140910ED

Page 11241

1 MS. BIERSAY: Thank you, Your Honour.

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

3 Q. Good morning, Mr. Seselj. I'd like to talk to you about your

4 evidence about the 200 executed at Ovcara. Do you remember that from

5 yesterday?

6 A. Of course. I remember everything.

7 Q. If -- I'd like to repeat what I understand you to be saying.

8 If I understand you correctly, you are saying that those

9 200 remained in the custody of the JNA and that they were never turned

10 over to the civilian authorities; right?

11 A. Yes.

12 Q. I understand -- thank you.

13 A. There is not -- there's not a single piece of evidence that they

14 were turned over. Ms. Biersay, you have --

15 Q. You answered my question. You said yes. And now I'd like --

16 I'll give you an opportunity, but first, I need to set the foundational

17 questions first. So I understood that correctly. Thank you.

18 Now, if I also understand your Milosevic testimony, there it was

19 your testimony that the 200 executed were turned over to the civilian

20 authorities; right?

21 A. That's what I thought at the time. I didn't lie. That was my

22 mindset at the time, based on what I had read in the media up to then,

23 and based on the outcome of the proceedings conducted before the

24 supreme court in Belgrade.

25 Q. Okay --

Page 11242

1 A. I believe General Gojovic was the president of the supreme

2 military court in Belgrade at that time.

3 Q. I see. If we could now turn to Defence tab 19, I believe it is,

4 which is 1D02805. And I'm interested in beginning at page 61.

5 A. General Gojovic. I said it. It wasn't recorded. [In English]

6 "I believe General Gojovic was the president of the supreme ..."

7 MS. BIERSAY:

8 Q. Now --

9 JUDGE DELVOIE: Mr. Zivanovic.

10 MR. ZIVANOVIC: I would object, Your Honours. The same document

11 I tried yesterday to show to the witness and the Prosecution objected,

12 and I object on the same ground.

13 MS. BIERSAY: I am showing his previous inconsistent statement

14 which is perfectly admissible, I would think, in -- during

15 cross-examination.

16 JUDGE DELVOIE: Just one moment, Mr. Zivanovic. Yes,

17 Mr. Zivanovic.

18 MR. ZIVANOVIC: I think it is -- it was quite legitimate for me

19 to show the witness and explore this issue with him during

20 my examination-in-chief, and I don't believe that different -- different

21 standards should be applied to the Prosecution.

22 MS. BIERSAY: May I, Your Honour?

23 JUDGE DELVOIE: Yes, Ms. Biersay.

24 MS. BIERSAY: Thank you. My memory, if it serves me properly, is

25 that my objection was based on the manner in which Mr. Zivanovic was

Page 11243

1 trying to use this, and it was an issue of memory, if the Trial Chamber

2 recalls, because the Trial Chamber did deliberate on this point.

3 MR. ZIVANOVIC: As far as I recall, the Prosecution opposed to

4 the -- to the use of this document to -- and to explore with the witness

5 something that was in this document.

6 JUDGE DELVOIE: Indeed, Mr. Zivanovic, for the reason Ms. Biersay

7 mentioned, and now is there different reason. The objection is

8 overruled.

9 MS. BIERSAY:

10 Q. So I know that before you -- it sounds like your English is quite

11 good and the transcript before you is in English, and I will read it in

12 English and they'll translate it for you just so I can put it on the

13 record.

14 So this --

15 A. [Interpretation] I don't understand a word of English. I can

16 only speak English. I cannot listen to the English language. Everything

17 has to be translated into Serbian for me.

18 Q. Understood. Let me begin at page 43604 of this transcript, which

19 is your testimony in the Milosevic case on 1 September 2005. And you

20 were asked a question about the events relating to Ovcara. And this was

21 your answer:

22 "A. I know something about these events because I made efforts

23 to find out, but I'm not an eye-witness. And what I found out is rather

24 reliable; namely that the authorities of the Autonomous District of

25 Eastern Slavonia, Baranja, and Western Srem asked the JNA that some

Page 11244

1 prisoners from the Vukovar Hospital be turned over to them, with a demand

2 that they be tried for the crimes that they had previously committed over

3 the civilian population of Vukovar. And the information I got is that a

4 certain number - I don't know exactly how many - of those prisoners were

5 turned over to them, after which the prisoners were taken to the farm

6 called Ovcara whereupon the execution of those prisoners occurred.

7 "Q. From all that you managed to find out, who was involved?

8 Was the JNA involved in any way?"

9 A. Ms. Biersay --

10 MS. BIERSAY: Your Honour, I would object to this. I have not

11 finished reading. And I don't know what Mr. Seselj is pulling out of his

12 briefcase and we would strongly object to this procedure.

13 JUDGE DELVOIE: Mr. Seselj, you -- indeed, you should wait for

14 the questions to put to you. And may we ask what you are pulling out of

15 your briefcase?

16 THE WITNESS: [Interpretation] I sincerely thought that

17 Ms. Biersay had finished reading, and I started answering her question.

18 And as for my briefcase, this is a previous statement --

19 JUDGE DELVOIE: There was -- Mr. Seselj, there was no question at

20 all. She was still reading, and even if she finished reading, there was

21 no question yet. And say again, please, what is it you took out of your

22 briefcase?

23 THE WITNESS: [Interpretation] What I've pulled out are

24 two folders. In one of them, there is a statement that I gave

25 Mr. Zivanovic, Mr. Hadzic's legal representative. And in the other,

Page 11245

1 there are several documents, including copies of my book, "The Defence

2 Witness for Slobodan Milosevic in The Hague." I published my entire

3 testimony and I photocopied those parts which Ms. Biersay is partly

4 quoting from. She's not quoting the entire thing. She has chosen only

5 some parts to quote from. If you want me to take -- put them back into

6 my briefcase, I can do that. I can also offer to make photocopies for

7 you, because I myself published that book and it was published in

8 21.000 copies. It was published in English. It's available on the

9 Internet. I can provide you with all of that.

10 JUDGE DELVOIE: We would appreciate, Mr. Seselj, if you would put

11 the documents back in your briefcase as you offered to do.

12 The parties, of course, know all of this, and I repeat once

13 again, that the -- the proceedings are in the hands of the parties. They

14 decide on what they want to show to Court, what they want to ask you, and

15 what they want to hear from you as the truth as you know it.

16 Please continue, Ms. Biersay.

17 MS. BIERSAY: Thank you, Your Honour.

18 Q. "Q. From all that you managed to find out, who was involved?

19 Was the JNA involved in any way?

20 "A. According to my information, not a single officer of the JNA

21 was involved. And from what I learned, it was some locals who did it,

22 who had some outstanding accounts with the prisoners, but I have no

23 direct knowledge about" --

24 MS. BIERSAY: This is -- if we could continue. I've stopped

25 reading. If we can continue to the next page, which is page 61 in

Page 11246

1 e-court.

2 "... but I have no direct knowledge about it because I wasn't

3 there."

4 Q. You also continued, Mr. Seselj, to say:

5 "I dealt with it because it was one of the charges in my

6 indictment, so I had to research it extensively and my experts are

7 working on it, and the knowledge I have was obtained actually by my

8 expert."

9 Now, you go on to talk about Aleksandar Vasiljevic, and Judge

10 Kwon asked you about this first-hand information that you said you had:

11 "What do you mean by first-hand, Mr. Seselj?"

12 And you replied:

13 "I learned from people who were there. There is reliable

14 information that I got because I dealt with this question, in a way."

15 And Judge Kwon asked you:

16 "From whom did you hear that?"

17 And you answered:

18 "I talked to a large number of people. I talked, in particular,

19 to the commander of the Leva Supoderica Unit, Milan Lancuzanin, also

20 known as Kameni. I couldn't even tell you the names of all the people

21 with whom I discussed it."

22 That's what you said in the Milosevic case; correct?

23 A. I demand that I may be allowed to answer as extensively as the

24 question was. You did not put it on paper so it is not easy for me

25 remember everything you said. You want me to start answering

Page 11247

1 immediately?

2 Q. My question to you is simply: By hearing the interpretation that

3 you had, is that what you said during the Milosevic trial?

4 A. You have made here a compilation of my statements made during

5 that testimony. You cherry-picked what you believe necessary to put

6 forward now but you left certain things out. For instance, I see that

7 one sentence is missing here, that my investigators are still working on

8 it. Why did you omit that? It is in my statement. It is also in the

9 transcript. I mean in the recording of my testimony.

10 Now, my knowledge up to that moment was as follows. I mentioned

11 yesterday Milan Lancuzanin known as Kameni. I insisted on finding out

12 from him whether the volunteers of the Serbian Radical Party had been

13 involved. He said no. I also had consistent information from the media

14 that all the prisoners had been handed over. And, third, there was the

15 investigation, the inquiry, carried out in Belgrade and such was the

16 outcome.

17 I studied it the first years I've --

18 Q. Thank you, Mr. Seselj --

19 A. -- spent in The Hague but at that time I did not have legal

20 advisors and no privileged communication.

21 Q. One moment, please. I understand this because you explained it

22 extensively to Mr. Zivanovic, and I -- you answered my question that

23 this, in fact, is information that you gave the Trial Chamber in the

24 Milosevic case. I understand your position about that.

25 My question to you is: Do I understand you correctly that you're

Page 11248

1 saying that your information is more accurate now than it was in 2005,

2 when you testified? Yes or no, your information is more accurate now?

3 A. Now I have incomparably more accurate information, but I'm not

4 ever going to answer you with a yes or no because this is not a TV quiz.

5 I am testifying here with full awareness of the importance of my

6 evidence, and you cannot manipulate me as you do other witnesses.

7 Q. Thank you, Mr. Seselj. So, Mr. Seselj, is it fair to say that

8 you tailor the facts to exonerate yourself or certain accused charged

9 before this Tribunal?

10 A. I have never tailored any fact in favour of my own Defence or the

11 Defence of Mr. Milosevic, Mr. Karadzic, or Mr. Hadzic. I found out here

12 in The Hague and Sljivancanin confessed in his own case that he had

13 brought the buses with prisoners to Ovcara; whereas I had earlier thought

14 that the prisoners had been handed over to the civilian authorities in

15 the Vukovar barracks.

16 Here you called many witnesses in my trial and you provided me

17 with their statements, statements of victims, survivors from Ovcara,

18 Emil Cakalic and others, from which it is evident that the JNA officers

19 were at Ovcara all the time. They compared lists. They released them,

20 et cetera.

21 So you subsequently showered me with information here that runs

22 counter to what I had thought. Now the first witness in my trial,

23 Goran Stoparic --

24 Q. Mr. Seselj -- Mr. Seselj, one moment, please --

25 A. [Overlapping speakers] ... recounted here how he had made

Page 11249

1 arrangements with Kameni --

2 Q. One moment, please. I think you have answered my question loud

3 and clearly. And --

4 A. You may think so, but I didn't. I have one more sentence.

5 Please, do not run away from the truth.

6 Q. One more sentence, okay.

7 A. [In English] One more sentence.

8 [Interpretation] Goran Stoparic stated here that he, Kameni, and

9 Kinez got together on somebody's instructions or somebody's demand over

10 there, I can't remember who, to agree how they should testify, give the

11 same evidence to exonerate Sljivancanin. Before I heard him --

12 Q. Mr. Seselj --

13 A. -- I had completely different information. I was taken aback. I

14 was surprised. You're again running away from the answer.

15 Q. Thank you. I'd now like to, if we could -- I believe this is

16 tab 100, which is 65 ter 4955.1. And this is a video-clip. And pursuant

17 to our internal protocol, I wanted to check with the interpreters to see

18 if they have been able to locate the transcript for this video, 4955.1,

19 which, for the record, is an extract from the main exhibit, from

20 30 minute, 08, to 31 minute, 11, and I believe --

21 THE INTERPRETER: We have it.

22 MS. BIERSAY:

23 Q. So before we start playing, Mr. Seselj, I'd like you just to take

24 a look at this video. And then after it's finished, I'll ask you some

25 questions about it.

Page 11250

1 [Video-clip played]

2 THE INTERPRETER: [Voiceover] "These are our volunteers who are

3 part of the Territorial Defence. We haven't got any units of our own

4 here. All the people are our people. All the units here are our units.

5 And, of course, those who came here of their own will to fight, know full

6 well why they are here and what they're fighting for, and they don't need

7 to be persuaded to fight because they themselves wanted to do so. And

8 therefore one should not be surprised at their courage.

9 "Q. How significant is the liberation of Vukovar for Serbia and

10 the Serbian people?

11 "Vojislav Seselj: It is of exceptional significance, exceptional

12 significance. This is the most powerful Ustasha stronghold. Once

13 Vukovar is taken, Ustashas have no chance of saving either Osijek or

14 Vinkovci. There is nothing to stop our forces. Vukovar is the key line

15 that needs to be broken through, that needs to be captured, and then

16 there will be nothing Ustashas can do. The Ustashas know that if Vukovar

17 falls here, if Slunj falls in Serbian Krajina, then Tudjman's Ustashas

18 regime in Zagreb will fall too. And that is why this battle is

19 decisive."

20 MS. BIERSAY:

21 Q. You recognised yourself, of course, I take it.

22 A. Ms. Biersay, I'm impressed at how good I looked and how well I

23 spoke at that time, and I hope that you are impressed too.

24 Q. But, of course. Now, Mr. Seselj, do you recall the occasion on

25 which you gave this interview? According to our information, it was not

Page 11251

1 long before the liberation of Vukovar.

2 A. It couldn't have been after 8 November. It could have been

3 during my first visit in October, or during my second visit, on the

4 8th of November. It couldn't have been later. And Vukovar was liberated

5 on 18 November; that is to say, ten days later.

6 Q. And it's accurate at the time, was it not, that the volunteers,

7 "our volunteers," your volunteers, made up a part of the Territorial

8 Defence?

9 A. And the Territorial Defence was part of the Motorised Guards

10 Brigade, completely integrated into their complement. And the

11 1st Assault Detachment, which participated the most in the fighting for

12 Vukovar, was made up, if I remember well, of three companies of the

13 Guards Brigade, two companies of the Territorial Defence, and the

14 detachment called Leva Supoderica. That was the composition of the

15 assault detachment commanded by Major Borivoje Trajkovic. This is

16 exhaustive information, and this is something that I witnessed.

17 MS. BIERSAY: At this time, the Prosecution tenders

18 65 ter 4955.1.

19 JUDGE DELVOIE: Admitted and marked.

20 THE REGISTRAR: Exhibit P3556, Your Honours.

21 MS. BIERSAY: I'd now like to turn to a document --

22 THE REGISTRAR: I apologise. 3256. Thank you.

23 MS. BIERSAY: A document which has already been admitted as

24 P2625, and it's tab 38.

25 Q. Now, you can see it already on your screen, Mr. Seselj, and --

Page 11252

1 A. Could you make it a bit larger? I don't see very well.

2 Q. Is that better?

3 A. Now I recognise the document, but I can't read it very well yet.

4 Q. Slobodan Katic, his name appears at the very bottom. You know

5 who that is; right?

6 A. Yes.

7 Q. And who is it?

8 A. Slobodan Katic was the commander of a group of volunteers that

9 had arrived with him from Belgrade and was integrated into the

10 Leva Supoderica Unit. Because of his merits in the war, I later

11 proclaimed him a Chetnik vojvoda, duke, too. However, when Vukovar was

12 liberated, he stayed to live in Vukovar and he got married there. And I

13 believe he continued to live there until the Croats recaptured Vukovar

14 again in the beginning of early 1996, if I'm not mistaken.

15 Q. Now this document is dated 9 December 1991, and it's a request

16 for promotion for the people listed below; right? So you have Katic and

17 he's proposing -- he's asking the chief of the War Staff,

18 Ljubisa Petkovic and his deputy Zoran Rankic from Belgrade to propose the

19 following warriors for promotion, right? That's what's happening in this

20 document?

21 A. Ms. Biersay, this document did not exist at the War Staff. It

22 was never registered in the protocol. It was the private property of

23 Ljubisa Petkovic and he turned it over to the OTP, to the investigators.

24 Indeed, Slobodan Katic did address Ljubisa Petkovic and his deputy asking

25 for the promotion of all these people but they are not members of the

Page 11253

1 Serbian Radical Party, and I cannot understand what kinds of sentiment

2 this reflects, whether Ljubisa Petkovic was supposed to influence somehow

3 his connections in the War Staff or what. None of them was in the

4 Leva Supoderica Unit, except for Milan Lancuzanin, known as Kameni, and

5 Kameni was in the first group that I proclaimed Chetnik vojvodas. I

6 don't know any of the other people.

7 Q. Now, this is not a request to the JNA for promotion to these

8 people; right? This request is going to the chief of the SRS War Staff

9 and Zoran Rankic, not to the JNA?

10 A. Ms. Biersay, ignorant, unschooled people are incapable of using

11 the proper form when they write something. Slobodan Katic did not have

12 much schooling. He was a good warrior but not very educated. We did not

13 have any agreement with the JNA, and the first officer ranks were granted

14 by Duke Momcilo Djujic on the 13th of May, 1991, at Ravna Gora, and he

15 promoted into officers all members of our volunteer group that had fought

16 in Borovo Selo. There are more cases -- was I now cut off? There are

17 more cases. It's important for me to tell you this.

18 Q. One moment, Mr. Seselj. We'll get there. But what I wanted to

19 do now is to show you another document, which is tab 35, P2576. And

20 while we're waiting for it to be brought to the screen, it is dated

21 9 November 1991.

22 And the signature at the bottom is -- it's written that this is

23 Ljubisa Petkovic signing this document. And it's addressed to the

24 commander of the Leva Supoderica Detachment. And in the first

25 paragraph it notes that:

Page 11254

1 "All the volunteers that the Serbian Radical Party has sent you

2 are being placed under your command and the protection of the Vukovar TO.

3 The SRS War Staff has appointed Slobodan Katic, a brave and experienced

4 soldier from Belgrade, as the commander or the komandant of the

5 volunteers in Vukovar."

6 Is that consistent with the information that you have?

7 A. It is not clear enough. Slobodan Katic was appointed by the

8 War Staff as commander of the group that had arrived with him on the

9 9th of November. Ljubisa Petkovic knows about the order of the commander

10 of the Guards Brigade to send volunteers to the unit. This group of

11 volunteers was taken to Bubanj Potok. They got weapons there and

12 uniforms, and they were bussed to Vukovar. This is a letter that he was

13 sending with Slobodan Katic. I don't see anything odd about it. It's

14 not perfectly articulate or literate, but I don't see anything

15 problematic about the content.

16 Q. I'd like to show you another video-clip.

17 MS. BIERSAY: And if I could just check with the interpreters

18 before we get there, it would be 88 -- P88.50.

19 [Prosecution counsel confer]

20 THE INTERPRETER: We've got it. In fact, we have two of them:

21 50.3 and 50.8.

22 MS. BIERSAY: Thank you. Thank you. And could I also confirm

23 that the interpreters have P1740?

24 THE INTERPRETER: Yes.

25 MS. BIERSAY: Thank you.

Page 11255

1 Q. Mr. Seselj, some of your very early contacts with people in

2 Borovo Selo was with Vukasin Soskocanin. Excuse me for my pronunciation.

3 Do you recall that person, Soskocanin?

4 A. I remember Vukasin Soskocanin very well. He was the commander of

5 the Territorial Defence of Borovo Selo. And the last time I saw him was

6 in April 1991, when we agreed about the integration of volunteers.

7 Q. And in your -- you recall giving an interview for the documentary

8 "Death of Yugoslavia" to Laura Silber?

9 A. Yes. I gave that interview. It was more than 30 minutes and

10 they actually used only five minutes. But I published the entire

11 interview in one of my books. I could not allow all the smart things I

12 said to go unheard.

13 Q. You describe in that interview that he provided your volunteers

14 with weapons; is that correct?

15 A. Vukasin Soskocanin? Yes. Our volunteers went there wearing

16 civilian clothes and no weapons.

17 Q. And you explained that later on you developed contacts with the

18 Serbian police and also with the General Staff of the JNA.

19 A. Ms. Biersay, those were our contacts, of course, but all these

20 contacts were done through Ljubisa Petkovic. I was never in the security

21 service or the Serbian police in general or the General Staff of the JNA.

22 And I never personally visited the General Staff of the Army of

23 Yugoslavia, the VJ. But we did have these contacts on a number of

24 issues.

25 Q. Sure. So you would have people who worked for you deal with

Page 11256

1 contacts with other people. You didn't do everything yourself. Is that

2 what you're saying?

3 A. Well, yes. You see, Ljubisa Petkovic went as one of my men both

4 to the State Security Service and the General Staff, and then, in the

5 meantime, the State Security Service recruited him to work for them

6 against the party. And when I heard about that, I interrogated

7 Ljubisa Petkovic before TV cameras and after that he was expelled from

8 the party. And he confirmed all that. He even confirmed that the

9 State Security Service had given him a car for his use, and he took out a

10 driving licence on which was written "the MUP of Serbia," the Ministry of

11 the Interior.

12 Q. He was expelled from the party. But you had a reconciliation

13 during the course of your trial; right?

14 A. Ljubisa Petkovic was questioned by OTP investigators several

15 times. He provided very extensive statements. He provided documents

16 that he had in his possession, that is to say, documents he had had at

17 home, and he collaborated with the OTP all the way up until the

18 Security Council decided that no new indictments could be raised. In

19 fact they decided that all the indictments had to be issued by the

20 beginning of 2005.

21 Ljubisa Petkovic was scared because he was threatened with an

22 indictment. He was very co-operative with investigators until that time

23 and he even brought them new witnesses for interview. However, when he

24 realised that there could be no indictment against him any longer, he

25 addressed my assistants. He offered his co-operation and assistance, and

Page 11257

1 he gave them even a copy of a long interview he had given to OTP

2 investigators, and that was in 2006 --

3 Q. Mr. Seselj --

4 A. -- and that is pure truth. And, of course, we embraced him

5 because he was useful.

6 Q. He was useful. And in fact, Mr. Petkovic refused to testify in

7 your trial as either a witness for the Prosecution or a witness for the

8 Trial Chamber, and he was convicted of contempt for that.

9 A. Yes. And that was the reason why after a while we appointed him

10 a Member of Parliament. One MP happened to die after the elections.

11 That was Dragan Tasic, a legal assistant of mine. He was a graduate of

12 the --

13 Q. [Previous translation continues] ...

14 A. -- university in Montpellier. He spoke perfect French,

15 et cetera.

16 Q. Thank you, Mr. Seselj.

17 A. When he died, we rewarded Ljubisa Petkovic by offering him his

18 seat in the parliament.

19 Q. It's been brought to my attention that I think at transcript

20 page 15 what's written is "Borivoje Trajkovic" in relation to the

21 commander of the 1st Assault Detachment. Do you recall the commander?

22 A. Certainly. Many newspapers published our photograph during our

23 inspection of the front line in Vukovar, and I even said that, on one

24 occasion, Borivoje Trajkovic complained that he had had a lot of trouble

25 because of that photograph because when we made an alliance with

Page 11258

1 Milosevic, he got into trouble over that --

2 Q. Mr. Seselj --

3 A. -- he later became commander of the gendarme service and a

4 general. I want to provide you with complete information.

5 Q. Is the name Borivoje Tesic familiar to you?

6 A. Sorry, it's my mistake. It's not Borivoje Trajkovic. It's

7 Borivoje Tesic. He was the commander of the 1st Assault Detachment. It

8 was my slip of the tongue. He posed for a photograph together with me at

9 that time, and it was published in all the newspapers.

10 Q. I'd like to --

11 A. I misspoke because there was also a man called

12 Borivoje Trajkovic.

13 Q. Mr. Seselj -- I understand.

14 MS. BIERSAY: If the interpreters could now go to the P1740.

15 May I just have a confirmation. I know you said it before, I

16 just -- directing my comments to the interpreters. I just want to make

17 sure.

18 THE INTERPRETER: Yes, we have it.

19 MS. BIERSAY: Thank you.

20 At this time I'd like to play P1740, which is also tab 129.

21 [Video-clip played]

22 THE INTERPRETER: [Voiceover] "Dr. Vojislav Seselj, president of

23 the Serbian Radical Party, visited Borovo Selo today.

24 "Seselj: The Serbian people located in the most endangered areas

25 have to persevere. They have to show as much patience and will as

Page 11259

1 possible as they are bearing a heavy burden. Most things depend on their

2 strength, courage, and determination.

3 "Reporter: Are the units of your party ready to help at this

4 moment?

5 "Seselj: We have no party units. What we do is organising the

6 registration of volunteers in Serbia and then sending them where they are

7 needed; i.e., they are going to the villages where they are asked to come

8 by Serbian villagers and they're immediately joining the local units

9 under the command of the village staff. That means that we do not have

10 any special units in this region nor do we have the need for them. We

11 are all Serbs regardless of the party affiliation. We are not taking

12 into account the party divisions until the borders of Serbia are secured.

13 "Reporter: Vojislav Seselj, president of the Serbian Radical

14 Party, met with the Orthodox bishop Lukijan from the ... Osijek-Polje,

15 who, among other things, said the following: All Serbs must be unanimous

16 as that is in their best interest. Enough with the divisions."

17 MS. BIERSAY:

18 Q. And so, Mr. Seselj, this is an accurate reflection of what was

19 happening at the time. Namely that your volunteers were being asked to

20 go to certain villages; is that correct?

21 A. I spoke about that yesterday and I'm confirming it today. Yes,

22 this clip was taken in Borovo Selo in April. I suppose. First we sent

23 them to Borovo Selo and then we started selling [as interpreted] them to

24 other endangered villages. I can give you some of the names of those

25 villages, if you wish, if you are interested.

Page 11260

1 Q. Yes, please, tell us just the names of the villages that you

2 remember.

3 A. Trpinja, Tenja, Mirkovci, Laslovo, and Ernestinovo.

4 Tomislav Nikolic, the current president of the Republic of Serbia, also

5 fought there, and as a result, he was also bestowed the title of a

6 Chetnik vojvoda. There are other villages that I can try and remember.

7 Q. Regarding your comment about Mirkovci, if I could now please turn

8 to tab 150, and this is P1741. I think this relates to what you're

9 describing.

10 A. I don't see anything yet.

11 Q. Some patience, please.

12 And this appears to be coming from the Mirkovci local community

13 going to the Serbian Radical Party in Belgrade. Can you see that?

14 A. Yes. It was signed by Zoran Beldar who was the president of the

15 local commune of Mirkovci. He thanked us for our assistance consisting

16 of our volunteers who were sent there. He emphasises three persons who

17 played an especially prominent role - Kosta Carina, Nenad Vukanovic,

18 Ranislav Dragojlovic. I can tell that you that Kosta Carina was their

19 leader, and I can tell you that they captured the state-of-the-art

20 Armbrust rocket-launcher which is used in antitank struggle. They

21 brought it to my office in Belgrade. We held a press conference and we

22 demonstrated that piece of weaponry and that was aired on all Serbian

23 television channels. Maybe Ljubisa Petkovic could have provided with you

24 that clip because he was the one who kept them. I fully confirm this

25 information.

Page 11261

1 Q. One clarification, Mr. Seselj, because the last name is not yet

2 entered on the transcript. For Zoran. You said: "The president of the

3 local community was Zoran," could you spell the last name, please, for

4 the record.

5 A. Beldar. That's his -- [In English] Beldar, B-e-l-d-a-r.

6 [Interpretation] You see how good I am spelling, Ms. Biersay? I don't

7 speak English at all, but I can spell.

8 Q. Quite remarkable. Mr. Seselj, could you describe for us your

9 view about whether or not Baranja is, in fact, Croatian territory

10 historically.

11 A. Baranja was never Croatian territory, absolutely never. It was

12 part of Hungary. It did not belong to any of the counties which

13 subsequently became parts of Croatia. It never belonged to the county of

14 Slavonia, for example. After the First World War, a great national

15 council of Serbs and people from Bunjevo [phoen] called Bunjevci --

16 Bunjevci are a Slav people very close to us Serbs. They met -- Bunjevci

17 have their idiosyncrasies in their culture and language and they reached

18 a decision that Banat, Backa, and Baranja would directly join Serbia.

19 After the Second World War, however, the Communists made Baranja a

20 Croatian territorial unit. Croats will have to return Baranja and all

21 the other Serbian lands to us, sooner or later.

22 Q. So am I correct that in your view, Baranja properly belongs to

23 the territories that belong to Serbs?

24 A. Yes, of course.

25 Q. Now, you describe the famous line that is the western border of

Page 11262

1 what would be Serbian lands, the one that runs through Croatia.

2 A. Yes, this is the line Karlobag-Ogulin-Karlovac-Virovitica. And

3 that line actually is why I should go down in history.

4 Q. I'd like to direct your attention to a document and -- tab 118,

5 previously admitted exhibit 2955.2913. This is a newspaper article, and

6 it doesn't ...

7 A. Again, I can't see it yet.

8 Q. Can you see it now?

9 A. [In English] No.

10 Q. Okay. It's coming. Can you see it?

11 A. Again, this has to be enlarged. I think that only the text you

12 are interested in should be on the screen. It would automatically be

13 larger, and I would be able to read it then.

14 Q. I am interested in the article called: "Western borders of

15 Slavonia now open."

16 A. As I can see, this is Goran Hadzic's press conference, but I

17 cannot read the text. If you want my comments on the text, you will have

18 to provide me with a hard copy of the article. The letters are too small

19 for my age.

20 JUDGE DELVOIE: Mr. Zivanovic.

21 MR. ZIVANOVIC: Your Honours, I would just let you know we have

22 it in hard copy in original size and we could provide it to the witness,

23 but not right now from -- approximately for several minutes.

24 MS. BIERSAY: It's fine.

25 JUDGE DELVOIE: Ms. Biersay.

Page 11263

1 MS. BIERSAY: I'll move on in a different way. In the same

2 document could we scroll into the English -- to the English translation,

3 please.

4 Q. I am -- perhaps can you see. It's the section that says:

5 "Ilija Petrovic." If you can't see it, I'll read it to you.

6 A. Yes, I can see that.

7 Q. Now, it says "Ilija Petrovic" who is identified as the

8 information minister. You knew him; correct?

9 A. I can't remember him. Yesterday I mentioned Ilija Petkovic and

10 Ilija Koncarevic. Ilija Petrovic, that doesn't ring a bell. I don't

11 know that I ever met him. His deputy was Rade Leskovac. He was well

12 connected on Serbian TV. That's why he was very often seen giving

13 statements instead of the minister himself. I may have met him but I

14 can't remember.

15 Q. I'd like to read you -- into the record what this says. It says:

16 "The information minister in Hadzic's government recalled that

17 the proposal of the Serbian National Council of these districts was to

18 establish the contentious western border along Ilova-Virovitica stretch

19 if necessary by moving the Serbian and Croatian population [sic]."

20 And my question to you: The Ilova-Virovitica line would be the

21 very northern-most boundaries of the line that you mentioned earlier, the

22 one for which you should go down in history?

23 A. This line is much more modest than mine. Less challenging or

24 demanding, if you will. My line comprises a lot more, significantly a

25 lot more territory. That's why I will go down in history and not

Page 11264

1 Ilija Petrovic.

2 Q. Your line, of course, also cuts down over in the Knin Krajina

3 area; right?

4 A. Ms. Biersay, with regard to Slavonia itself, my line encompasses

5 much more territory than the one starting in Ilova. If you look at the

6 line Karlobag-Ogulin-Karlovac and then onwards to Virovitica, you will

7 see that that comprises a lot more territory than the Ilova-Virovitica

8 line. If you had a map, I could show it to you on the map.

9 Q. What I'd like to ask you about is the idea of population

10 exchanges. You have previously said that you advocated population

11 exchanges in certain situations; correct?

12 A. Ms. Biersay, you charged only me with that. Although many people

13 advocated that. In Croatia it started with Tudjman. Dobrica Cosic

14 adopted that idea. There was a meeting somewhere on the Adriatic coast,

15 I don't know where exactly. He actually met up with Tudjman in order to

16 agree that. It was to be a civilised exchange of population where

17 differences could not be reconciled. It was a repeating theme. I was

18 not the only one. Ilija Petrovic was not the only one who mentioned it.

19 Many, many politicians - more of them on the Croatian side than on the

20 Serbian side - kept on mentioning that. The Croats were the ones who

21 started mass expulsion of the Serbs in 1990 already, and later on they

22 decided to put forth that proposal.

23 JUDGE DELVOIE: Ms. Biersay --

24 MS. BIERSAY: Yes, Your Honour.

25 JUDGE DELVOIE: -- just to clarify, is -- or was this question

Page 11265

1 still based on the document we have in front of us at the moment?

2 MS. BIERSAY: Not regarding Mr. Seselj's own views about the

3 population exchange, and it was based on the attribution to Petrovic

4 about moving the Serbian and Croatian population.

5 JUDGE DELVOIE: My concern was the word "exchange" and

6 "exchanging," because in this document, it said "moving."

7 MS. BIERSAY: Exactly. So my question to Mr. Seselj was about

8 his view of population exchanges.

9 JUDGE DELVOIE: But not about population moving.

10 MS. BIERSAY: No, Your Honour.

11 JUDGE DELVOIE: Thank you.

12 MS. BIERSAY: Thank you.

13 If I could now have --

14 THE WITNESS: [Interpretation] Ms. Biersay --

15 MS. BIERSAY:

16 Q. There's no question yet, Mr. Seselj. If you could wait for

17 one minute while I show you another document, which I believe is

18 tab 11 --

19 JUDGE DELVOIE: Ms. Biersay, the document -- the hard copy --

20 MR. ZIVANOVIC: We provided the document [overlapping speakers]

21 --

22 JUDGE DELVOIE: The hard is there.

23 MS. BIERSAY: It's okay. I've finished. I don't need it

24 anymore. Thank you.

25 JUDGE DELVOIE: You've finished the document.

Page 11266

1 Thank you, Mr. Zivanovic.

2 THE WITNESS: [Interpretation] But I did not fully answer your

3 question. I did not give you a full answer. It says: "Moving the

4 Croatian and Serbian populations." This is an exchange. If it was only

5 Croatian or only Serbian, it would be a different thing. However, if the

6 populations of two ethnic groups move at the same time, this constitutes

7 an exchange. It is not done subsequently. It is done at the same time,

8 one move to the place from which the others have moved out. That's an

9 exchange.

10 MS. BIERSAY:

11 Q. So I take it that you agree with what Ilija Petrovic is saying in

12 this article.

13 A. No.

14 Q. And in what way do you disagree with him?

15 A. I don't agree with him at all.

16 Q. And in what way do you disagree with him?

17 A. I don't agree in terms of the western border of the Serbian

18 Slavonia or in terms of people moving out. It was only in 1992 that I

19 started advocating the idea of the exchange of population when

20 300.000 Serbian refugees and displaced persons arrived in Serbia. In

21 1991, I believe that I was never in favour of this idea, unless you have

22 something to prove that I did. It was only when Serbia was swamped with

23 refugees from Croatia that I started advocating the idea of the exchange

24 of population as a partial solution to the problem.

25 MS. BIERSAY: If I could now have tab 60, which is 65 ter 155.

Page 11267

1 Q. And, Mr. Seselj, this is a transcript of an interview given on

2 24 May 1991 with you called: "Chetnik revenge will be blind."

3 Do you recall that?

4 A. I remember it, and yes, the revenge will be blind. That's what I

5 said.

6 Q. And if we could go to -- actually, Mr. Seselj, we'll come back to

7 this document.

8 A. So should I retain it in my memory until then?

9 Q. No, no need.

10 MS. BIERSAY: I'll move to another 65 ter number, which is

11 65 ter number 6613. And for the Trial Chamber, that is tab 138. If we

12 could go to the second page in the English.

13 Q. So I am interested in the portion that begins: "However

14 regarding Croatia," and I think it begins at the bottom of the page that

15 you're looking at in Serbian. Do you see it? It says:

16 "However, regarding Croatia, we, the Serbian Chetniks, are

17 constantly telling to the new Ustasha leader Franjo Tudjman ..."

18 Do you see that, Mr. Seselj?

19 A. Again, can this be enlarged just a little? Can you highlight

20 only that part and put it on the screen?

21 Q. Is that any better?

22 A. Why don't you read it and I will listen.

23 Q. So you can't see it?

24 A. With difficulty. You read it.

25 Q. You say here:

Page 11268

1 "The new Ustasha leader, Franjo Tudjman, and the new Ustasha

2 authorities in Croatia not to play games with the Serbian people that

3 lives in the areas of the present improvised Croatian state community.

4 This is the Serbian territory, populated by the Serbian people, and we

5 shall never allow it to be separated from its mother country. The Croats

6 may separate themselves from Yugoslavia; in other words, they may have an

7 independent state, may merge with someone else. However, they must know

8 at all times that at all costs that the price of new rivers of blood, we

9 shall not let them separate any territory that contains Serbian villages,

10 Serbian mass graves, Serbian slaughter-houses, Serbian pits, Serbian

11 camps, Serbian Jasenovac, destroyed Serbian churches. We shall never

12 allow that."

13 A. You should now show the last page of the interview. We need to

14 see the date. Or perhaps you can just give us the date. Please take a

15 look and give us the date. And then I'll just pretend that I believe

16 you.

17 There should be the date on the last page and the place where

18 this was published or the name of the journalist, or perhaps it was a TV

19 show. I'm sure that it was a TV show but -- because it says "presenter."

20 Do you have the entire interview?

21 Q. We do but not in our electric electronic system and I can get

22 that after the break.

23 But my question to is now is: Based on what I've just read, it

24 sounds like what you're saying here, it's that wherever Serb villages,

25 Serb mass graves, slaughter-houses, pits, camps, churches were, that that

Page 11269

1 was Serbian -- Serb territory. Do I understand that correctly?

2 A. Well, you did not fully understand me because you're absolutely

3 not familiar with those things. I am saying that the results of genocide

4 should not be recognised, and I'm talking about the genocide that

5 Croatians committed against the Serbian people during the Second World

6 War. The Croats wanted to erase what happened during the Second World

7 War and then to establish borders according to the current ethnic

8 composition. Our position was we should not admit that the number of the

9 Serbian population was -- has been reduced because they were killed

10 during the Second World War. The Croats cannot enjoy the fruit of the

11 genocide that they had committed against the Serbian people.

12 I said this sometime in the first half of 1991, before the war

13 started, if my memory serves me properly. That's why you are not very

14 keen on giving us the date and the place. However, if you are a serious

15 Prosecutor, you should always have that information at the tip of your

16 fingers. You have to have that information. You should have preceded

17 this question by giving us the time and the date.

18 Q. Mr. Seselj --

19 A. This is what I would do if I were in your shoes.

20 Q. So you confirm that this, in fact, is in 1991; correct?

21 A. I can't confirm this because this could have been in 1990.

22 However, judging from the contents you can tell that the war had -- did

23 not start yet.

24 Q. Thank you, Mr. Seselj.

25 MS. BIERSAY: I see the time for the break, Your Honours. I'm

Page 11270

1 happy to stop here.

2 JUDGE DELVOIE: Thank you, Ms. Biersay. We take the first break,

3 30 minutes. We will be back at 11.00.

4 Court adjourned.

5 --- Recess taken at 10.30 a.m.

6 --- On resuming at 11.01 a.m.

7 JUDGE DELVOIE: Ms. Biersay, please proceed.

8 MS. BIERSAY: Thank you, Your Honour.

9 Q. Mr. Seselj, do you recall attending the Great National Assembly

10 of Slavonia, Baranja, and Western Srem in September of 1991?

11 A. Possibly.

12 MS. BIERSAY: If I could have tab 4, please, which is P22.

13 Q. And I'm sure it will need to be expanded for you, Mr. Seselj.

14 It's the article discussing "constitutional law adopted."

15 And you can see at the top, it says:

16 "Meeting of the Great National Assembly of the Serbian District

17 of Slavonia, Baranja, and Western Srem, Beli Manastir, 25 September."

18 Now, what I'm interested in is actually found on page 3 in the

19 English and it should be towards the end of the -- this article, and I

20 believe the paragraph begins: "Seselj went on to say ..."

21 Actually it's the paragraph that begins:

22 "'Your Territorial Defence has restored the glory of Serbian

23 soldiers,'" said Dr. Vojislav Seselj, addressing the deputies."

24 Do you see that in the Serbian?

25 A. No, it's not before me. Now I see it.

Page 11271

1 Q. Does this refresh your recollection about whether or not you

2 attended that session, that assembly --

3 A. Yes, yes.

4 Q. And so --

5 A. No doubt.

6 Q. Why did you go to that meeting; do you remember?

7 A. Well, somebody must have invited me or informed me, and I went

8 there to give my support to the highest body of the legislative branch of

9 Slavonia, Baranja, and Western Srem. I gave my support through my

10 presence and my speech.

11 Q. And I take it at this time you had no political conflict with

12 Goran Hadzic in 1991?

13 A. You know what? I really didn't even know Goran Hadzic at that

14 time. He was at this session, and maybe we shook hands in passing, but I

15 don't remember that we ever talked. We could have met. We could have

16 shaken hands, but that's all. I knew much better Caslav Ocic, for

17 instance, who was also elected foreign minister. And I also -- I already

18 told you about Ilija Koncarevic and Mr. Petkovic. One of them must have

19 invited me.

20 Q. I'd like to move to a different topic regarding Arkan. You

21 described yesterday in great detail your conflict with him when he

22 threatened you; do you recall that?

23 A. Yes. And I returned the threat.

24 Q. I take it you also knew that, by reputation, he was wanted by

25 Interpol?

Page 11272

1 A. Well, at that time, I wasn't really informed about that. There

2 was talk that he had robbed banks in Sweden. There were stories of that

3 kind. But in 1986, I was interested in him as a means to target Stane

4 Dolanc. Arkan was then an unimportant person, whereas Stane Dolanc was

5 one of the top leaders in Yugoslavia and --

6 Q. I understand. So you're saying that all the information that you

7 had about him being a bank robber and all those -- all that criminal

8 activity, that was information you had in the 1980s?

9 A. Well, I had information that he was involved in the murder of

10 Djurekovic. And yesterday when I returned to Scheveningen, I saw on TV

11 that Germany had asked the Serbian authorities to issue a certificate

12 confirming that Arkan is dead or that he is alive, what a coincidence.

13 Obviously the Germans have the same information and you had much better

14 contact with Arkan. He negotiated with you in order to be relieved from

15 prosecution to appear as a witness in exchange in the Milosevic and some

16 other trials.

17 Q. Mr. Seselj --

18 A. I don't mean you personally. I mean the Office of the

19 Prosecutor.

20 Q. You and Arkan had this personal conflict but you reconciled in

21 1991 at the funeral of a volunteer; right?

22 A. If that was real reconciliation. We shook hands then. Perhaps

23 we exchanged a couple of words. That's when Mirko Lovadinovic, known as

24 Uco, got killed. He was a volunteer in Slavonia. And when a group of

25 our volunteers withdrew, he had decided to stay and join Arkan and his

Page 11273

1 men, and he got killed fighting with Arkan's Men. And Arkan and I both

2 attended his funeral. And a similar thing happened to another person. I

3 think it happened twice.

4 There was another meeting I had with Arkan when Arkan came to my

5 home. Are you interested in that? In November --

6 Q. In November --

7 A. Are you interested?

8 Q. In November of what year?

9 A. It was in October, 31st October 1992. I can tell you all about

10 it if you're interested.

11 Q. Well, let me show you these documents first and perhaps we'll get

12 to that.

13 MS. BIERSAY: I'd like now to have tab 145, which is P1743. It's

14 been previously admitted. And this interview, the date of it, is given

15 as 29 November 1991. The B/C/S page, I think it's -- it begins at the

16 very end of the third page. I think it should say page 123 at the bottom

17 of the B/C/S text. And so the very bottom, which hopefully we can

18 enlarge for Mr. Seselj. And, in the English in which I'm interested,

19 at -- is on page 2. Before we move to the Arkan part that I want to --

20 to go to, I just wanted to address an issue on this page.

21 Q. And, so the part I'm interested in is the part that starts:

22 "The army has already cleansed its ranks ..."

23 Do you see that text? I'm sure you're familiar with it as it's

24 your -- you published it. So it says on page --

25 A. Yes, yes.

Page 11274

1 Q. "The army has already cleansed its ranks quite a bit. It should

2 keep cleansing them and cleanse them to the maximum ..."

3 Further on it says:

4 "Now we trust the army, because the army has shown -- show us in

5 practice that it is fighting to defend the Serbian people, Serbian

6 territories, our western borders. The army is acting in co-operation

7 with all of our men, and without their acting in co-operation, neither

8 one of them would have achieved the results which are being achieved."

9 And that is the view that you held at the time that you gave this

10 interview; is that correct?

11 A. Yes.

12 MS. BIERSAY: And now going to page 7 in the English, and I

13 believe it's the very end of 124 in B/C/S. It's a sentence that carries

14 over into 125.

15 Okay. I believe we have the B/C/S well situated. And for the

16 English we need to go back a few pages to get to the portion that I want.

17 THE WITNESS: [Interpretation] Which excerpt have you shown me in

18 Serbian?

19 MS. BIERSAY:

20 Q. It will be the very -- the very last -- "sto," the very last

21 thing that you see, "sto" on the last line on that page. You see where

22 there is a period and then it begins "sto ..."

23 A. I see that but I need the -- the continuation.

24 Q. Right.

25 A. "As for ..."

Page 11275

1 MS. BIERSAY: If we could go in the English go -- go backwards

2 one more page. Okay. There we go. And if, for the English, if you

3 could enlarge the first paragraph.

4 Q. So, Mr. Seselj, if you could -- you've read that -- that line.

5 MS. BIERSAY: If we could now move in the B/C/S to the next page,

6 125, at the very top.

7 Q. Now, you were asked a question about co-operation, and here it

8 says:

9 "As far as the Serbian Volunteers Guard, headed by Zeljko, Arkan,

10 Raznjatovic, is concerned, we co-operate with them and our men have

11 participated in many battles together."

12 Does that correctly reflect the situation when you gave this

13 interview in November of 1991?

14 A. One point should be cleared up here. The statement is correct,

15 it was correctly quoted. It was the end of November 1991. In the course

16 of that month of November, our volunteers, just as Arkan's volunteers,

17 were under command of Radovan Stojicic, known as Badza, in the

18 Operative Group North commanded by the Novi Sad Corps. So Arkan's Men

19 were there as well. They took part in some combat such as the battle for

20 Tenja, but the two groups of fighters did not mix. Both of them were

21 engaged but they did not join together and they did not mix. We were

22 under the same command but each had their own section of the front line

23 where they fought.

24 And my aim at that time was not to increase tensions between me

25 and Arkan so that our people, our men on the ground, would not clash

Page 11276

1 mutually. That was my concern. Because on a couple of occasions, a

2 conflict, an armed conflict, a skirmish between our two groups of men was

3 barely avoided.

4 MS. BIERSAY: I'd like to now turn to tab 151, which is

5 65 ter 2039.2.

6 Q. If you just be patient while we find this document.

7 A. I have all the time in the world for you, Ms. Biersay. I like

8 you best of all the Prosecutor's Office.

9 MS. BIERSAY: And in -- in the B/C/S, I think we can go forward

10 to page 10 to 11 in the B/C/S, and I think it also corresponds to

11 pages 10 to 11 in the English as well. And this is an extract of an

12 interview given to B92 and it was republished in April of 1994. So

13 65 ter 2039.2.

14 [Prosecution counsel confer]

15 MS. BIERSAY: My colleague made it even easier than I thought.

16 So only the two pages of the B/C/S are in -- are uploaded.

17 Q. While we're waiting for this, Mr. Seselj, if I can ask you what

18 information at the time did you have about Arkan and the criminal

19 activities that he was involved with in Slavonia?

20 A. I had information about his robberies and looting. I knew about

21 several murders he committed. I once even filed a criminal complaint

22 about the murder of Iso Lero. Arkan's Men kidnapped him in Belgrade,

23 took him to Slavonia. They killed him, covered him with cement, and

24 threw him into the Danube. And a police inspector later came to tell me

25 they couldn't do anything. Arkan was so dangerous that even the police

Page 11277

1 couldn't do anything about him. So I had information about robberies.

2 And only when I came here did I receive extensive documentation about the

3 war crimes he was responsible for.

4 Q. And did you have any information about his activities with the

5 Djeletovci oil expiration [sic]?

6 A. Exploitation, you mean. I didn't hear of any explosion.

7 I believe that, in many places where he went, he would kind of

8 impose his presence so that he could go on doing whatever he pleased. I

9 had information that for a while he appropriated this oil field, exported

10 and sold that oil. The time of this story, of this text, is much closer

11 to the time when it was all happening, and my memory now is certainly not

12 so fresh as this text.

13 Q. Okay.

14 MS. BIERSAY: At this time are we -- let me check to see if we

15 are able to display 65 ter number 2039.2?

16 [Prosecution counsel confer]

17 MS. BIERSAY: Could I have the next page in English, please.

18 Thank you.

19 And if I could have the next page in the B/C/S as well.

20 Q. So what I'm interested in, Mr. Seselj, it's at the top of that

21 page. And I will read the part in English that I -- I'm interested in.

22 You're talking about Arkan, and at the end of that first full

23 paragraph -- in the middle of the first full paragraph it begins:

24 "In 1991, though, there was a war and what cannot be denied is

25 that Arkan was a brave soldier in this war. His courage cannot be

Page 11278

1 denied. He fought. He really fought. I can testify to this. But the

2 problem is the other side of the coin. The problem lies in all the

3 large-scale plundering that took place in the war and in which he was

4 implicated. Then there's his link with the former president of the

5 Republic of Serbian Krajina, Goran Hadzic ..."

6 What link did you have in mind there?

7 A. Between Hadzic and him?

8 Q. Yes.

9 A. Or the authorities in Serbia? Well, I saw on more than one

10 occasion that Arkan was appearing in various places together with

11 Goran Hadzic, and based on that, I concluded there were ties between

12 them. And then Arkan later imposed himself, thanks to Radovan Stojicic,

13 Badza, and he'd simply do as he pleased. He went wherever he wanted to.

14 He even attended sessions of the government of Slavonia, Baranja, and

15 Western Srem. He would come to the government session and nobody could

16 do anything about it. Nobody even dared asked him --

17 Q. Thank you. I --

18 A. -- why he had come. As for ties with the regime in Serbia -- oh,

19 you don't want me to say that.

20 Q. Mr. Seselj, I want you to slow down so I can catch up with the

21 translation.

22 I'd like to go back in time, back to 1990 when you were trying to

23 have the Serbian Chetnik Movement registered. You talked about that

24 yesterday.

25 MS. BIERSAY: At this time, if I could please have 65 ter 6611,

Page 11279

1 tab 137. And this is -- it was published in 1994 and it's dated 1990.

2 And in the English, if we could go to the third page. In the

3 English, could we have the next page, please, and the page after that.

4 Sorry, the next page, obviously. Thank you.

5 And in the B/C/S, if we could go to page 5, I think. Yes, at the

6 bottom.

7 Q. So, Mr. Seselj, this is the decision rejecting the application of

8 the political party, the Serbian Chetnik Movement. Now, at the bottom of

9 the page that you're looking at you can see the beginning of it, and when

10 you're finished looking at that, I can move to the next page. Can I --

11 A. Move to the following page, please.

12 MS. BIERSAY: And the same in English, please.

13 Q. Now, in the -- the statement of reasons, it's written here by the

14 deputy, the republican secretary, that:

15 "It is known from the recent history of Yugoslavia that members

16 of the Chetnik movement in World War II ended the war on the losing side

17 and their leaders were convicted as war criminals by people's courts

18 because of massacres and other forms of terror against the peoples of

19 Serbia, Montenegro, and Bosnia and Herzegovina.

20 "Believing that the submitted name offends public morals in the

21 Socialist Republic of Serbia, this secretariat has rejected the

22 application of the political party, the Serbian Chetnik Movement ..."

23 Is that what you meant yesterday by the Serbian Chetnik Movement

24 being denied registration? Is this the document you had in mind?

25 A. Yes, this is the document I had in mind.

Page 11280

1 MS. BIERSAY: At this time we'd move for the admission of

2 65 ter 6611.

3 JUDGE DELVOIE: Admitted and marked.

4 THE REGISTRAR: Exhibit P3257, Your Honours.

5 JUDGE DELVOIE: Thank you.

6 MS. BIERSAY: And if we could now move to tab 136, which is a

7 one-page document. And it is 65 ter number 6610. I now fast-forward to

8 1991.

9 Q. And now directing your attention to this, this, in fact, is a

10 decision registering the Serbian Radical Party in 1991; correct? Is this

11 the document you had in mind?

12 A. Yes.

13 MS. BIERSAY: And it's -- for the record, it's dated

14 12 March 1991. And at this time we'd move for admission of 65 ter 110.

15 JUDGE DELVOIE: Admitted and marked.

16 THE REGISTRAR: Exhibit P3258, Your Honours.

17 MS. BIERSAY: And just to let the interpreters know, the next

18 trio of clips that I'd like to play would be P88.50, and it would be the

19 .3 document that you have, and the .8 document you have. And then

20 Exhibit 2030. And then 65 ter 4936.1.

21 Q. Mr. Seselj, I'd like to talk about Slobodan Milosevic and your

22 relationship and the party's relationship with him. Now, in 1991, 1992,

23 and 1993, you and your party were receiving assistance from him; is that

24 correct?

25 A. We as a party never received any assistance from Milosevic.

Page 11281

1 However, the Milosevic's regime helped us sending volunteers to Serbian

2 Krajina. I told you how yesterday. Those volunteers had guaranteed

3 labour rights, even privileges, in their workplaces. The federal

4 authorities through the JNA provided additional guarantees.

5 As I explained yesterday, Milosevic's regime tried as hard as

6 they could to prevent successful mobilisation into the JNA. They feared

7 that the generals would take an opportunity to topple himself and

8 Tudjman. But he knew that he needed to help western Serbs. That's why

9 his regime helped the sending of volunteers as of September 1991, when

10 the volunteers of the Serbian Radical Party started joining JNA units.

11 Before September 1991 --

12 Q. So in the future when I -- if I'm tapping my headphone it means

13 that the interpretation needs to catch up to you. And if you could just

14 stop, let the interpretation finish and then continue, it would be

15 helpful.

16 A. Ms. Biersay, I noticed your signals, but I misinterpreted them.

17 I thought that they meant something entirely different. Now you have

18 made the thing clear.

19 MS. BIERSAY: If the interpreters are ready, we can proceed with

20 the playing of P88.50 and the first clip is -- will go from, I believe,

21 14:40 to 16:24. And the next clip will -- .8 will go from 37:41 to

22 38:48.

23 May I get a confirmation --

24 THE INTERPRETER: We are ready.

25 MS. BIERSAY:

Page 11282

1 Q. So, Mr. Seselj, if you please just listen and watch the video.

2 [Video-clip played]

3 THE INTERPRETER: [Voiceover] "Therefore, we were in direct

4 conflict with the regime and at that time Milosevic's policies were

5 prominently Communist. His reversal came as late as 1991, when we --

6 some communication was established between us, meaning that he came over

7 to our side instead of us coming over to his.

8 "LS: And how did you ... when you signed up those volunteers for

9 Knin, how did you obtain weapons, or how did they obtain them just in

10 case they needed to do something there?

11 "Seselj: We did not obtain weapons in 1990. We only signed up

12 volunteers and sent them on occasion if there was a need to do so, but

13 these were very small groups. In 1991 we began to organise greater

14 numbers of volunteers and to send them to the front lines that had

15 already been formed, particularly those in Eastern Slavonia and here in

16 the eastern part of the Republic of Serbian Krajina. Our volunteers

17 really proved themselves in the battle in Borovo Selo on 2nd May 1991,

18 when they overpowered the more powerful Croatian forces, the Croatian

19 police and parapolice forces. We received weapons from Milosevic's

20 police, first from the then-minister of the interior, Radmilo Bogdanovic,

21 and when he was replaced, from his successor. We also received old

22 weapons from the Territorial Defence depots. These were old American

23 Thompson rifles that had long been out of use, and old M-48 rifles, the

24 so-called Tandzare. These were all obsolete and the army had stopped

25 using them a long time ago, or had stored them in Territorial Defence

Page 11283

1 depots. They didn't want to destroy them completely so they simply gave

2 them to us. But it was these weapons that allowed us to defeat the

3 Croats who were armed with modern weapons."

4 MS. BIERSAY: And now moving to .8.

5 [Video-clip played]

6 THE INTERPRETER: [Voiceover] "LS: When you received those

7 weapons, did that ... you said that the regime gave weapons to your

8 party, I mean, the volunteers, was that in ... with the political

9 leadership's, with Milosevic's knowledge, or through the police and

10 through ...

11 "Seselj: This was all done with Milosevic's knowledge, there's

12 no doubt about that. And key people in the police with whom we

13 co-operated at the time were Radmilo Bogdanovic, Mihajl Kertes and

14 others ... Franko Simatovic, also known as Frenki, who later commanded

15 the Red Berets. From the General Staff, we mostly co-operated with

16 General Domazetovic, who was the deputy chief of the General Staff and

17 also at that time the head of the personnel administration, if I remember

18 correctly. There were also contacts with lower-ranking officers and so

19 on, depending on the need and the situation. Our volunteers came to

20 Belgrade, the barracks in Bubanj Potok. That is where we put on

21 uniforms, and where they were given weapons and buses to take them where

22 they wanted. They were under the command of the Yugoslav People's Army

23 as soon as the Yugoslav People's Army became involved in the fighting."

24 THE WITNESS: [Interpretation] Why did you interrupt the clip when

25 it became the most interesting? It is like watching a western movie and

Page 11284

1 somebody interrupts it at the moment of the showdown between the two

2 opposing -- opponents.

3 MS. BIERSAY:

4 Q. So it is true that Milosevic provided your volunteers with

5 assistance in 1991, 1992, and 1993?

6 A. Well, it's not as simple as that. There are two things that need

7 be to clarified. When you say "Milosevic," he usually personified the

8 regime itself. He was the most prominent politician in Serbia. His

9 party was the ruling party without any competition. So when we say

10 "Milosevic," we mean Milosevic's regime.

11 Second of all, I mystify things on purpose. For a number of

12 years I was hiding the real source of weapons, and I tried to confuse the

13 media. At my press conferences I used to claim that we imported weapons

14 from Hungary and with the help of a Hungarian minister. Here I involved

15 Milosevic's police in order to cover up who the actual source of weapons

16 was. And the true source of weapons was General Dusan Pekic. I didn't

17 mention his name in public before he died.

18 General Dusan Pekic had a huge authority in the JNA. He managed

19 to engage some officers and reach the depots where obsolete weapons were

20 stored, the weapons that were supposed to be destroyed. Those weapons

21 were delivered to us in the course of 1991, while we were still sending

22 our volunteers illegally and deploy them in many places. I say that our

23 volunteers were dispatched illegally before September 1991. As soon as

24 we made an agreement with the JNA, then we started enjoying the

25 assistance of Milosevic and the federal authorities. As for Milosevic

Page 11285

1 himself, I met him for the first time in April 1991 at a session of the

2 National Assembly. And the first time we spoke was in May 1991 in his

3 office.

4 MS. BIERSAY: If we could now move to tab 32, which is

5 Exhibit 2030. And that is a clip from 4773, which goes from 1 hour,

6 15 minutes and 31 seconds to 1 hour, 18 minutes and 20 seconds.

7 [Video-clip played]

8 THE INTERPRETER: [Voiceover] "When we announced that you and

9 Mr. Poplasen were going to be our guests tonight, there were a lot of

10 telephone calls and questions. However, one of the questions was asked

11 most frequently. It was about volunteers, the members and supporters of

12 your party, who were present in the territory of the ex-Croatia and the

13 ex-Bosnia and Herzegovina from the very beginning of the war as

14 volunteers. However, the viewers have the impression that this has been

15 running out of steam lately, as if some of the people and some of your

16 members and supporters have lost their interest in the fate of the Serbs

17 in Republika Srpska. Is it so, and are your volunteers still here and

18 are you, are they ready, I mean ...?

19 "Vojislav Seselj: This is a false impression. Firstly, our

20 volunteers are still there. They are with Chetnik Vojvoda Slavko Aleksic

21 at the Jewish Cemetery, with Vojvoda Vasko in Ilijas, with Vojvoda

22 Manda Maksimovic on Majevica ... there are also a number of volunteers

23 with Vojvoda Brne at Ilidza, then with Vojvoda Radovic in the area of

24 Velez and so on. There are many but there would be many more if the

25 Command of the Serbian army requested us to send volunteers. It is much

Page 11286

1 harder for us to send volunteers now than in 1991, 1992, or 1993. When

2 we were sending volunteers then, we had good co-operation with

3 Slobodan Milosevic. He used to give us uniforms, weapons, buses. He

4 granted the entire barracks in Bubanj Potok to the Serbian Radical

5 Party - everything, all the necessary equipment and it all used to be

6 functioning much better. Due to the treason committed by Slobodan

7 Milosevic, the Serbian Radical Party faces huge difficulties when sending

8 and equipping volunteers these days. Now our volunteers go in civilian

9 clothes to the areas where they are called from by some -- and we are

10 sending them by buses. They go through corridor, through Banja Luka.

11 The local Serbs already know that. We cannot talk about numbers, of

12 course. It is much harder for us to secure buses, the basic equipment

13 that has to be sent with the volunteers. The volunteers are provided

14 with weapons when they arrive. They put on uniforms there. Our

15 situation is so much more complicated and the process to prepare the

16 volunteers for departure is longer and harder. However, if the command

17 of the Serbian army so requests, we are fully capable of sending out

18 volunteers."

19 MS. BIERSAY:

20 Q. And, Mr. Seselj, this is another occasion that you referenced

21 sending volunteers and having good co-operation with Slobodan Milosevic;

22 correct?

23 A. Again, this is the regime personified. I told you when it was

24 that I met Milosevic for the first time. However, towards the end of

25 1991, if Milosevic had been against our volunteers, we would have been

Page 11287

1 prevented like we were until the end of summer 1991. His police tried to

2 prevent our departure so we had cross the Danube illegally.

3 I don't have the time to explain everything in detail. In any

4 case, Milosevic is the personification of the entire regime in Serbia and

5 the Federal Republic of Yugoslavia. That's how you understand to things.

6 It is not like Milosevic had a say in every little detail.

7 And now on to another matter and that is our volunteers. We are

8 still proud of them, to this very day we are.

9 Q. Mr. Seselj, thank you.

10 MS. BIERSAY: And if we could now play 65 ter 4936.1.

11 [Video-clip played]

12 THE INTERPRETER: [Voiceover] "It is the end of March, and the

13 year is 1995.

14 "Cheers!

15 "Vojislav Seselj is addressing the Serbs from Glina, only four

16 months before the operation Storm started.

17 "Seselj: Milosevic needed us both in 1991 and 1992. Besides,

18 Slobodan Milosevic was helping the western Serbian countries at that

19 time, Serbian Krajina as well as Republika Srpska, Serbian Krajina and

20 Republika Srpska were established with his help. Besides that, he gave

21 us, the Serb radicals, weapons for 30.000 volunteers we were sending off

22 to almost all battle-fields, where they were most needed. He also gave

23 us buses, uniforms, he put the whole barracks in Bubanj Potok at the

24 disposal of the Serbian Radical Party, for volunteers. We haven't

25 forgotten that. And also in the first days after the battle in

Page 11288

1 Borovo Selo when we were transporting the weapons across the Danube to

2 the Eastern Slavonia, on the rafts, by night. The weaponry we got from

3 the police warehouses and Serbian Territorial Defence warehouses pursuant

4 to Milosevic's order. We returned Milosevic the favour, we supported him

5 when he was having the toughest of times."

6 MS. BIERSAY:

7 Q. And this is again you discussing the assistance received from

8 Slobodan Milosevic in 1991 and, in this case, 1992.

9 A. I'm saying from September 1991 onwards. This was just one short

10 part of my speech. I am not happy that you censorship the speech of

11 Aleksandar Vucic, the prime minister of Serbia, who was there and he also

12 spoke.

13 Second of all, I am again explaining to people and I use

14 Milosevic to personify the entire regime because immediately after that I

15 attacked Milosevic. I am accusing him that he wanted to betray the

16 Republic of Serbian Krajina. The essence of that was: You were helping

17 us before and now you want to betray us. And that's -- we scheduled a

18 large protest rally on St. Vitus Day in 1995, on the 28th of June.

19 However, at the beginning of June, Milosevic's police arrested me in

20 Gniljane and kept me and Tomislav Nikolic in prison for two months

21 together with some of our associates.

22 When it comes to the personification of a regime, one person is

23 the entire regime. You don't think that Milosevic was the head of a

24 warehouse who could hand out the weapons himself. You don't think that

25 he was the commander of the barracks in Bubanj Potok. The JNA was in

Page 11304

1 September 1991 and after September 1991. In connection with this, she

2 also asked you about the contacts you had with Milosevic. I will read

3 out to you what was recorded in the transcript and please tell us whether

4 that is correct or not.

5 MR. ZIVANOVIC: It is page 47, lines 12 to 19:

6 Q. "Those weapons were delivered to us in -- in the course of 1991,

7 why we were still -- while we were still sending our volunteers illegally

8 and deploy them in many places. I say that our volunteers who were

9 dispatched illegally before September 1991. As soon as we made agreement

10 with JNA, we started enjoying the assistance of Milosevic and the federal

11 authorities. As for Milosevic, I met him for the first time in

12 April 1991 at a session of National Assembly. And the first time we

13 spoke was in May 1991 in his office."

14 [Interpretation] Did you really talk about this year 1991 as the

15 one when you first met Milosevic or was it a different year?

16 A. This is also deliberate falsehood because I said clear and loud

17 that I first met Milosevic in April 1992 and that I was first in his

18 office in May 1992 which was when we talked. 1992.

19 And in 1991, in April, I was not a member of parliament at all.

20 I was in a party that had no representatives in the parliament. This is

21 also a deliberate falsehood. It's obvious. The Prosecutor would like

22 that to turn out that Milosevic provided weapons to us when we went

23 illegally to defend Serbian villages. I have explained to you that

24 General Dusan Pekic was the one who procured all discarded weapons

25 through his friends, generals, and that he should get all the merit for

Page 11305

1 this.

2 Q. All right. I would like now to remind you about something that

3 the Prosecutor asked you yesterday, namely, your contacts with

4 Goran Hadzic from the moment when he arrived to the Detention Unit.

5 So please tell me whether you remember if there were any measures

6 prohibiting your communication with Goran Hadzic.

7 A. Yes. As far as I remember, there were. Whoever new arrived here

8 was prohibited from contacting me and I think it lasted for some months.

9 I'm not sure how many. I think we received this ban in writing. And

10 what the reason was, probably the Prosecution was afraid that I might

11 inform Mr. Hadzic about everything I knew and it was information that he

12 might be interested in, because I have learned many things here. And you

13 see what the problem with the Prosecution is. By definition, an

14 international prosecutor is administrator, an officer of international

15 justice, but his goal to determine the truth and not to arrive at

16 convictions. With equal care and effort, he has to collect evidence

17 which might end in conviction or in acquittal. And if an indictment is

18 issued against someone, here it's a question of life and death for them

19 to see that that person is eventually convicted.

20 Q. Again, today, earlier today, the Prosecution put to you an

21 excerpt from your evidence given in the Milosevic trial and part of your

22 closing arguments, the two of them being inconsistent. You have already

23 said something about this, but you tried to explain why you are better

24 informed now about the events at Ovcara, the hand-over of prisoners,

25 et cetera. You were trying to explain why you were better informed about

Page 11306

1 it all in 2012 than when you testified in Milosevic.

2 A. With my hunger strike in 2006 I achieved a number of important

3 things. First of all, I forced the Tribunal to rid me of Judge

4 Alphons Orie, who was violating my procedural rights, and to register my

5 legal advisors and enable me to have privileged communication with them.

6 Only then could I start my investigative work. Until then it wasn't

7 possible. I heard a little bit from here and a little bit from there,

8 but nothing really solid. This is the moment when my real investigation

9 began and when I began to receive reliable information. And the

10 information I was receiving from the field was for the most part

11 consistent with the evidence given by Prosecution witnesses. There were

12 many officers, including high-ranking officers such as colonels, who

13 testified that they had been in Ovcara all the time.

14 Q. In 2005, when you testified in the Milosevic case, you did not

15 have privileged communication with your legal advisors, did you?

16 A. For almost five full years, I did not have that kind of

17 communication. I sat here, wrote books, read, and I practically didn't

18 interfere in my own case because there was no sense in doing that while I

19 had a lawyer that was imposed on me. I needed to get rid of this lawyer

20 who was imposed on me, and I also had to get them to give me all the

21 documents in the Serbian language. I had to make them do all that, to

22 rewind the trial to the beginning, and to enable me to represent myself.

23 And thanks to achieving that, I absolutely shattered all the evidence led

24 by the Prosecution, including the indictment, et cetera.

25 Q. The Prosecutor showed you --

Page 11307

1 JUDGE DELVOIE: Mr. Zivanovic, you should be -- you should know

2 better than to start your next question before Mr. Seselj's answer is

3 interpreted. Please pay attention.

4 MR. ZIVANOVIC: Yes. Yes, Your Honour.

5 Q. [Interpretation] You have seen a video-clip footage depicting you

6 when you arrived in Vukovar. The Prosecutor showed it to you earlier

7 today. In that footage you were talking about the importance of

8 capturing Vukovar. On that occasion, you also visited the volunteers of

9 the Serbian Radical Party who were there. You were talking about whose

10 command they were under, et cetera.

11 I'm interested in this: While the volunteers of the Serbian

12 Radical Party in -- on the Vukovar front line, do you know who provided

13 them with ammunition?

14 A. There was a depot in the building of Velepromet held by the

15 military police, and that's where they got weapons, uniforms or parts of

16 uniforms to replace the torn ones, ammunition. They got there everything

17 they needed, including food. So supplies came from the same source for

18 the Guards Motorised Brigade, for guardsmen, for soldiers, and for

19 members of the Territorial Defence. There was no discrimination among

20 them.

21 Talking about that military police. In the same depot, the

22 military police was holding prisoners. That's why it was under their

23 control.

24 Q. Let us take a look at a letter sent by Ljubisa Petkovic.

25 MR. ZIVANOVIC: [Interpretation] It's 2650. [In English] Sorry,

Page 11308

1 just ...

2 JUDGE DELVOIE: Can we have a tab number, please.

3 MR. ZIVANOVIC: Sorry. It is -- it is 2576. Sorry, I'll try to

4 find it. It is -- sorry, it is 3556. P3556. Or ... no. No, no, no.

5 2625, 2625. Tab 38.

6 JUDGE DELVOIE: Is that on your list or the OTP's list,

7 Mr. Zivanovic? Tab number.

8 MR. ZIVANOVIC: Unfortunately, it is not this document. It is

9 2576. 2576. Tab 35.

10 JUDGE DELVOIE: 35. Your list or OTP's list?

11 MR. ZIVANOVIC: Ah, that's it.

12 JUDGE DELVOIE: I see it now. It's the OTP's list.

13 MR. ZIVANOVIC: Yes, it is on OTP list.

14 JUDGE DELVOIE: Yes.

15 MR. ZIVANOVIC: [Interpretation]

16 Q. Would you kindly tell us, this letter that has already been shown

17 to you by the Prosecution, was this letter sent with those volunteers who

18 were going to the front line or was it sent independently of them? Can

19 you remember?

20 A. I also saw this document for the first time here. I don't think

21 it's particularly important. I think it was done -- I mean, it was sent

22 in this way in this particular case, whereas other letters were sent by

23 different channels. It is said here that it is addressed to the

24 commander of the Leva Supoderica Detachment, that this group was under

25 the command of Slobodan Katic. It is suggested that they be given two

Page 11309

1 extra days. Is it what it says here? It's difficult for me to read.

2 Q. Yes, it's a bit small.

3 A. What I'm trying to say, it's not some kind of prototype or

4 template.

5 Q. On page 29, a document was shown to you about the movements of

6 Croatian and Serbian population, and you mentioned 300.000 refugees. How

7 are you able to know this figure? And what position did you occupy then?

8 How did you know that there were 300.000 refugees at that time in Serbia?

9 A. I knew the figure of 250.000 refugees at that moment, and these

10 statistics were constantly updated, though those were official

11 statistics. And the authorities kept publicising the figure, and we

12 didn't even need those statistics because the whole of Serbia was awash

13 with refugees.

14 Q. Considering that you were also a Member of Parliament at that

15 time in the Republic Assembly and the Federal Assembly, were these

16 figures officially known to the authorities?

17 A. Not only were they known --

18 JUDGE DELVOIE: Mr. Seselj, I hoped that when I told

19 Mr. Zivanovic that he had to respect a pause between your answer and his

20 question, I hoped that you would pick up and remember that you also have

21 to respect a pause between his questions and your answer. Because if

22 not, it is very difficult for the interpreters to have your -- your

23 statement exactly on the record. Thank you.

24 MR. ZIVANOVIC: [Interpretation]

25 Q. Could you please continue.

Page 11310

1 A. Not only did the state authorities know this data, it was

2 broadcast on television and published in newspapers. As the number of

3 refugees grew, it was constantly publicised how many of them there were.

4 It was no secret.

5 Q. On page 35, you said in response to certain questions put to you

6 concerning Zeljko Raznjatovic, Arkan, that he had been in negotiations

7 with the Office of the Prosecutor. Could you tell us where did you get

8 that information?

9 A. For the first time, I heard that on Croatian television. And

10 then in the proceedings against me, I filed a request, a motion, that the

11 OTP share with me all the documents they have on the subject. The

12 Prosecutor started to object and oppose my motion, to explain that it has

13 nothing to do with my case or the evidence against me. You can find that

14 in the transcript. It's obvious they had some dealings with Arkan, which

15 were probably left incomplete because Arkan was killed in Belgrade on

16 15 January 2000, because two high police officials were killed together

17 with him, because they just happened to be there when the murderer walked

18 in on them.

19 Q. Did you get any official response from the OTP?

20 A. No, I have not. They are hiding these documents. And if memory

21 serves me well, the Prosecutor even said something like: None of that is

22 in the form of official documents, they are unable to provide me with

23 their work notes, et cetera. They were making all sorts of excuses.

24 Q. On page 36 of the transcript, document 1743 was shown to you.

25 You will probably remember the document contains a reference to the army

Page 11311

1 needing to cleanse, to purge its ranks. What exactly did you mean? How

2 should the army purge its ranks? From whom?

3 A. First of all, there were many spies in the army, mainly Croats,

4 officers, who, every now and then, would pack a full boot of their cars

5 with confidential papers and drive off to Croatia.

6 Second, it needed to be purged of die-hard Communists who had no

7 fighting skills, no soldierly skills, and constantly carried out

8 indoctrination in army ranks and prevented the army from doing its job

9 properly. And as long as they were there, the people would not respond

10 to mobilisation drives.

11 And the first such cleansing started in May 1992, when the army

12 was led by Blagoje Adzic. And then we managed to get the army to replace

13 another 40 leading men in August 1993, including Zivota Panic, who was

14 involved in some sort of corruption scandal. But among the people we

15 wanted to eliminate, the regime also included in that list some people

16 whom they wanted to get rid of, accusing them that they were close to us,

17 the radicals, and they wanted to get rid of them for that reason. That

18 was a month or two before we began our final showdown with the Socialist

19 Party and Slobodan Milosevic.

20 I remember that I demanded in the National Assembly, in the

21 Federal Assembly, the replacement of the chief of the military security

22 service, Aleksandar Dimitrijevic and - what is the name of that spokesman

23 of the army? - Ljubodrag Stojadinovic. I threatened that we, the

24 radicals, would not vote for the rebalancing of the budget, for the

25 adjustment of the budget, unless they meet our demands and replace these

Page 11312

1 two people. And then the regime blackmailed or bribed a number of our

2 MPs and thus managed to get a majority in the Federal Assembly. So our

3 demand to replace these two colonels was not met.

4 Q. Can you tell us -- you said in the first batch about 40 people

5 were replaced, and in the second one another 40. Out of all of these

6 replaced people how many were Serbs?

7 A. Most of them were Serbs. You see, we used to say: Out of all

8 the Communists, the worst one are Serb Communists.

9 Q. In a nutshell, the shakeup in the army, was it supposed to be on

10 ethnic grounds or on some other grounds?

11 A. It was not on ethnic grounds but it was well known which Croatian

12 officer was a spy, which was leaking secrets, who was sending documents.

13 But in any case, most of them had fled before the shakeup. Only two or

14 three were still in their positions when the purges started. Most of the

15 Serbs who were removed were removed due to the membership in the League

16 of Communists, because of placing hindrances before the attempts of the

17 Serbian people to defend themselves, for incompetence, and so on and so

18 forth.

19 Let me tell one thing. On the 4th of May, 1991, the Serbian

20 Radical Party in Belgrade held a rally in front of Tito mausoleum. Tito

21 is the former Communist dictator of Yugoslavia. The official name of our

22 rally was March on the Flower House and the official demand that we put

23 forth was for Tito's mausoleum to be moved away from Belgrade. We had

24 applied for permission to hold that rally with the police. The police

25 did not prohibit it. We had people in charge of peace and order, and

Page 11313

1 there were no incidents at all. In the beginning of May 1991, the JNA

2 General Staff was on red alert. They did not want us to interfere with

3 the image of their Supreme Commander and the then-Colonel Sljivancanin

4 placed machine-gun nests around Tito's grave and on surrounding buildings

5 there were snipers deployed. If we were to start destroying the

6 mausoleum, they were going to kill us all.

7 Sljivancanin confirmed it on several occasions here in this

8 Tribunal. He never hid the fact. I believe that in his book that he

9 published after having been released from prison he spoke about that.

10 The title of the book, "I was defending the truth," is ironic because he

11 never told the truth, he never wrote the truth. In the book he only

12 speaks about his fellow prisoners, what people cooked, what games they

13 played, how they dressed, and so on and so forth, below any threshold of

14 dignity in any case.

15 Q. You also said on page 38, inter alia, that you filed another

16 criminal report against Arkan and that that was sometime in 1991 or 1992

17 or thereabouts. You said that it would amount to nothing.

18 Can you tell us very briefly when that was, who did you file the

19 report with, and who told you that it would amount to nothing?

20 A. In Belgrade there was a person called Iso Lero. He was a member

21 of the Roma people and he was the owner of a security agency. He was in

22 the casino in the building of Beogradjanka in the very centre of

23 Belgrade. You know it very well, don't you. He got drunk and he saw

24 Arkan's poster or Arkan's photo. He pulled out a pistol and opened fire

25 at the photo. When Arkan heard that, he sent a group of his men to find

Page 11314

1 him. They located them, indeed. They kidnapped him and they brought --

2 took him to Slavonia, to Erdut. And there Arkan kept him, tortured him,

3 beat him for a while, and then he ordered that he should be killed. They

4 pored concrete over his legs and they threw him into the Danube.

5 One of Arkan's men that defected from Arkan's unit came to me and

6 told me all that. With the help of -- of our volunteers I provided him

7 with the shelter. He gave a statement, he described the whole event. I

8 found him a shelter in the interior of Serbian -- I believe that he spent

9 some time with Novak Savic in Loznica. He was a member of the Serbian

10 Radical Party. And I also filed a criminal report with the police. The

11 senior police inspector came to me, to the seat of the Serbian Radical

12 Party. He told me that they already knew about that but they didn't have

13 any capabilities or courage to do anything against Arkan.

14 For example, in 1991, 1992, 1993, Serbia was intersected by

15 police check-points. On every road there was one. Everybody had to

16 stop. Their IDs were checked. Their vehicles were inspected because

17 there was a constant fear of terrorist actions and the like. Arkan could

18 zoom in through those check-points, never paying any heed to the police.

19 Not a single policemen could tell him anything, and many police officers

20 even grovelled up to him. The only person that Arkan feared to a certain

21 extent was Radovan Stojicic, Badza. When Radovan Stojicic, Badza, was

22 killed --

23 JUDGE DELVOIE: Mr. Zivanovic?

24 MR. ZIVANOVIC: Yes.

25 JUDGE DELVOIE: Do you still remember the question you put to the

Page 11315

1 witness?

2 MR. ZIVANOVIC: Yes. Yes, Your Honour.

3 JUDGE DELVOIE: Okay. That's good.

4 MR. ZIVANOVIC: [Interpretation]

5 Q. I believe that you have answered my question. We don't have to

6 go into further detail.

7 One more question within that context was about your claim that

8 Arkan and Goran Hadzic were in cahoots. We can look at it on the screen.

9 However, I read that part of your book. You said "the former president

10 of Serbian Krajina." That's how you described Goran Hadzic.

11 When this was written, what was your relationship with

12 Goran Hadzic at the time?

13 A. The relationship was hostile, absolutely hostile. I believe that

14 that was in 1994. In 1993, I attacked him verbally at the general

15 Serbian Assembly in the Sava centre at the beginning of May. And in

16 November 1993 with -- a group of other officials of the Republic of

17 Serbian Krajina attacked me in writing and the entire Serbian Radical

18 Party and so on and so forth. So then there was a lot of hostility.

19 There was no love lost between the two of us.

20 And the foundation for the claim about us being in cahoots was

21 the fact that Hadzic appeared in public together with me in the same

22 photos but -- with Arkan. But my subsequent investigations revealed that

23 Arkan imposed themselves on anybody. He, for example, took a petrol

24 station near Erdut and proclaimed it his. When Badza left Slavonia, he

25 took over the training centre in Erdut and nobody dared approach it from

Page 11316

1 then on, neither the military or the police. In 1991 he entered the

2 session of the government and sat down, and none of the ministers dared

3 asked him what he was doing there. He got involved in any debate and

4 started talking nonsense. So nobody could do anything to him. The only

5 person in all of Serbia, in the entire Serbian people, who had the

6 courage to confront Arkan publicly and directly was myself.

7 Q. I wanted to ask you - you will find it on page 41 - you were

8 shown an exhibit from the Prosecutor's list pursuant to Rule 65.

9 MR. ZIVANOVIC: [Interpretation] 6611. Tab 137. It is P3257.

10 That's how it was admitted. Or perhaps 32 --

11 JUDGE DELVOIE: Mr. Zivanovic?

12 MR. ZIVANOVIC: [Interpretation] -- or perhaps 3258.

13 JUDGE DELVOIE: Please convey to the witness the court reporter's

14 note.

15 THE WITNESS: [Interpretation] I see it, Mr. President. I've

16 taken note. I'll try to do what I can.

17 JUDGE DELVOIE: Thank you.

18 MR. ZIVANOVIC: [Interpretation] I'd like to call up P3258.

19 I'm sure that this is not the document that I need.

20 Q. I'll try to put a question to you without the document. I can't

21 find the page that I need. It is about a decision by which your

22 application to register the Serbian Radical Movement was denied. I am

23 sure that you remember that was shown to you earlier today. Actually, it

24 was the registration of the Serbian Chetnik Movement.

25 You said -- you saw in the statement of reasons that this was

Page 11317

1 done because they were defeated during -- in the Second World War and

2 national courts had decided that they had committed crimes against

3 various ethnic groups.

4 What national courts were in question or people's courts?

5 A. When the decision was issued about our registration being denied,

6 the regime was still fully Communist and all the ministers were Communist

7 ministers. The elections took place only in December of that year. Even

8 after the elections, the regime could not get rid of its Communist chains

9 for quite a while. The decision on denying our application is full of

10 Communist prejudices.

11 People's courts never tried any Chetniks. They tried -- the

12 courts that tried them were Communist courts and they executed most of

13 the Chetniks. They court-martialed them and summarily executed them.

14 When Drazen Mihajlovic was put on trial, the two-tier principle was

15 encroached. He was -- the sentence was passed one day and the following

16 day he was executed. He did not have the right to appeal. The only

17 thing that he could do was to apply for pardon within a couple of hours

18 and that was all.

19 In any case, the Communists rely on the experience of the

20 Nuremberg trials. There also there was no right of appeal. The

21 sentences were passed and the accused were executed. I'm not sorry that

22 they were executed. I would have done it without a trial. But basic

23 legal principles had to be honoured even with respect of the most serious

24 criminals.

25 And now back to the Chetnik movement. It was indeed defeated in

Page 11318

1 the Second World War but that was due to -- the Churchill's treason and

2 the treason --

3 JUDGE DELVOIE: Mr. Seselj, as Mr. Zivanovic doesn't intervene,

4 although his time is almost completely over, I'll do. You probably don't

5 remember the question anymore, but you answered the question.

6 MR. ZIVANOVIC: That's correct, Your Honour, and I --

7 THE WITNESS: [Interpretation] Mr. President, I remember the

8 question very well. The question was about people's courts that

9 allegedly tried Chetniks.

10 JUDGE DELVOIE: So then please --

11 THE WITNESS: [Interpretation] I am getting on, but I'm not that

12 old not to remember a simple question.

13 JUDGE DELVOIE: Okay. Then the problem is not your memory, but

14 the problem is your talkativity, perhaps.

15 Mr. Zivanovic, how many questions do you --

16 MR. ZIVANOVIC: I've just finished.

17 Q. [Interpretation] Thank you, Mr. Seselj. I have no further

18 questions for you.

19 JUDGE DELVOIE: Thank you.

20 Yes, Mr. Terzic.

21 MR. TERZIC: [Interpretation] Mr. President, with regard to

22 today's session, I would like to point out a procedural problem. During

23 the previous break this was already raised in the record. We read parts

24 of the record from the Seselj trial which does not contain all the

25 elements that should have been recorded. There seems to be a problem