war started in Bijeljina.  One Muslim on horseback

 7     was going to throw a hand-grenade on the cafe called Srbija.

 8     Mirko Blagojevic was standing outside that cafe, grabbed his pistol, and

 9     as the Muslim was about to throw the grenade, he shot him in the leg.

10     That Muslim was sitting here in the witness box, and all I wanted to know

11     about that was how the horse fared.  Thank God the horse was uninjured,

12     but that Muslim, in all this excitement, forgot to activate the grenade

13     before throwing it so it didn't explode, and that's when the shooting

14     started between the Serbian cafe called Srbija and the Muslim cafe, whose

15     name I forget, in the centre of Bijeljina.  And in this settlement of

16     accounts, the Serbs prevailed.

17             In the fighting itself, Arkan's role was negligible.  But in what

18     happened after the fighting, that's another matter.  In the Serbian

19     public, I attacked Arkan when no one else dared to because he had taken a

20     fire brigade vehicle from Bijeljina worth several hundred thousand

21     Deutschemark, perhaps 1 million tractors, and God knows how much more

22     equipment.  Nobody in Serbia dared lift a finger against Arkan, not the

23     government, not the police, no one, because he was involved with

24     underground structures, Mafia, he had the protection of Radovan Stojicic,

25     Badza.  Nobody dared anything against him.

Page 17393

 1             Muslims could have prevailed in Bijeljina, but in Bijeljina,

 2     apart from the few Muslims killed by Arkan when he came in, there was no

 3     expulsion of Muslims.  Muslims joined the unit of Mirko Blagojevic.

 4     Later on two battalions or two brigades were formed comprising Muslims,

 5     and they were deployed on the line facing Orasje, which is a Croatian

 6     settlement.

 7             The expulsion of Muslims was Mauzer's idea and the idea of that

 8     man of Arkan's, that major - what's his name? - and that's when we

 9     started a conflict with them.  The Prosecution showed this document by

10     Mirko Blagojevic condemning the mistreatment of Muslims.  The Prosecution

11     found that document.  I would not have been able to find it or it would

12     have taken me a lot of trouble.  So where is the common pattern of

13     conduct?  Where is the JCE?

14             The Prosecution is saying now that I'm distancing myself from

15     people in the SRS or the volunteers.  No, I'm not distancing myself.  I

16     am still proud of my own role in the war and of theirs, but I have to

17     clear certain facts up.  And the most important facts include where we

18     sent volunteers from Belgrade and where we did not.

19             You see how perfidious the Prosecution is when it comes to

20     Zvornik.  We had an old Muslim woman here in the courtroom whose husband

21     and two sons were killed by Arkan's men.  She came, she was very

22     emotional, and she had only great hatred for me.  You could see that.

23     However, she described the events very truthfully.  Arkan's men broke

24     into that settlement, took the men away, and executed about 20 Muslim

25     men.  And she describes nicely how they went from there to the centre of

Page 17394

 1     Zvornik, and how somewhere later on they were met by Seselj's men, how

 2     they took Arkan's men somewhere and tried to dissuade them.  Then they

 3     took the Muslims somewhere else and told them to calm down, that they

 4     would protect them, whereas one of them broke a shop window, took some

 5     chocolates, and distributed them to Muslim children.  And the Muslim

 6     woman then said, "Yes, he was telling us they were not all the same but

 7     how do we know that?"  I don't know how she's thinking.  That's another

 8     matter.  But I am proud of these details that speak volumes about the

 9     kind of people our volunteers were.

10             The Prosecution is also trying to insult me, saying that I'm a

11     quasi soldier, that I'm this and that.  This is a quasi Prosecution.

12     These are quasi prosecutors, whereas I am no quasi soldier.  I am a

13     soldier inasmuch as I have done my compulsory military service and from

14     the first day of war I placed myself at the service of my fatherland.

15     And I am still a soldier of my homeland in this courtroom, in The Hague,

16     a soldier of Serbia ready to die for my homeland, Serbia.

17             But you don't understand what that means.  You don't understand a

18     thing because you have a totally different system of values.  That system

19     of values is decadent.  That system of values is dehumanised, based on

20     pure individualism, whereas we Serbs have an individual and a collective

21     conscience and we jealously guard both.

22             Here the Prosecution speaks of Greater Serbia, and of course I am

23     fighting for Greater Serbia.  That is my personal aim and the aim of the

24     Serbian Radical Party, but it has never been the goal of

25     Slobodan Milosevic or Veljko Kadijevic or Blagoje Adzic or Borislav Jovic

Page 17395

 1     or Radovan Karadzic or Milan Babic or Milan Martic or Jovica Stanisic or

 2     Franko Simatovic.  Many of them are still crying for Yugoslavia, for the

 3     old Yugoslavia, and you cannot artificially portray it as our common

 4     design.  It's my design, the design of my party whose main founder and

 5     leader I am.

 6             And the Prosecution keeps insisting that we were fighting for a

 7     homogenous Greater Serbia, but there is no basis for that in any

 8     document.  When did any of us say that we wanted a homogenous

 9     Greater Serbia?  You invoke Stevan Moljevic.  Stevan Moljevic was not a

10     leader of the Ravna Gora movement.  He was a prominent personality but

11     his personal opinion placed no obligation on anyone.  Draza Mihailovic

12     fought for the restoration of Yugoslavia and he said that at the congress

13     of 1944.  Draza Mihailovic had Chetnik Vojvodas of both Orthodox and

14     Catholic faith.

15             The Catholic Vojvoda Bartulovic was executed by the Partizans

16     sometime towards the end of the war.  Near Split, Djuro Vilovic, from

17     Makarska, was convicted together with Mihailovic and spent time in

18     Sremska Mitrovica, a great author.  Mustafa Mulalic, a Muslim, tried

19     together with Draza Mihailovic.  Ismet Pupovac, so many Chetnik Vojvodas.

20             The Prosecution acts as if they had never seen in the documents

21     they included into evidence themselves the programme of the

22     Serbian Freedom Movement, the Serbian Chetnik Movement, the Serbian

23     Radical Party, that we are fighting for a unified Serbian state that

24     would include all Serbian lands and then we enumerate those Serbian

25     lands.  The current Serbia, Macedonia, Bosnia and Herzegovina - when I

Page 17396

 1     say "current Serbia," that means Kosovo and Metohija and Vojvodina -

 2     Bosnia and Herzegovina, Montenegro, Dubrovnik, Lika, Kordun, Banija,

 3     Slavonia, Baranja.  And we talk about the brotherhood and unity among

 4     Serb Orthodox people, Serb Catholic people, Serb Muslims, et cetera.  You

 5     admit that into evidence.  You tender it into evidence yourself, and then

 6     you go on talking nonsense.

 7             What homogenous Greater Serbia?  In addition to insisting on

 8     unity, regardless of faith and confession, we guarantee all the rights to

 9     everyone, even minorities.  But we also expect them to be loyal to the

10     state of Serbia.

11             You mentioned here my statements concerning Kosovo, and in his

12     dissenting opinion under Rule 98 bis, Judge Antonetti did as well.  Why

13     didn't you include it in the indictment?  What do they mean now if

14     they're not in the indictment?  Although they date back to the time

15     outside the consolidated amended indictment and they were made in

16     locations outside the indictment.  Who made that mistake?  Maybe it would

17     have been easier for you to make the judgement if you had included them.

18     What do you want to do now?  Re-write the indictment again?  It can't be

19     done, although anything goes here.

20             We Serbs will never give up on the liberation of Kosovo and

21     Metohija.  To us, it is sacred Serbian land.  We will never ever give up.

22             And all Albanians loyal to Serbia will be able to live in Kosovo,

23     and not only that, the entire northern Albania as it is today stretches

24     over Serbian land.  The first Serbian state covered the area of the

25     current northern Albania.  It is -- it was the Kingdom Caslav,

Page 17397

 1     Stefan Vojislav, Jovan Vladimir.  Do you think we will give up on that?

 2             The Serbs freed Skadar in the First Balkan War.  The Montenegrin

 3     Serbs tried first but they didn't make it.  Many of them died.  Then the

 4     Serbian troops came with artillery and Skadar fell.  And then the great

 5     powers forced us to pull back from Skadar and from the greater Albania.

 6     Great Western powers created Albania as it is today, that state will

 7     exist until those countries still have all the power.  When that stops,

 8     when they lose that power, things will go back to what they used to be.

 9             The first leader of Skadar was Esad Pasha, an Albanian but also

10     an Ottoman general.  And in that fighting more than 30.000 Serbs died,

11     most of them from Montenegro.  When the Serbian artillery arrived, when

12     they got involved, negotiations about the surrender of Skadar began and

13     it was agreed that the Ottoman army with all its infantry weaponry should

14     leave Skadar.  Only heavy artillery remained, if my memory serves me

15     well.  And when the Turks, including a large percentage of Albanians,

16     started leaving Skadar, the Serbs organised a gauntlet with military

17     music playing.  And they were sent off to military music.  That is

18     Serbian military honour.

19             Now, we had those communist dregs involved in this war and we

20     also had Serbs who had lost their sense of military honour and that's not

21     something we could be proud of.  Nevertheless, the fact remains that

22     others started to violate the rules and customs of war first, to commit

23     crimes against humanity first, that others were much more involved and

24     got away scot-free.

25             Which Muslims did you try here?  When you look at it, nobody.

Page 17398

 1     And where are the Serbs from Sarajevo?  Where are 200.000 Serbs from

 2     Sarajevo?  Who drove them out?  Do you think they just up and left their

 3     apartments and houses?  How many Serbs were killed in Kazani, in

 4     Pofalici, in many other places in Sarajevo?  Where are the Serbs from

 5     Tuzla?  Where are the Serbs from Zagreb?

 6             According to official statistics, there were 600.000 Serbs in the

 7     former federal unit of Croatia.  Where are they?  How many of them

 8     remain?  Who was held responsible among the Croats and Muslims for that?

 9     No one.  Yes, you came down hard on Bosnian Croats to some extent so that

10     they lose all their enthusiasm for the recreation of Croatian Bosnia.

11     That was your main goal.  But out of Croats, you tried only two men:

12     Gotovina and Markac.  It was the easiest way out for you and the

13     then-Croatian authorities to sacrifice those two.  Which Croatian

14     minister did you try?  Which high-ranking military commander was tried?

15     Not one.  Why not Tudjman?  Why not Alija Izetbegovic?

16             In the attack against the western part of Krajina in 1995,

17     11 Croatian commanders were involved.  They attacked from 11 different

18     directions, and you went after those two alone.  I'm not defending them.

19     I don't want to defend anyone, although I have my prisoner's solidarity

20     with all of them regardless of nation, be they from Congo, Rwanda,

21     Liberia, never mind.  I'm always on the side of the prisoner vis-a-vis

22     the Prosecution and the Judges.

23             But where is that justice that you are pursuing?  What kind of

24     justice are you pursuing?  You want to achieve reconciliation in the

25     Balkans with these trials?  There will be no reconciliation.  You put --

Page 17399

 1     you added fuel to the flames of those passions with the trials.  Do you

 2     think the Serb people will be reconciled to the fact that you are trying

 3     their highest military and police officials, whereas others go

 4     unpunished?  Never.  Never.  Reconciliation cannot be achieved in this

 5     way.  This is how you pour fuel on new animosity and new conflicts.  And

 6     the Pax Americana that came after this war will not last long.  It will

 7     last as long as the American empire, the American hegemony and

 8     domination.  You see that it's now on very shaky legs, on thin ice.

 9             The Hague Tribunal, instead of being the basis of a new

10     international law and international justice, it will actually become a

11     mockery of international judiciary system.  And nobody will be glad to

12     refer to the precedents that were established here and the judgements

13     that were issued and passed here.  Because it was not justice that was

14     administered here.  It was political interests that prevailed in this

15     Tribunal.

16             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, it's now 6.30.  You

17     can stop now if you want to have a rest.  We can reconvene tomorrow

18     morning.  Or, if you wish, we can continue until 7.00.  As you please.

19             THE ACCUSED: [Interpretation] You have probably sensed that I

20     have become a bit lost for words.  I was embarrassed to say that I was

21     tired, that I wished to have a break and continue tomorrow morning, but

22     it would be a good idea.  We should do that.

23             JUDGE ANTONETTI: [Interpretation] Very well.  We shall reconvene

24     tomorrow at 9.00.  Thank you.  Have a good evening.

25                           --- Whereupon the hearing adjourned at 6.28 p.m.,

Page 17400

 1                           to be reconvened on Thursday, the 15th day of

 2                           March, 2012, at 9.00 a.m.