Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12057

 1                           Tuesday, 25 November 2008

 2                           [Open session]

 3                           --- Upon commencing at 2.18 p.m.

 4                           [The accused entered court]

 5             JUDGE ANTONETTI: [Interpretation] Madam Registrar, please call

 6     the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon,

 8     everyone in and around the courtroom.

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

10     Vojislav Seselj.

11             JUDGE ANTONETTI: [Interpretation] Today is Tuesday.  Good

12     afternoon to the OTP representatives.  Good afternoon to Mr. Seselj and

13     to the witness, who is going to testify through a videolink.

14             I'm going to ask the Registrar to move into private session

15     first.

16                           [Private session]

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Page 12058











11 Page 12058 redacted. Private session.















Page 12059

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16                           [Open session]

17             THE REGISTRAR:  We are in open session, Your Honours.

18             JUDGE ANTONETTI: [Interpretation] Very well.

19             Sir, can you please state your first name, last name and date of

20     birth.

21             THE WITNESS: [Interpretation] Please, Judge.  My lawyer did

22     receive an invitation from the Tribunal to attend.

23             JUDGE ANTONETTI: [Interpretation] I do not know your lawyer,

24     myself.  He is not a witness.  So there is no reason why your lawyer

25     should attend.  If your lawyer was summoned by this Tribunal, that's part

Page 12060

 1     of another case, in front of another Trial Chamber.  The only person I

 2     know is you, you as a simple witness who does not need counsel.

 3             Please state your first name, last name, and date of birth.

 4             THE WITNESS: [Interpretation] Aleksandar Stefanovic, the 19th of

 5     May, 1953.  Zabari, Valjevo.

 6             JUDGE ANTONETTI: [Interpretation] What is your current

 7     occupation?

 8             THE WITNESS: [Interpretation] At the moment I have a fruit and

 9     vegetable processing factory in Central Serbia in a place called

10     Smederevska, Palanka.  The factory is called Voce.

11             JUDGE ANTONETTI: [Interpretation] Very well.  Have you ever

12     testified before a tribunal or is it going to be the first time today?

13             THE WITNESS: [Interpretation] I think I did appear in a certain

14     proceedings before domestic courts.

15             JUDGE ANTONETTI: [Interpretation] Were these proceedings related

16     to the events that took place in the former Yugoslavia or was it about

17     something else?

18             THE WITNESS: [Interpretation] I assume you mean the other trials.

19     No, it wasn't in connection with the other trials, the first thing you

20     said.

21             JUDGE ANTONETTI: [Interpretation] Excellent.

22             The Registrar is probably sitting next to you.  He's going to

23     show you the solemn declaration.  Please read it out.

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

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

Page 12061

 1                           WITNESS:  ALEKSANDAR STEFANOVIC

 2                           [The witness answered through interpreter]

 3                           (The witness testified via videolink)

 4             JUDGE ANTONETTI: [Interpretation] Thank you, sir.

 5             Let me tell you how we are going to proceed today.

 6             You will first have to answer questions by the Prosecutor.  In

 7     this particular case, I believe that Ms. Dahl will conduct the

 8     examination-in-chief.  She'll tell us later on how much time she will

 9     need.  The three Judges sitting in front of you may at any moment ask

10     questions, and Mr. Seselj, who is the accused in this case - I don't know

11     if you're able to see him at this precise minute - will also ask you

12     questions as part of the cross-examination.  He is entitled to do so.

13             Ms. Dahl, how much time will you need to examine this witness?

14             MS. DAHL:  I would respectfully request two hours, and I will

15     endeavour to complete my examination faster than that.

16             JUDGE ANTONETTI: [Interpretation] Very well.

17             Ms. Dahl, you may proceed and conduct your examination-in-chief.

18             MS. DAHL:  Your Honour, before I begin to question the witness, I

19     wanted to put on the record that I was advised that when the witness

20     arrived at the Belgrade liaison office, he demanded compensation as a

21     condition for his testimony, which was disturbing, because there is no

22     payment for testimony.  Regulations apply to afford witnesses per diems

23     and there is no additional payment, and I'd like that to be clarified by

24     the Chamber with the witness before I begin my examination.

25             JUDGE ANTONETTI: [Interpretation] Witness, in your country and in

Page 12062

 1     my country, when you go and testify before a court, your daily expenses

 2     are reimbursed.  Is that what you were requesting earlier on?

 3             THE WITNESS: [Interpretation] I don't know what the Prosecutor is

 4     saying.  I asked for per diems.  "Per diems" means remuneration, money

 5     remuneration for the time spent testifying, so that's all I asked for.  I

 6     don't know if that's clear.  And we had a discussion over that which

 7     lasted over an hour.  They said, "Yesterday, today, tomorrow, never."  I

 8     don't know what all this is about, but I think in your country, as in my

 9     country, that's how things stand.  You receive financial reimbursement,

10     per diems.

11             JUDGE ANTONETTI: [Interpretation] I am going to ask the Registrar

12     to tell me how much money you're entitled to, precisely, and I'll let you

13     know later on.

14             Ms. Dahl, please proceed with your examination-in-chief.

15             MS. DAHL:  Thank you, Your Honour.

16             May I ask the Registrar in Belgrade to please present the witness

17     with the statement that he signed dated 12 June 2006.  It is in the

18     witness binder that accompanied the Registrar to Belgrade.  It has label

19     7147 in the binder, which is the 65 ter number necessary to upload the

20     document in e-court.

21             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, the witness has been

22     shown the document.

23             MS. DAHL:  Let me correct the record.  I transposed the numbers.

24     The document number is 7417.

25             Let me clarify.  The Chamber has lifted the requirement to use a

Page 12063

 1     pseudonym with this witness; is that correct?

 2             JUDGE ANTONETTI: [Interpretation] Yes, indeed, because this

 3     witness testifies without any protective measures.

 4                           Examination by Ms. Dahl:

 5        Q.   Mr. Stefanovic --

 6        A.   I don't understand what all this is about.

 7        Q.   Mr. Stefanovic, would you please look at the document 7417 that's

 8     in front of you, and tell me if you recognise your signature on the

 9     document.

10        A.   Yes.  Yes, but if we want to discuss signatures and documents, I

11     have to say this first, and I started raising the issue a moment ago and

12     telling the Judge what I had to say.

13             JUDGE ANTONETTI: [Interpretation] What is this all about?  What

14     is this preliminary issue?

15             THE WITNESS: [Interpretation] It's this:  As I started to tell

16     you, when there was an investigation or whatever, proceedings or

17     whatever, against Vojislav Seselj, I think -- I think that at the

18     beginning, in 2003, I think that's when it started, although possibly I

19     might be wrong, but, anyway, I didn't pay attention to the date.  I

20     didn't think it was an important date in my life.

21             But, anyway, I was a member of the Republican Parliament at the

22     time, just like Mr. Seselj.  We were in different parties and different

23     political options, but since 1999 I, myself, joined the parties of the

24     so-called DOS, the Demo-Christian party or Christian Democratic Party,

25     led by Vladan Batic in the government of Dr. Zoran Djindjic.  He was

Page 12064

 1     Minister of Justice in that government.  And there was quite a lot of

 2     talk about how we could put a stop to the Radicals, their actions.  And

 3     from the information of the Assembly, the Parliament that was set up in

 4     January and served 2001, straight out to the elections held on the 23rd

 5     of December, in fact, 1990, the parliamentary majority, which made up a

 6     combination of 18 parties, rallied together and started discussing the

 7     changes in the protocol of the Assembly.  It's a sort of mini-law, if

 8     I can use that term, a code of conduct that was binding upon the deputies

 9     of the Parliament of Serbia; what rights they had, what duties they had,

10     how they could act, how they could be eliminated from the parliamentary

11     sessions if they violated the code of conduct.

12             And I remember that after the elections -- immediately after the

13     elections, within the Parliament, as I say, immediately after the

14     elections, a so-called body was set up which was called the Women's Group

15     or -- what's it in English, Women's something.  Anyway, that's what it

16     was called, and they were the most active in that respect.

17             What they wanted was this:  They wanted, through the code of

18     conduct of the republican Parliament, or the rules and regulations of

19     that Parliament, in a way to curtail -- or, rather, prevent the Radicals

20     from obstructing work.  I don't know if you know what I mean when I say

21     "obstruction," but, anyway, during the session --

22             JUDGE ANTONETTI: [Interpretation] Well, Witness, please get to

23     the point.  What's your point?

24             THE WITNESS: [Interpretation] I'm coming to my point,

25     Your Honour.  For me to make my point, I have to tell you the

Page 12065

 1     preliminaries so that you can understand what I'm talking about and my

 2     position at the point in time when, quite apart from my own will, I

 3     become something -- well, I don't know what I become.  I become somebody

 4     being examined and interviewed by The Hague Tribunal or the Prosecutor,

 5     so it was against my will that I went to The Hague Tribunal to give my

 6     statement, not a statement that I'm going to testify about, but a

 7     statement, having been told to do so by Dr. Zoran Djindjic, who had an

 8     agreement with the then Prosecutor of the Hague Tribunal, Carla

 9     Del Ponte, so it was an agreement between them.  And these were not

10     people who were without authority, might I say.

11             So, anyway, if you think that there is a written or unwritten

12     trace, there are witnesses to that.  There is Vladan Babic, the then

13     minister, for instance.  Then I'm going to tell you how the conversation

14     evolved, how it was conducted.

15             When the prime minister told me, I said, "You know, Mr. Djindjic,

16     I don't know whether Seselj -- or that Seselj --"

17             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, the --

18             THE WITNESS: [Interpretation] Allow me to finish what I was

19     saying, please.

20             JUDGE ANTONETTI: [Interpretation] Yes, but the Prosecutor is

21     objecting.  The witness is challenging his own testimony of the 6, 7 and

22     12 February 2003.  He's telling us this was all part of a political

23     agreement between Mr. Djindjic and Ms. Carla Del Ponte.

24             Witness, we get your point.  At least I understand what you were

25     telling us.  Let's then see what is the content of your statement.

Page 12066

 1             Ms. Dahl, you have the floor.

 2             MS. DAHL:  Thank you, Your Honour.

 3        Q.   Mr. Stefanovic, let me turn your attention to page 24 of your

 4     June 16, 2006 statement.  In B/C/S, the ERN stamped on that document is

 5     0601-2454.  Let me ask you to turn to that page, and tell me if you

 6     recognise your signature above the date.

 7        A.   Yes, without a doubt, they're my signatures.  But I'd like to

 8     explain, if that's at all important for the Court, how it came -- how

 9     these signatures came about.

10        Q.   Let me ask, Mr. Stefanovic, first that you please read the

11     acknowledgment that you signed, beginning with the statement consists --

12        A.   That's precisely what I'm doing now.

13        Q.   Okay.  Please read the paragraph.

14        A.   "This statement contains --" is this all right?  It doesn't say

15     "confirm."  It says:  "This statement contains or consists of 28 pages,

16     has been read over to -- has been read in Serbian."  No, that's not true.

17     It's never been read in Serbian, nor have I ever read this.  This is the

18     first time I'm looking at this.  I read it in the Serbian language, my

19     mother tongue, and it is true to the best of my knowledge and

20     recollection.  Well, I have given this statement voluntarily.  I'm aware

21     that it may be used in legal proceedings before the International

22     Criminal Tribunal for the prosecution of persons responsible for serious

23     violations of international law committed in the territory of the former

24     Yugoslavia since 1991 and that I may be called to give evidence in public

25     before the Tribunal.

Page 12067

 1             Now, Madam Prosecutor, I wish to state --

 2        Q.   I'm sorry.  I'm asking the questions and you're giving the

 3     answers, so Mr. --

 4        A.   I haven't read this.  No, this statement is not correct.

 5        Q.   I'm sorry.  You just identified your signature on the document,

 6     and --

 7        A.   My answer is that it is not correct.

 8        Q.   Let me confirm that you have in front of you the original Serbian

 9     document bearing your signature on page with the ERN number 0601-2454.

10     Do you have that page in front of you?

11        A.   Well, it's probably this one, yes.

12        Q.   Not "probably."  "Yes," or "no"?

13        A.   I said, "Yes."  I've already said that.

14             MS. DAHL:  Madam Registrar, let me ask you to give Mr. Stefanovic

15     his 2003 statement, and you'll find that in his binder at document 7416.

16     That's the 65 ter number given to the document to allow it to be

17     up-loaded into e-court.  The original was signed in English on 12

18     February 2003.  So if you can give him both the English and the B/C/S

19     translation to enable the witness to read the document.

20        Q.   And let me ask you to turn to, first, the front page and tell me

21     if you recognise your signature on that document.

22        A.   Yes, but we're not only talking about this signature.  Probably

23     the signature is right, but I'd like to discuss the previous document.

24     We didn't finish discussing that.

25        Q.   Mr. Stefanovic, let me ask you to please answer my questions.

Page 12068

 1     You'll have an opportunity to explain, but I want to get the information

 2     that the Chamber needs about this so-called agreement out first.

 3             Let's go to the last page before the interpreter's certification

 4     and ask you to please look at the English page with the ERN number

 5     0119-1880 and find your signature under the date 12 February 2003.  Tell

 6     me if you recognise your signature, please.

 7        A.   It's like this, Madam Prosecutor:  Let me make things clear.

 8     This is my signature, and most probably -- may I be allowed to explain,

 9     please?  It's very important, because the answer is both "yes" and "no,"

10     and I have to explain.

11        Q.   It's either your signature or it's not your signature.

12             THE ACCUSED: [Interpretation] Mr. President, you never allow

13     me -- I have an objection.  You never allow me to interrupt the witness

14     to stop what he's saying, and you always insist that the witness has the

15     right to state what he wants to state fully.  So I demand that you act in

16     the same manner when the Prosecutor is doing the examining.

17             JUDGE ANTONETTI: [Interpretation] Witness, obviously you are now

18     a hostile witness, hostile to the OTP.  That's quite obvious.

19             You will, in due course, give us all the necessary explanation.

20     For the time being, I'm going to ask you to answer the questions put to

21     you by the Prosecutor by "yes" or "no."  Later on, I can assure you that

22     you will have all the time necessary to tell us under what circumstances

23     you signed this document.  But now we are just asking you to answer a

24     basic series of preliminary questions; yes, you signed this document, and

25     we'll talk about the circumstances later.

Page 12069

 1             Ms. Dahl.

 2             THE WITNESS: [Interpretation] Judge, Your Honour, I can't

 3     continue before I am allowed to explain something to you.  Just two

 4     sentences, please.

 5             It is absolutely incorrect, you can ask the official of the

 6     Tribunal here, the clerk of the Tribunal, I'm not angry at all either

 7     towards the Prosecutor, or towards you, or towards the accused Seselj.

 8     I'm saying this quite calmly, and I'm saying it under oath.  I'm a

 9     Christian, Your Honour, and I have pledged in my church to always tell

10     the truth, which I will do.  So at this point in time, I'm taking very

11     great care about what I'm saying, and far from it, may God forgive me

12     that I have any hostile sentiments toward Madam Dahl, whom I met in

13     Belgrade in these same premises here.  She left a very good impression on

14     me.  We discussed some very -- had a very nice conversation.  We

15     discussed some pleasant memories that I have, and I very often like to

16     recount when I meet my friends.  So I don't have a single reason for not

17     liking the Prosecutor, especially so as we spent an hour and a half here

18     together and I tried to have my rights respected that I would get

19     financial recompense for the time I'm losing here.

20             So you're not going to have a problem with me, in the sense of me

21     hating anybody.  I don't.  So I find it a little unpleasant to hear what

22     I'm hearing now.

23             JUDGE ANTONETTI: [Interpretation] Mr. Stefanovic, when did you

24     meet the Prosecutor, because that's the first time I hear from it.  I

25     thought you'd completely disappeared.  When did you meet the

Page 12070

 1     representative of the Office of the Prosecution?

 2             THE WITNESS: [Interpretation] Countless times.  Maybe I'm mixed

 3     up.

 4             I'm Aleksandar Stefanovic.  I never hid from the Court.  I always

 5     responded to every summons.  I always came here.  So how could I have

 6     gone missing?

 7             JUDGE ANTONETTI: [Interpretation] When was the last time you met

 8     the representative of the Office of the Prosecution?

 9             THE WITNESS: [Interpretation] Oh, it's a problem for me to recall

10     the exact time, but I think -- I'm not sure exactly when it was.  I can't

11     recall.  But I know very well that we had a polemic -- she comes from

12     another civilization, from America.  We wanted to define what a crime

13     was.

14             Napoleon is characterized by history as a positive personality,

15     whereas Hitler is categorised as a very negative personality, and yet

16     these two men did very similar things in their lives.

17             We discussed the fact that my son, after the bombing by NATO, got

18     cancer of the lymph glands due to the radiation, and I had two or three

19     years of agony during the medical treatment of my child, which

20     fortunately ended well, but this agony is still ongoing.  The

21     consequences are quite incredible.

22             I spoke of the responsibility of the leaders of the NATO pact,

23     Wesley Clark, Jamie Shea and others who used depleted uranium and used

24     this for an air strike against Serbia.

25             Let me finish.

Page 12071

 1             JUDGE LATTANZI: [Interpretation] Sir, why aren't you responding

 2     to the question asked to you by the Presiding Judge?  When did you meet

 3     with Ms. Dahl?  He didn't ask you about the content of the conversation.

 4     He asked you when you met her and how many times.  Could you please

 5     provide an answer to this question?

 6             THE WITNESS: [Interpretation] A few months ago, I was on these

 7     premises with Madam Dahl, before that with a gentleman called Sax

 8     [as interpreted].  I think he was a Prosecutor also.  That might have

 9     been a year and a half ago with Sax, but only a few months ago with

10     Madam Dahl.  That's my response.

11             JUDGE ANTONETTI: [Interpretation] Very well.

12             Ms. Dahl, you may proceed.

13             MS. DAHL:  Your Honour, the date that I met with Mr. Stefanovic

14     preceded the opening of the case.  It was September 18, 2007.

15        Q.   Now, Mr. Stefanovic, on your statement dated 12 February 2003 --

16             THE ACCUSED: [Interpretation] Objection.  Madam Dahl does not

17     have the right to testify, until you ask her a question.  She can only

18     ask questions of witnesses.

19             JUDGE ANTONETTI: [Interpretation] Since the witness could not

20     remember the date, Ms. Dahl, who was taking part in the meeting,

21     specified the date instead of him.

22             18th of September 2007 or 2008, Ms. Dahl?

23             MS. DAHL:  2007, Your Honour.

24             JUDGE ANTONETTI: [Interpretation] Witness, Ms. Dahl indicated

25     that she last met with you on the 18th of September, 2007.  Do you agree

Page 12072

 1     with that?

 2             THE WITNESS: [Interpretation] I don't know when it was, but it's

 3     possible it was on that date.  And that's what we discussed.  She said

 4     she had completed primary school in Boston.  We had a very nice chat, in

 5     fact.

 6             Your Honour, just something -- may I say something, please?

 7             JUDGE ANTONETTI: [Interpretation] Mr. Stefanovic, you're here to

 8     answer questions.  Please let Ms. Dahl ask questions to you.  Then it

 9     will be the Judges' turn, and we'll clarify the points that deserve some

10     clarification.

11             Please proceed, Ms. Dahl.

12             MS. DAHL:

13        Q.   Mr. Stefanovic, you signed your 2003 statement on 12 February

14     2003; correct?

15        A.   Yes.

16        Q.   In the witness acknowledgment directly above your signature, it

17     states that you may be called to give evidence in public before the

18     Tribunal; correct?

19        A.   Yes, but that's in English.  I don't speak English.  I speak

20     German very well, I speak Serbian and I speak Russian, but I don't speak

21     English, so even now I don't know what this says.

22        Q.   Can you look at the interpreter certificate that follows on the

23     last page of the 2003 statement, and please ask the Registrar to give you

24     the Serbian translation of the document.

25             Do you have it in front of you now?

Page 12073

 1        A.   This second document, the witness confirmation, not the interpret

 2     confirmation, as you say, it says "Witness Acknowledgment," not

 3     "Interpreter's Acknowledgment."

 4        Q.   The last page with ERN number 0119-1181 has the interpreter's

 5     certification, and it states that the interpreter has been informed by

 6     Aleksandar Stefanovic that he speaks and understands the Serbian language

 7     and that the above statement has been orally translated for you from the

 8     English language to the Serbian language in the presence of Stefanovic,

 9     who appeared to have "heard and understood --

10        A.   That's not correct.

11        Q.   " -- my translation of this statement."

12        A.   That's not correct.

13        Q.   Am I reading the document incorrectly?

14        A.   This statement is not signed, Madam.

15        Q.   Look at the English version.  It has your signature at the bottom

16     below the interpreter's certification, doesn't it?

17        A.   Very well.

18        Q.   And paragraph 4 --

19        A.   Correct.

20        Q.   -- indicates --

21        A.   But I don't understand what it says here.  There's no witness

22     signature or no -- or a signature by the interpreter on this document.

23     I'm saying that what it says here is not correct, what it says here.

24     That is not correct.

25        Q.   Are you reading in Serbian or in English?  I can't see the

Page 12074

 1     document you're pointing to because of the videolink.

 2        A.   I can only read the document in the Serbian language.

 3        Q.   Can you recognise your signature on the English language document

 4     next to the numerals 17?

 5        A.   No, I don't see the document.

 6             THE ACCUSED: [Interpretation] Judges, I have an objection again.

 7             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, for the time being

 8     we are checking documents, and I really don't need you to know how -- in

 9     which circumstances he signed those documents.  We know that he signed

10     documents in English, while he doesn't understand English.  It is a

11     classic.  Let's not waste our time on this.

12             Now, sir, Ms. Dahl is telling us that it seems you've signed

13     documents in English.  As far as I'm concerned, those documents should

14     have been submitted to you in your own language, but that's the way we do

15     things here; hence the problems we are constantly faced with.  And I also

16     understand that the interpreter who was there at the time apparently read

17     to you the entire document.

18             THE WITNESS: [Interpretation] That's not correct.  He didn't read

19     it to me.

20             JUDGE ANTONETTI: [Interpretation] Okay, it wasn't read to you.

21     Fine.

22             THE WITNESS: [Interpretation] He didn't read the translation to

23     me, no, and that's certain.  I assert that with full liability, and I'll

24     tell you why.

25             JUDGE ANTONETTI: [Interpretation] Sir, in paragraph 3 the

Page 12075

 1     interpreter states that the statement was orally translated from English

 2     into your own language.  That's in paragraph 3.  You're saying that the

 3     document wasn't read back to you?

 4             JUDGE LATTANZI: [Interpretation] Sir, sir, Witness, there's

 5     something I don't understand.  Why did you sign the document in English

 6     if it wasn't read back to you and translated in Serbian?

 7             THE WITNESS: [Interpretation] Well, to tell you the truth, I

 8     didn't follow the trials in The Hague all that much, or the trials that

 9     were ongoing before this one, which was broadcast on television.  At that

10     time, I was a deputy in the Assembly, I was the owner of a big business,

11     and I had a very ill son.  I spent more than eight hours here, and had

12     they told me to sign that I agreed to be beaten up by the first policeman

13     I encountered in the street, I would have signed that.

14             I'm not someone who is easily frightened, but when I came here --

15             JUDGE LATTANZI: [Interpretation] But it is quite strange for a

16     member of Parliament of the Serb Republic to sign anything, a document

17     submitted to him by just about anyone.  Do you think that sounds

18     credible?

19             THE WITNESS: [Interpretation] Well, Madam Judge, I received

20     guarantees from the top people of the Tribunal and the Serbian state,

21     Mr. Djindjic and Madam Del Ponte, that I would not appear in the court as

22     a witness.  And had they told me, "Go and say this, go and say that,"

23     "Sign this or sign that," I would have done it.  Why would I do anything

24     else, either as a deputy or as a layperson?

25             MS. DAHL:

Page 12076

 1        Q.   Mr. Stefanovic --

 2        A.   I still think that way, I still think the same.

 3        Q.   The language about not having to testify does not, in fact,

 4     appear in the 2003 statement; correct?

 5        A.   I didn't read the statement, to tell you the truth, but it's

 6     probably correct.

 7        Q.   The 2006 statement that you signed in Serbian does not have

 8     language regarding any agreement that you would not have to testify, does

 9     it?

10        A.   I told you I haven't read the statements, but most probably it

11     was not written down, what I kept telling the Prosecutors.  And I told

12     you the same, Madam Prosecutor.

13             JUDGE ANTONETTI: [Interpretation] Mr. Stefanovic, sir, when you

14     met with Ms. Dahl in September 2007, did you tell her that the

15     prime minister at the time and Ms. Del Ponte gave you assurances that you

16     would not have to testify; did you tell her at the time?

17             THE WITNESS: [Interpretation] I kept saying that to everybody, so

18     I think I did.  I don't know if there's a transcript of the conversation

19     between me and Madam Dahl, but let the Prosecution show me the minutes of

20     the conversation between Madam Dahl and myself.

21             JUDGE ANTONETTI: [Interpretation] My question is very simple.

22     You met with Ms. Dahl in 2007, in September.  Ms. Dahl gave you a very

23     positive impression, it seems.  Now, did you tell her that you were

24     surprised to have to meet her because you were given assurances that you

25     would never have to testify?  Did you tell her or not?

Page 12077

 1             You are a member of Parliament.  You understand my questions.  Or

 2     at least you were a member of Parliament in the past.  I believe my

 3     question is very clear.

 4             Did you tell Ms. Dahl that because you were given assurances, you

 5     did not understand why you were called to testify as a witness?

 6             THE WITNESS: [Interpretation] Yes.  I didn't tell Madam Dahl what

 7     you are saying, but I told her the story about Zoran Djindjic and Carla

 8     Del Ponte.  But let the Prosecution show me the record of that meeting

 9     between Madam Dahl and myself, if it's possible.  Maybe it's recorded

10     there.  I haven't seen that record.  Please.

11             JUDGE ANTONETTI: [Interpretation] Because when you spoke with

12     Ms. Dahl, you think Ms. Dahl took note of everything you said?

13             THE WITNESS: [Interpretation] It's not what I think, it's

14     understood.  I never knew if I was summoned for this or that reason.  I

15     don't know what to think about it.  Let me see the record of that

16     meeting.  Let the Prosecution show me the record of that meeting.  I

17     think I must have said that, because this is detrimental to my authority,

18     to my political career, to my business, to my life in general for me to

19     appear as a witness over there.  And I even told her, "I do not want to

20     be a protected witness.  What does it mean to be protected or not

21     protected, to be a judge, or a prosecutor, or a witness, or whatever?"

22     Didn't I say that?  Don't you remember that?  I think I did.  Let me see

23     the record.  Or did she summon me for nothing, only to get a look at me?

24     Why did she summon me if she didn't make a record?  Is there a record?

25     Please let me see the record.  Does the Prosecution have a record?

Page 12078

 1             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, please proceed.

 2             MS. DAHL:

 3        Q.   Mr. Stefanovic, let me turn your attention to the 2006 statement

 4     that you signed, and would you please look at the Serbian copy.  And I

 5     want you to flip through -- past the first page to the second page,

 6     and --

 7             THE ACCUSED: [Interpretation] Mr. President, you told the witness

 8     that he was evidently a hostile witness, hostile to the Prosecution, but

 9     I don't know whether that means that you, as a Trial Chamber, have

10     decided to declare him a hostile witness, which would give Madam Dahl the

11     right to put such questions.

12             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, since Mr. Seselj is a

13     procedural specialist and knows common law very well and doesn't need a

14     lawyer, are you ready to declare this witness a hostile witness or not,

15     because if you declare him a hostile witness, you are entitled to leading

16     questions.

17             MS. DAHL:  Your Honour, I'd like to pose questions in a format

18     that gives the Chamber information directly from the witness.  If it

19     proves difficult for him to answer the questions put to him, then I think

20     it would be appropriate.  So far, we've established, I think, that he's

21     signed two statements and that his name is Aleksandar Stefanovic, so the

22     current question pending is a request to --

23             JUDGE ANTONETTI: [Interpretation] We've used almost 30 minutes to

24     learn that his name is Stefanovic and that he signed a document.  Please

25     proceed.

Page 12079

 1             MS. DAHL:

 2        Q.   Mr. Stefanovic, will you look at the first page of your 2000 --

 3        A.   I've also said that it is not correct, what is written there.

 4        Q.   Mr. Stefanovic, there's no question.  There's a request that you

 5     turn to page 1.  Would you do that, please.

 6             Paragraph 1 says that you are giving the statement voluntarily

 7     and that you will describe things known to you, to the best of your

 8     knowledge and recollection.  You signed that statement; correct?

 9        A.   You're putting two questions to me, and the answer to one is

10     "no."  The answer to the other is "yes."

11        Q.   Let me break it down to you.  Read along paragraph 1.  I'm going

12     to read it to you, and you can tell me if I've done so correctly:

13             "I am giving this statement voluntarily and I will describe

14     things I know to the best of my knowledge and recollection."

15             Is that what paragraph 1 says?

16        A.   That's what it says, but that doesn't mean that that's what I

17     said.

18        Q.   Let's go to paragraph 2.  You were requested to give information

19     based on your personal knowledge and your own observations; correct?

20        A.   Up there, yes.

21        Q.   You were requested to make a truthful statement based on your

22     personal experiences; correct?

23        A.   That's what it says here.  If that's what it says here, then it's

24     correct.  I have always spoken the truth.

25        Q.   You were told by the representatives of the Office of the

Page 12080

 1     Prosecutor who were interviewing you that the information you were

 2     providing could be used in criminal proceedings; correct?

 3        A.   That's what it says here, but I wasn't shown this before giving

 4     my statement.  He said, "Good day, Mr. Stefanovic."  I said, "Good day,

 5     Mr. Investigator."  "What you say will be used in the criminal

 6     proceedings against Seselj," well, that's something he never said to me.

 7             JUDGE ANTONETTI: [Interpretation] Witness, I've just noticed a

 8     detail which may be of significance.

 9             In the statement before us, in the title a reference is made to

10     89F.  Once you explained at the time that you were giving a written

11     statement which was going to be admitted in writing and that you wouldn't

12     have to come and testify, was it what was said to you at the time or

13     nothing -- wasn't anything said to you?

14             THE WITNESS: [Interpretation] No, no, nothing like that was said

15     to me.

16             JUDGE ANTONETTI: [Interpretation] You weren't told anything.

17     Fine.

18             Please proceed, Ms. Dahl.

19             MS. DAHL:

20        Q.   When you gave this statement, you told the investigators and the

21     other people present that you were willing to testify before the

22     International Criminal Tribunal for the former Yugoslavia; correct?

23             THE ACCUSED: [Interpretation] That's a leading question.

24     Ms. Dahl cannot make a statement and then say, "Is that correct?"  She

25     should ask as follows:  "What did you say when they told you this or

Page 12081

 1     that?"

 2             MS. DAHL:  Your Honour, I'd like you to authorise me to lead the

 3     witness so that we can work our way through the evidence the witness is

 4     competent to provide the Chamber.

 5             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, the Judges have some

 6     experience in this area, because this isn't the first time we're faced

 7     with this problem.  We're interested in the functioning of the SRS, so

 8     maybe you should leave aside this procedural issue.  I think we heard

 9     what the witness had to say.  We will assess this part of his testimony

10     accordingly.

11             Now, as far as the substance is concerned, we want to know what

12     he was doing within the SRS, and I think in that particular area the

13     witness may have interesting explanations to provide.

14             MS. DAHL:

15        Q.   Mr. Stefanovic, have you ever formed your own political party?

16        A.   Yes.

17        Q.   Did you form a political party in 1989?

18        A.   Yes.

19        Q.   What was the name of that party?

20        A.   The Liberal Party.

21        Q.   What was the objective of that party?

22        A.   The objective of every party is to fight for power and to get rid

23     of the existing regime.  The aim was to fight against the existing

24     regime, the Communist Party which had ruled on its own for the past 50

25     years on the territories of Yugoslavia and Serbia and to establish a

Page 12082

 1     multiparty system such as exists in all Western democracies.

 2             We felt, a group of people and I, we who founded the party felt

 3     that the time had come to set up a multiparty system in Serbia, in view

 4     of the fact that at that time, in many former Yugoslav republics, a

 5     multiparty system had already been established.  Elections had been held,

 6     and it was only Serbia that was lagging behind in that respect.

 7        Q.   Okay, thank you.  Are you familiar with the Srbski Slobadarski

 8     Pokret [phoen]?

 9        A.   Yes.

10        Q.   What is that?

11        A.   That was a political party founded by Mr. Vojislav Seselj, if I

12     remember well, on the 23rd of January, 1990, and this was in Batajnica,

13     if I remember well.

14        Q.   Did you have occasion to cooperate with the political party

15     founded by Vuk Draskovic, the Serbian National Renewal?

16        A.   Well, the words "to cooperate" is very broad in its meaning.  At

17     that time, there was no antagonism among the newly-established political

18     parties.  We would see each other at various meetings.  We would meet

19     informally and talk.  So there wasn't any special cooperation.  Everybody

20     pushed their own policy.  Vuk Draskovic was very prominent in this

21     because he had a lot of support from the regime of Slobodan Milosevic,

22     which felt that Vuk Draskovic's party was not a threat to him, so it was

23     favoured in the daily newspapers, the electronic media, and in all other

24     public --

25        Q.   Let me ask you the period of time that we're talking about.  Is

Page 12083

 1     this March 1990?

 2        A.   Yes, yes.  The first half of 1990, in fact.

 3        Q.   Did there later come a point in time where Mr. Seselj and

 4     Mr. Draskovic had a conflict?

 5        A.   Yes.

 6             JUDGE ANTONETTI: [Interpretation] Witness, I have a technical

 7     question for you.

 8             I'm reading your written statement, with all the reservations

 9     that you expressed about the statement.  You said at the time that, in

10     fact, it was Milosevic who, via the SDB, had control over all these

11     parties.  Is that true, is that untrue?

12             THE WITNESS: [Interpretation] Yes, almost all the parties; not

13     over mine, certainly, because I didn't have any contacts with the DB, and

14     I don't think he had any contacts at that time either with Seselj's

15     freedom movement, if view of the fact that the people in the party were

16     characterized as express anti-communists, adversaries to the communist

17     regime, whether it was Milosevic's regime or Titoism, who as a spirit

18     still loomed high, and perhaps some other party too.  But many parties

19     were not only under the control of the SDB but were also created by the

20     DB, in fact.

21             JUDGE ANTONETTI: [Interpretation] In your view, which party may

22     have been created or founded by the SDB?

23             THE WITNESS: [Interpretation] Your Honour, the SDB is no weaker

24     now than it was then, so don't bring me into a difficult situation so

25     that I have repercussions because of any statement I might make.

Page 12084

 1             Do you understand me?  I hope you understand me.

 2             JUDGE ANTONETTI: [Interpretation] Very well, fine.  I get the

 3     point very quickly.

 4             Ms. Dahl.

 5        Q.   When Mr. Draskovic and Mr. Seselj had a conflict in 1990, what

 6     did Mr. Draskovic do?

 7        A.   I don't understand the question.  What do you want me to say?

 8     I'm not sure.

 9        Q.   Well, did there come a point in time where --

10        A.   What do you mean, what did Mr. Draskovic do?

11        Q.   Was there another political party founded?

12        A.   Yes.

13        Q.   What was it called?

14        A.   Yes, Draskovic did form the party.

15        Q.   Its name?

16        A.   Well, Vuk Draskovic in June, I think, founded a party which was

17     called the Serbian Renewal Movement, the SPO, and it exists to this very

18     day.  That's what it's still called, and Vuk Draskovic is still at the

19     head of that party.  Now, I might be wrong whether that was March or

20     later, I can't say for sure, but I do know that it was in the first half

21     of the year.  Whether it was after the 10th of March, that is to say, the

22     famous events in the Engineers and Technicians hall where Mirko Jovic

23     threw the -- threw Vuk Draskovic out of the Serbian Renewal Movement, he

24     stormed the hall with his sympathizers who made up the main board of the

25     Serbian National Defence -- or Renewal Party, and he came on to the

Page 12085

 1     rostrum and said that Vuk Draskovic as of that moment had been replaced

 2     and was no longer the head of the Serbian Renewal Party, and

 3     Vuk Draskovic and Seselj, Boskovic and I agreed to meet the next day in

 4     the Moscow Hotel, and we did indeed meet to shape our future activities,

 5     to see what we should do, since it was quite obvious at that point in

 6     time that the most popular oppositional party had given a red card to

 7     Vuk Draskovic, who at that point in time was one of the most important

 8     opposition leaders and the man who, before that, was generally known as a

 9     major dissident.  And he enjoyed great popularity among the Serbian

10     people, especially in the national corps of Serbs, who had not forgotten

11     their origins or their religion, the healthiest part of the Serbian

12     people, or their need to exist in those territories the people who had

13     not forgotten Serbian traditions.  So at that point Vuk Draskovic was an

14     important, if not the most important person in the opposition parties of

15     Serbia on the Serbian political scene.

16             I don't know if I've made myself clear enough.

17        Q.   Can you describe for the Trial Chamber how it came about -- the

18     formation of the Serbian Chetnik Movement came about?

19        A.   Yes, I can do that.

20        Q.   Please do so.

21        A.   Well, it's like this:  I just need -- well, like all the Eastern

22     countries, Yugoslavia, too, and the Republic of Serbia, was under great

23     torture by the Communists when they arrived on the 1st of September,

24     1944, and enforced with the help of the British, the Communist Party

25     authority, led by Josip Bros Tito, who throughout the time of his reign

Page 12086

 1     showed expressly anti-Serb tendencies, and in the autumn of 1994 alone,

 2     in my district, the Valjevo district, executed over six and a half

 3     thousand Muslim men, mostly young villagers, in order to maim the Serb

 4     nation and in order to introduce government and power of fear, based on

 5     fear.

 6        Q.   Let me focus my question.

 7        A.   You asked me to --

 8        Q.   Were you involved with Mr. Seselj in the creation or formation of

 9     the Serbian Chetnik Movement?

10        A.   Yes, yes.

11        Q.   And when was that formed?

12        A.   Well, I can't give you an exact date, but I think it was June

13     1990, when a group which had left the Serbian Renewal Movement,

14     dissatisfied with the policies waged by Vuk Draskovic, and joining up

15     with the Liberal Party from Valjevo, the Serbian Chetnik Movement was

16     formed at a meeting where the people expressed their own free will.

17        Q.   Let me ask you, who was the president?

18             JUDGE ANTONETTI: [Interpretation] One moment, Ms. Dahl.  I have a

19     question for the witness.

20             Witness, we've heard a number of witnesses tell us about rallies

21     of the Serbian Chetnik Movement, and we asked questions about why they

22     joined this movement.  It struck me that many of us -- many of them

23     explained to us that they joined the movement because they were

24     monarchists.

25             THE WITNESS: [Interpretation] Yes.

Page 12087

 1             JUDGE ANTONETTI: [Interpretation] That was the reason for joining

 2     the movement.  You, yourself, were at some point the vice-president of an

 3     organisation.  Did you have the feeling that many of those who joined the

 4     movement did so because they wanted to restore the monarchy?

 5             THE WITNESS: [Interpretation] Well, it's like this:  You must

 6     understand one thing.  I didn't follow the trials in The Hague that have

 7     been going on.  I tried to tell you that earlier on.  So I don't know

 8     what the gentlemen who were in the Chetnik Movement have said, but I say

 9     with full responsibility that one of the motives was that, too, but

10     I think that the Chetnik Movement is exclusively an anti-communist

11     movement in the first place, rallying people who were expressly

12     anti-communists and who advocated a stream, if I can put it that way,

13     which wanted, in one way or another, to rehabilitate the great not only

14     Serbian, Yugoslav, but also the European personage, Dragoljub

15     Draza Mihajlovic, general of the Yugoslav Army, who was without a doubt

16     was foremost fighter in Europe in World War II.  So he led this movement,

17     and to a great extent it was maimed by the communists in the postwar

18     period.  And Draza Mihajlovic, himself, in a rigged trial in Belgrade in

19     1946, on the 17th of June, was executed for no proper reason.  So that's

20     it.

21             But my motives for joining the Chetnik Movement were the same as

22     the motives that the Liberal -- for the founding of the Liberal Party in

23     Valjevo and entry into another party, that is, to deal in politics, I was

24     interested in seizing power, taking power, to impound authority; in other

25     words, to have a say as much as possible in how things were run in my

Page 12088

 1     country and for the system that I believed to be correct.  And I always

 2     said this in my public speaking, that every party in the pre-electoral

 3     campaign should come forward with its programme and platform and say that

 4     we're going to have a good economy, we're going to support the stability

 5     of our national currency, we shall work for the good of such and such,

 6     and so on.  And another party, like the Serbian Chetnik Movement, would

 7     say, for instance, "We will nurture Serbian traditions.  We will fight to

 8     protect and defend our fellow nationals outside the Republic of Serbia so

 9     that the terrible crimes of World War II shall not be repeated under the

10     wings of Germany and in cohorts with the British after World War II who

11     had forgiven those countries, because there was no greater crime that was

12     committed during World War II than the crime committed by the Croats

13     against the Serbs in the area of Posavina.  That's how it was.  I think

14     that's correct.

15             JUDGE ANTONETTI: [Interpretation] Fine.  You've answered my

16     question.

17             Ms. Dahl, we have 20 minutes before the break.  Please proceed.

18             MS. DAHL:

19        Q.   Mr. Stefanovic, who was the president of the Serbian Chetnik

20     Movement?

21        A.   Vojislav Seselj.

22        Q.   And who was the vice-president?

23        A.   Aleksandar Stefanovic.  That is to say, I was, I myself.

24        Q.   Are you familiar with the political programme of the Serbian

25     Chetnik Movement?

Page 12089

 1        A.   Absolutely, yes, and I am one of the creators of that programme.

 2     And I'm having proud of being that, of being -- of having devised and

 3     formulated such a nice programme, in cooperation with all the other

 4     people who made up the Chetnik Movement of the day.

 5        Q.   Is it correct, my understanding, the programme includes the

 6     restoration of a free, independent and democratic Serbian state in the

 7     Balkans; is that correct?

 8        A.   Well, it wasn't the restoration, it was the establishment,

 9     because that kind of Serbian state might have consisted of that in just

10     two or three days of its history.  But it wasn't quite logical, from the

11     viewpoint of the Serbian nation, that a state should be set up on

12     territories where the Serbs were the ethnic majority, the absolute ethnic

13     majority, so as to avoid having history repeat itself, the very bloody

14     history in the 19th century, and which was directed and orchestrated by

15     the Vatican; that is to say, the Serbian people lost a lot of blood, and

16     looked at from today's perspective, brought itself to the very edge of

17     genetic survival.

18        Q.   Mr. Stefanovic, which lands would be under the Serbian Chetnik

19     Movement's platform included in a new Serbian state?

20        A.   Well, it's like this:  Following on from the example of Hitler in

21     1936 and Hitler's annexation of Sudetenland, Czechoslovakia, which was

22     under Czech administration, Europe, at the time it gave the green light

23     to this and agreed with this move on Hitler's part.  And Europe agreed

24     again today.  It kept quiet when Austria was annexed and thought that

25     Hitler would stop there.  And certainly Hitler would never have been

Page 12090

 1     convicted and would have lived for a long time to come had he stopped

 2     there, so that wouldn't have been a problem, as far as civilization in

 3     Europe was concerned and the viewpoints of the day were --

 4        Q.   Rather than discussing this by analogy, let me direct your

 5     attention to the geography of the Balkans.

 6             Under the Serbian Chetnik Movement's political platform, would

 7     the new Serbian state include territories now in Macedonia?

 8        A.   Yes, absolutely so.  Macedonia never existed as a state until

 9     1992, never.  Aleksandar the Great, Aleksandar Makedonski.  Now, and

10     Montenegro is a Serb state today, too, regardless of the regime of the

11     government there, but it's a Serb state.  And Vojvodina will be a Serb

12     state.  It won't be a Spanish state, will it?  And Bosnia-Herzegovina,

13     and history and time have shown that a large part of that is a Serbian

14     state.  The Republika Srpska is not a Spanish state, it is a state of

15     Serb people.  Unfortunately, it's almost ethnically pure, and

16     unfortunately there was a lot of bloodshed prompted by the pot entates of

17     Europe.  So what did the Serbs get, the Serbs, Muslims and Croats there?

18     They had trouble and strife, poverty and hatred.  That's what they got.

19             And today we have Haris Silajdzic, who can just at the bat of an

20     eye get a couple of million that he needs, so --

21        Q.   Please.  I want to focus your attention on the political

22     platform.

23        A.   But, yes, that's right.

24             JUDGE ANTONETTI: [Interpretation] Witness, what you are saying

25     has some historical relevance, but we've already heard quite a lot of

Page 12091

 1     evidence about all this.  The purpose of the Prosecutor, and I believe

 2     that it is also the purpose of Mr. Seselj, is for us to have as much

 3     information as possible about the Serbian Radical Party, whose president

 4     is the accused in this case, for events that took place in 1991 and 1992.

 5             What you're telling us about the history of the region has some

 6     relevance, but, please, in order to help us establish and ascertain the

 7     truth, please focus on the SCP and SRS.  Ms. Dahl, with her questions, is

 8     trying to focus you on these particular topics.

 9             JUDGE LATTANZI: [Interpretation] I have a question for you,

10     Witness.

11             You referred to ethnic purity.  Was the idea to create an

12     ethnically-pure Serb state?

13             THE WITNESS: [Interpretation] My answer is "no," and here's why:

14     Within the frameworks of the Chetnik Movement of the Serbian Radical

15     Party, we had Hungarians, we had deputies who were Hungarians; that is to

16     say, the top post.  We had Elvira Fehete, for example, who was a

17     Hungarian.  We had Muslims.  We had a man called Spaho, who was very

18     famous.  He was a descendant of the famous Mehmed Spaho, the former

19     Bosnian politician.  We had Croats, we had Siptars, we had Serbs from

20     Macedonia, Serbs from Montenegro.  I don't know.  All sorts of

21     ethnicities within the party, so why would we struggle to be ethnically

22     pure?  No, that's not a good formulation, and that's why the Serbian

23     Radical Party or the Serbian Chetnik Movement never fought, and I say

24     that with full responsibility.  I did not follow the trial, so I don't

25     know what Mr. Seselj is saying now.  But before, there was never a

Page 12092

 1     problem for people to join the party who are, for example, a Hungarian.

 2     There was Elvira Fehete.  She was a deputy in the Assembly.  She's a

 3     Hungarian, yes, she is.  Mehmed Spaho, he was a deputy, yes, he was.  Is

 4     he a Muslim?  Yes, he is.  Then there was the Siptar down there.  What

 5     was his name, the journalist there?  I don't know what he was, anyway.

 6     What was his name?  Zanevi [phoen] or whatever.  So why would it be

 7     ethnically pure?

 8             JUDGE LATTANZI: [Interpretation] You've answered my question.

 9     Thank you.

10             JUDGE ANTONETTI: [Interpretation] Witness, all this confusion is

11     due to a sentence you uttered earlier on.  It may have led us to some

12     confusion, but you've clarified the matter.

13             Ms. Dahl, you may proceed.

14             MS. DAHL:

15        Q.   Did the Chetnik Movement include areas that are now presently in

16     Croatia within the geographic objectives of the new Serbian state?

17        A.   It's like this:  You must understand one thing.  We wanted to

18     establish or, rather, to prevent the persecution of the Serb people who,

19     with the establishment of Tudjman's power and authority in Croatia, were

20     under jeopardy.  So that was the main problem, as far as I see it and as

21     far as all the Radicals see it, and why they joined up and decided to

22     engage in a political struggle to prevent that.  So from the point in

23     time when the Serbs came under the power and authority of Tudjman and

24     jeopardised that way, then it's quite natural that the mother country

25     wanted to protect the people that had no protection, no arms, nothing,

Page 12093

 1     and especially having remembered what happened in the Second World War in

 2     Jasenovac, Kozadin [phoen], and so on and so forth.  So what should we

 3     have done?  We couldn't have let the Serbs be killed.  We couldn't say,

 4     "We'll help Tudjman kill the Serbs."

 5             So we Serbs had suffered a great deal from the point in time when

 6     Croatia, with America's help, expelled over 300.000 Serbs from their

 7     thresholds.  They launched an attack on Serbia when Serbia was

 8     economically depleted, and we all had to pool our efforts to help our

 9     fellow men.

10        Q.   Let me go back to my question.  I'm thinking the answer to my

11     question was, yes, the programme platform included locations now in

12     Croatia.  Is that correct?

13        A.   Yes.

14        Q.   How about Kosovo, did the programme --

15        A.   Well, but I'm telling you why, I'm explaining.

16        Q.   Yes, I appreciate that.  I want to move on to the next question.

17     Did the programme platform include Kosovo?

18        A.   It's like this, Ms. Dahl:  Not only my own personal answer and

19     not only what I think, but I'll tell you.  Let me tell you what I think,

20     and I think it's this:  Only a madman could recognise the independence of

21     Kosovo today, regardless of who that person is.  Kosovo has thousands and

22     thousands of monasteries.  There are thousands and thousands of

23     monasteries of the Serbian Orthodox Church over there in Kosovo.

24             MS. DAHL:  [Previous translation continues)... to direct the

25     witness to answer my question instead of launching into a tangent about

Page 12094

 1     today's political questions.

 2             JUDGE ANTONETTI: [Interpretation] Yes.

 3             Witness, I can see that you are a politician.  You're used to the

 4     spoken word, and you have a tendency to move on to other topics that may

 5     have some relevance, politically speaking.  But here we are dealing with

 6     extremely complex matters, and the Prosecutor is trying, through her

 7     questions, to highlight some of these issues, so please try to focus on

 8     the questions put to you by the Prosecutor.  If I or my fellow Judges

 9     realise that some things are missing, we'll put the necessary questions

10     to you.  And in any case, as part of his cross-examination, Mr. Seselj

11     will probably have time to deal with these matters.  We are now in the

12     phase of the examination-in-chief, and she is entitled to put to you the

13     questions she wants to put to you.

14             Ms. Dahl, you have five minutes left.  Please proceed.

15             MS. DAHL:

16        Q.   Did the platform include retaining Kosovo?

17        A.   Well, it's like this:  You're asking me whether -- well, Kosovo

18     was Serbia, and there was absolutely no question of Kosovo escaping

19     anywhere.  Kosovo was within the frameworks of Serbia, so I don't know

20     why you're asking me whether that was it.  We can't say that we're going

21     to separate part of a territory because Tito allowed a million Siptars

22     and went in there unlawfully, just as if Mexicans were to storm your own

23     country.  You take up your rifles and you kill them all, you build a

24     Chinese wall between Mexico and America.  And that's what Tito did.  He

25     let 350.000 Siptars enter the country after World War II and during World

Page 12095

 1     War II, and they were on the territory of Serbia; Kosovo, Serbia and

 2     Yugoslavia, the Yugoslavia of Tito.  Tito did not expel them.  He left

 3     the criminals to remain, and so it's quite normal to strive and put that

 4     injustice right, so that those immigrants should be sent out.  You do

 5     that all over the country.  Name me one state that doesn't do that, sends

 6     immigrants back.

 7             I don't know what to say.  What can I say?

 8             JUDGE ANTONETTI: [Interpretation] Witness, we knew that already,

 9     but I don't understand.  You used the words "these criminals."  Even if

10     Tito made them go there, some of them may have been extremely decent

11     people.  Why do you call them criminals?  That's the same with Mexicans

12     going to the United States of America.  These people aren't necessarily

13     criminals.  Or did you get carried away?  Okay, you got carried away.

14             Ms. Dahl, you may proceed.

15             MS. DAHL:

16        Q.   Was the Serbian Chetnik Movement --

17        A.   Yes, precisely, Your Honour.  That was just an erroneous

18     interpretation.  They weren't on the territory of Kosovo lawfully.  It's

19     not that they were criminals, murders, thieves, but they were there

20     unlawfully and therefore criminally on the territory of Serbia and

21     Yugoslavia and Kosovo.  So they should be expelled, and that was to put

22     right the injustice that had been done by Tito.  So that's my story,

23     because it was illogical for you to ask me that question, whether

24     Britanny is part of France, for example, a component part of France.  I

25     apologise for making this all into a caricature, but that's how I

Page 12096

 1     understood the question and felt it, so I had to explain.

 2             JUDGE ANTONETTI: [Interpretation] Okay, we get the point.

 3             Ms. Dahl.

 4             MS. DAHL:

 5        Q.   Mr. Stefanovic, was the Serbian Chetnik Movement registered as a

 6     legal political party?

 7        A.   We had all the necessary documents, handed them over to the state

 8     organs, in this case the Ministry for Local Self-Government, that's how

 9     it was registered, and the Minister of Justice first, actually.  And

10     without explanation, they refused to have us registered, but we continued

11     working as a -- an unregistered party.

12        Q.   Were you involved in the formation of the Serbian Radical Party?

13        A.   Yes.

14        Q.   When was it formed?

15        A.   It was formed on the 23rd of February, 1991.

16        Q.   Who was elected president?

17        A.   At the first founding session held in Kragujevac, Mr. Seselj was

18     elected as president, and there were three or four vice-presidents, and I

19     was elected the secretary-general of the party.

20        Q.   Who were the vice-presidents?

21        A.   If I remember correctly, they were Stanoje Djordjevic from Nis.

22     Then there was Vojin Vuletic, Maja Gojkovic was the third, and the fourth

23     was Tomislav Nikolic, the same man who was president of the newly formed

24     party, also by the DB of Serbia, another intelligence -- foreign

25     intelligence services as well.

Page 12097

 1        Q.   And did the Serbian Chetnik Movement continue to exist?

 2        A.   It's like this, you see:  It was incorporated into the Serbian

 3     Radical Party.  In formal terms, I can't remember whether it still

 4     existed for a certain time until that section, if I can put it that way,

 5     was abolished.  Well, it was incorporated.  It conjoined.  There was a

 6     Serbian Radical Party and Serbian Chetnik Movement that was conjoined,

 7     and the Serbian Radical Party was formed with the unification of the

 8     Chetnik Movement and the National Radical Party.  Part of the

 9     dissatisfied members of the policy led by the popular Radical Party.

10     Veljko Guberina went on to form the other.

11        Q.   What is the Central Fatherland Administration?

12        A.   That was the top organ of the party.

13        Q.   Were you a member of that or hold a seat on that organ?

14        A.   Yes.

15        Q.   Can you describe for the Trial Chamber what your duties were as

16     secretary-general?

17        A.   Well, you see, I think the formulation is clear.

18     Secretary-general, the name speaks for itself.  It means covering all

19     administrative work having to do with the work of the party, the

20     organisation of party structures, and looking after all the technical

21     details necessary for the work of the party.  It's a specific post,

22     demanding a lot of work, a lot of self-sacrifice.

23             And there's one thing that you seem not to have noticed.  The

24     Radical Party was established about a year an half after all the other

25     political parties on the Serbian political scene, and there had already

Page 12098

 1     been an election held without the activists of the Serbian Radical Party

 2     involved.  So we had to invest extra effort in organising ourselves on

 3     the territory of Serbia.  And on the 29th of May, 1992 we participated in

 4     the first elections.  There we achieved the greatest success, I think, in

 5     the history of the party.  I think it was about 1.650.000 votes or

 6     something like that, and the party enjoyed great popularity among the

 7     citizens of Serbia.  There were many sympathizers.

 8             Quite a lot of time has elapsed.  You have to bear in mind that

 9     I'm an elderly man, that I'm ill, and that I'm burdened with various

10     problems.  But as far as I can remember, this was between 35 and

11     40 per cent.  If you take into account that the late Hyder [phoen] had

12     between 15 and 20 per cent and Austria was exposed to sanctions because

13     of his activities, the reason I mention him, well, he died recently, but

14     he's not the worst example.  But a party in any state that has over

15     35 per cent of the vote is worthy of respect.

16        Q.   Mr. Stefanovic, do you remember my question?  I asked you what

17     your duties were as secretary-general.

18        A.   My duty was to be at the head of the Secretariat.  The

19     Secretariat had about 10 or 15 people working in it, and they dealt with

20     administration, the organisation of the party, courier services, porters,

21     gatekeepers and so on, whether there would be someone to make the coffee,

22     to wash up the coffee cups, to convene a press conference, to organise a

23     public speaker, and so on and so forth.

24        Q.   Can you tell us how long you held the position of

25     secretary-general of the Serbian Radical Party?

Page 12099

 1        A.   About five years.  I'm not sure exactly.

 2             JUDGE ANTONETTI: [Interpretation] Very well, five years.

 3             We'll take a break, sir, because we must take a 20-minute break

 4     now.  We will resume in 20 minutes.

 5             I'm happy to inform you that at the end of the day, the Registrar

 6     in Belgrade will pay 4.807 dinars to you.

 7                           --- Recess taken at 3.51 p.m.

 8                           --- On resuming at 4.13 p.m.

 9             JUDGE ANTONETTI: [Interpretation] We're back in session.

10             Ms. Dahl, you can proceed.

11             MS. DAHL:  Thank you, Your Honour.

12        Q.   Mr. Stefanovic, before the break we were talking about your

13     position as the secretary-general of the Radical Party.  Could you tell

14     me how long you remained a member of the Radical Party?

15             Your Honour, the screen indicates no microphone on the far side,

16     and I'm not getting any translation, although I can see Mr. Stefanovic is

17     attempting to answer the question.

18             JUDGE ANTONETTI: [Interpretation] Yes, indeed, there seems to be

19     no microphone, according to what we can see on the screen.  Can we fix

20     it?

21             Witness -- oh, now it should be working.  No, the logo had

22     disappeared, but it's back on the screen now.

23             Witness, can you hear us?

24             THE WITNESS: [Interpretation] Yes, yes.  It's all right now.

25     I can hear you, I think.

Page 12100

 1             MS. DAHL:  Let me repeat my question.

 2        Q.   How long did you remain in your position as secretary-general?

 3        A.   Five years.  I said that already, five years.

 4        Q.   When did you leave the position?

 5        A.   I can't recall the exact date.  But there was some

 6     misunderstandings within the party, and I was upset by the standpoint

 7     taken by the party leadership, and I simply left the party in a way that

 8     was not pompous or drastic.  There were no big upheavals, and Mr. Vucic

 9     came to take over my place, and Dragan Todorovic took over some work on

10     behalf of the Executive Committee, and I think Stevo Dragisic did some

11     work as well.  I don't remember all their posts, but I simply left the

12     party quietly and without any major traumas.

13        Q.   Your statement indicates that you left your official function in

14     1996.  Does that refresh your recollection?

15        A.   Yes, that's what I said.  Maybe you didn't hear me, but I said I

16     stayed until the end of 1995 or 1996.  There's nothing in dispute there.

17        Q.   Did you have the intention to leave the party earlier than that?

18        A.   No.

19        Q.   Let me direct your attention to paragraph 11 of your 2006

20     statement.  And let me ask you to look at the last sentence, which

21     states:

22             "In fact, I wanted to leave the party in 1994, but I could not do

23     that because Seselj threatened me with death at that time."

24        A.   I'd like to go back to the beginning and to my explanation

25     concerning the promise that I would not appear before this court.

Page 12101

 1        Q.   Mr. Stefanovic, do you have the document in front of you?

 2        A.   I heard what you said.

 3        Q.   Do you have the document --

 4        A.   Yes, on my left-hand side here.  There it is.

 5        Q.   Okay.  Are you looking at paragraph 11?

 6        A.   Paragraph 11 doesn't mean anything to me, Madam.  I'm telling you

 7     the truth.  I'm testifying under oath and I'm telling you the truth.  You

 8     can say what you like.  This is the first time in my life I've seen it

 9     written down like this.

10        Q.   Mr. Stefanovic, let me ask you --

11        A.   It looks as if I'm someone who dictates texts, and I'm not.

12        Q.   Mr. Stefanovic, does the last sentence of paragraph 11 read:

13             "In fact, I wanted to leave the party in 1994, but I could not do

14     that because Seselj threatened me with death at that time"?

15        A.   No, that's not how it was.

16        Q.   I'm not asking you that question.  I'm asking you if the

17     statement reads as I have stated.

18        A.   Well, it says here I wanted to leave the party in 1994 but I

19     could not do that because Seselj threatened me with death at that time.

20     But if you want me to tell you about this, I will.  Is that what you

21     want?

22             JUDGE ANTONETTI: [Interpretation] Yes.  Well, that's the question

23     asked to you by Ms. Prosecutor.  Yes, please do explain.

24             THE WITNESS: [Interpretation] Yes.  Let me explain this in

25     detail.  Ask the Prosecutor if it's all right for me to explain this.

Page 12102

 1             MS. DAHL:  Before we get to the explanation, Your Honour, could I

 2     ask that he acknowledges that his initials are at the bottom of the page

 3     that we've just read from.

 4             THE WITNESS: [Interpretation] Madam Prosecutor, I have to give

 5     you a detailed reply now.  I would come to the --

 6             MS. DAHL:  [Previous translation continues]... bottom of the

 7     page, and then we can go to the explanation.

 8             JUDGE ANTONETTI: [Interpretation] Witness, you have put your --

 9     witness, you have put your initials next to paragraph 11.  Paragraph 11

10     is very clear.  At the time, that is, the 12th or 15th or 16th June 2006,

11     with two OTP investigators present, you said that you were threatened to

12     death by Mr. Seselj.  Now, can you give us an explanation about what is

13     stated here?  What happened at the time?

14             THE WITNESS: [Interpretation] It was like this.  What I want to

15     say is the following:  Coming before the investigators was, for me, very

16     traumatic.  It wasn't whether I loved or hated, or agreed or disagreed,

17     with Vojislav Seselj, but it was clear to me that I was hurting myself in

18     every way, politically, morally, and in every other way.  It's very

19     unfair to wrongly attack someone when he is in a defenceless situation;

20     for example, in prison.

21             I keep trying to explain two things.  First, before I come here

22     to give a statement, I would take sleeping pills and tranquilizers.  I

23     would drink two or three glasses of alcohol before coming here to give

24     statements.  But in spite of this, it looks here as if I dictated all

25     these points, 1, 2, 3, 4.  I didn't do that.  I assert that with full

Page 12103

 1     liability.  I didn't do that.  They could have written down, for example,

 2     I condemn my late father to death.  I would have signed that and left,

 3     not because I wanted to condemn my father to death, but because I didn't

 4     look at what it said here.  And this sort of statement, divided into

 5     paragraphs 1, 2, 3, 4, I never gave a statement like this one.  This is

 6     written up according to something that was prepared in advance.  They

 7     didn't say, "Number 11, Aleksandar Stefanovic, how do you ...," and so on

 8     and so forth.  I assert with full liability that I did sign this

 9     statement, but I did not make it in this shape and form, the way it's

10     written down here, and this is the first time I see this text.  I've

11     never seen this before, and it's not logical.  It's not logical, the way

12     it's all organised in points.

13             And what does it mean, "You signed it?"  Oh, I did sign it, all

14     right, so I did.  So what?  Well, tell me.

15             JUDGE ANTONETTI: [Interpretation] Sir, we are professional judges

16     in this Chamber.  We know that witnesses may sometimes change their

17     minds.  We have before us a document which shows that in 2006, you said

18     what is in this statement.  You're telling us the contrary now.  You told

19     us that you took drugs, that you would have signed anything.

20             Now, one question comes to mind.  Were you threatened, was

21     pressure exerted upon you, or are you telling the truth now?

22             THE WITNESS: [Interpretation] Judge, if I may say the following:

23     This morning, for at least half an hour or an hour before the beginning

24     of this hearing, there were grounds to suspect that someone tried to

25     assassinate me or kidnap me.  An unknown person came to my home.  I

Page 12104

 1     haven't seen my family.  I was on the way to the Tribunal.

 2             MS. DAHL:  [Previous translation continues]... please.  I'm

 3     concerned that the witness should be able to give candid information

 4     about serious allegations in private.  If he's presenting information

 5     about his personal security, let's go into private session.

 6             THE ACCUSED: [Interpretation] Objection.  That would make sense

 7     only if the witness insisted on going into private session.  I think

 8     there are no grounds for this.

 9             JUDGE ANTONETTI: [Interpretation] Witness, do you wish us to move

10     into private session or are you happy with telling us about it in a

11     public hearing?

12             THE WITNESS: [Interpretation] I want the Serbian public to hear

13     everything I'm saying.  I have not told a single lie, nor do I wish to

14     conceal anything.  Also, if somebody wants to kill me, let them do so.

15     I've lived long enough.  I've had a very good and rich life.

16             So I think that what I'm saying, well, you fail to understand one

17     thing.  Please listen to me for just a minute.  May I speak my mind for

18     just a minute?

19             Three days ago, I found in the newspapers that a Dutch sports

20     journalist is calling Laskovac a war criminal, a football player, and he

21     didn't want to include him in the team.  And when I read that the

22     journalists have called this innocent young man a Serbian war criminal

23     just because he's a Serb, I couldn't sleep for three nights.  That

24     journalist wasn't working on his own.  He has superiors, he has bosses.

25     We are all regarded as war criminals here, and I find this very hurtful.

Page 12105

 1             This morning, I came here to testify, and my blood pressure was

 2     185.  Any -- through 115.  Any doctor would have sent me to hospital with

 3     this sort of blood pressure.  No one needs to kill me.  I can drop dead

 4     at any minute now.

 5             I suffer from angina pectoris.  I have high blood pressure.  I

 6     have serious arteriosclerotic problems.

 7             But let me say in open session, this morning, what this woman was

 8     looking for?  She can say she was a humanitarian worker, but what was she

 9     looking for in my home?  Let someone normal explain this to me if they

10     can.  And why did they strike against the house?  When someone strikes

11     against a house in Australia, they kill you, if someone had killed that

12     woman who came to the door.

13             I'm reacting emotionally now.  Please forgive me for speaking

14     like this.

15             JUDGE ANTONETTI: [Interpretation] Witness, well, first of all,

16     relax, because if you have such high blood pressure, that is 18, you

17     shouldn't go up to 20; otherwise, you might end up dead.

18             Now, we want to know if you were threatened.  You said that

19     somebody turned up at your door.  It could have been a policeman, because

20     we tried to locate you because we had the feeling that you had vanished.

21     So it may have been a policeman who turned up at your door to check where

22     you were.  Why are you telling that somebody tried to kidnap you?

23             THE WITNESS: [Interpretation] This young woman who came to my

24     door, she was a female, and she's here.  She's not a member of the

25     Serbian police. (redacted)

Page 12106

 1     (redacted). But why did she come to my

 2     home?  Why was the Trial Chamber mistrustful when I always responded to

 3     telephone calls?  Mr. President, there were at least 300 telephone calls

 4     over the past two or three years from the Tribunal.

 5             MS. DAHL:  [Previous translation continues]...

 6             THE ACCUSED: [Interpretation] Objection.  Why would that name be

 7     redacted from the transcript?  (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted) They have now been arrested in

11     Pristina.  Now, why should this be a secret, why the conspiracy?

12             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, you're on your feet.

13     What do you have to say, because apparently Mr. Seselj anticipated what

14     you were going to say.

15             MS. DAHL:  [Previous translation continues]... witness unit made

16     arrangements to provide transportation for Mr. Stefanovic for his

17     appearance today.  I am, I'd say minimally, a little bewildered by the

18     conspiracy theory being created or that the Victim and Witness Unit, the

19     officer who provided transportation would create an assassination attempt

20     or --

21             THE WITNESS: [Interpretation] What sort of transportation?

22             MS. DAHL:  -- kidnapping.

23             JUDGE ANTONETTI: [Interpretation] Witness, the person who came to

24     see you, and we'll have to redact her name, is a staff member of the

25     Registry.  She came to see you to make arrangements about your

Page 12107

 1     transportation.  We are not talking about an agent of the German

 2     intelligence services.  It was simply someone who was doing her job.

 3     Please do not develop any kind of conspiracy theory about all this.  It

 4     was just an employee of the Registry who was there to help you, as part

 5     of your testimony.

 6             We're going to redact her name, because she's entitled to

 7     protection from the Trial Chamber.

 8             THE WITNESS: [Interpretation] [Previous translation continues]...

 9     just pass over this.

10             MS. DAHL:  Your Honour, Mr. Seselj repeated --

11             THE WITNESS: [Interpretation] I can't allow you to declare me

12     paranoid.

13             JUDGE ANTONETTI: [Interpretation] Witness, you told us that

14     someone came to your door.  I immediately wondered who could have come to

15     get you, especially since earlier on you told us that somebody had tried

16     to kidnap you.  But apparently the person who came to see you is a staff

17     member of the Registry.  She didn't come to see you to kill you.  She

18     just wanted to ask you to go to the office, and this was following a

19     request made by the Judges or the Trial Chambers.  They wanted to see

20     you -- we wanted to see you.  We have nothing against you.  So if you

21     believe immediately that someone who is doing her job, who comes to see

22     you to tell you that you are going to testify, if you immediately jump to

23     the conclusion that someone is trying to murder you, then we're indeed

24     faced with a slight problem.

25             Okay, we've clarified this point.  There's no danger you're

Page 12108

 1     under.

 2             Ms. Dahl, you may proceed.

 3             THE WITNESS: [Interpretation] Two more words.  We can't just pass

 4     over this just like that.  What sort of transportation?

 5             JUDGE ANTONETTI: [Interpretation] What do you want to add?

 6             THE WITNESS: [Interpretation] You said I'm paranoid.  I'm not

 7     paranoid.  I left my home to go in the direction of the Tribunal.  I've

 8     been living in Belgrade for 35 years, so why would someone need to

 9     transport me from here to there, across the River Sava?  It's less than

10     two kilometres away.  Who is going to believe that an employee should

11     come over from Sarajevo to transport me?  Maybe I'm crazy, all right, but

12     don't ask me to be clever.

13             MS. DAHL:

14        Q.   You are not being candid with the --

15             THE WITNESS: [Interpretation] For half an hour -- to be sane for

16     half an hour and then crazy for another half an hour.

17             MS. DAHL:

18        Q.   Mr. Stefanovic, you are not being candid with the Court, are you?

19     You and I and my investigator had a telephone conversation last Tuesday,

20     where you told me and my investigator that you had made arrangements with

21     the Victim and Witness Unit to be picked up in time for your testimony

22     today.  You were not surprised, were you?

23        A.   Do you have that recording?  I wasn't surprised, but my family

24     was.  They alarmed my friends.  I hadn't taken a mobile phone with me.

25     You are trying to portray certain things here in a negative light, as far

Page 12109

 1     as I'm concerned, and you're not allowing me to explain.  It's nothing

 2     terrible.  Let me explain how it happened.  And you say, "Keep quiet,

 3     don't talk, calm down, you'll die here," I don't know what.

 4             I left my home.  I went out --

 5             JUDGE ANTONETTI: [Interpretation] Mr. Stefanovic, let's put that

 6     aside for the time being.  Ms. Dahl reminded you that she called you on

 7     Tuesday and she told you that a car would come and fetch you to take you

 8     to the office for the videolink testimony, and because of that, somebody

 9     came to see you.  There's nothing to add.

10             THE WITNESS: [Interpretation] That wasn't how it was.  Excuse me,

11     that's now how it was, Your Honour.  Madam Dahl has her conversation with

12     me recorded.

13             I received a subpoena on Friday from the Serbian police.  It was

14     my mother's Patron Saints Day, it was the feast day, the Holy Arcangel.

15     And I was summoned to report to the Tribunal at 1.00.  And the lady who

16     telephoned me -- every keeps telephoning.  Nobody wants to send a fax or

17     an e-mail or communicate in a civilised way.  They always call from a

18     no-number telephone, and then they ask whether I'm there, and then it's

19     whether I said something or not.  Madam Dahl has that conversation on

20     tape.

21             Last Tuesday, I was in the office of my lawyer, Zoran Stojkovic,

22     and we overlooked the fact that Friday was the Holy Arcangels' Day.

23     That's a family feast day which -- St. Michael, and that's the day when

24     the whole family gathers together and nobody leaves home.  I was supposed

25     to be at home.  But I apologised to Madam Dahl for that reason, and I

Page 12110

 1     said that the OTP had no need to contact me because I had sent written

 2     information to Judge Dilparic about my status and to the Tribunal in

 3     The Hague so there was no misunderstanding.  And you have the

 4     conversation on tape.  I did not agree to have it taped, but if you do

 5     have it, play it now.  I agree to have it played, the conversation on

 6     Tuesday between myself and the Prosecutor, Madam Dahl.

 7   (redacted)

 8   (redacted)

 9             JUDGE ANTONETTI: [Interpretation] Mr. Stefanovic, we have no

10     recording, and it's not a common practice to record all telephone

11     conversations.  I, for one, do not have any recording at my disposal.  So

12     you are asking for this recording.  We don't have a recording.

13             THE WITNESS: [Interpretation] [Previous translation continues]...

14     conversation and I said don't.

15             JUDGE ANTONETTI: [Interpretation] What I'm interested in, and

16     it's also in the interests of Mr. Seselj, what I'm interested in is for

17     us to go back to the topic of the Serbian Radical Party.  That's the

18     purpose of your testimony.

19             Ms. Dahl, you may proceed.

20             THE WITNESS: [Interpretation] I just have a comment to make.  I'm

21     not interested in Seselj -- in the interests of Seselj, that is.

22             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, please put your

23     questions to the witness.

24             MS. DAHL:  Your Honour, I don't think I got an answer to the

25     question about whether Mr. Stefanovic had been threatened with death in

Page 12111

 1     or before 1994 which caused him to remain in his position as

 2     secretary-general longer than he wanted to.

 3        Q.   Mr. Stefanovic, did you or did you not receive a death threat

 4     from Mr. Seselj at that time?

 5        A.   No.

 6        Q.   Did you have an opportunity --

 7        A.   I can explain, but you're not allowing me to explain what this is

 8     about.

 9             MS. DAHL:  Your Honour, with the Chamber's permission, I'd like

10     to move on to the activities during the war.

11             JUDGE ANTONETTI: [Interpretation] Please proceed.

12             MS. DAHL:

13        Q.   You mentioned before the break that the Radical Party was

14     interested in securing publicity and popularity for itself.  Did you have

15     the occasion to accompany Mr. Seselj when he gave speeches in 1991?

16        A.   Absolutely, yes, and it's quite normal that the party wanted as

17     much publicity as possible in order to attract the largest possible

18     number of voters.  Every party does the same, both the Democratic and

19     Republican Parties in America and the National Front in France, and any

20     European party, they all want to attract as many voters as possible in

21     order to get the biggest piece of pie they can in the elections.  That's

22     the reason why parties exist.

23        Q.   Mr. Stefanovic, when you went with Mr. Seselj in 1991, when he

24     gave different speeches, where did you go?

25        A.   Wherever they invited us or where it was in our interests to go.

Page 12112

 1        Q.   Did you travel in a place --

 2        A.   To --

 3        Q.   -- that Mr. Seselj referred to as Eastern Slavonia?

 4        A.   In Belgrade, the term "Eastern Slavonia" is something everybody

 5     uses, not just Seselj.  You are probably referring to the villages around

 6     Vukovar, Vinkovci and so on.  That's probably what you're referring to.

 7     The answer is, yes, there were occasions when I went there.

 8        Q.   That region refers to areas that are presently in Croatia?

 9        A.   I don't know what you're trying to say by that.

10        Q.   I'm trying to get the geography.

11        A.   They're part if Europe, if Croatia enters.

12        Q.   Can you give the Trial Chamber the gist of Mr. Seselj's

13     speeches --

14        A.   "Eastern Slavonia," in Belgrade, is a term that's commonly used.

15             MS. DAHL:  Your Honour, with the Chamber's permission, may I put

16     some leading questions to the witness to see if we can get through this

17     bit about geography?

18             JUDGE ANTONETTI: [Interpretation] Yes, please proceed.  We'll try

19     to save time.

20             MS. DAHL:

21        Q.   Is the area referred to as Eastern Slavonia located within

22     present-day borders of Croatia?

23        A.   Yes.

24        Q.   When Mr. Seselj made speeches in 1991 within the area called

25     Eastern Slavonia, was he -- how did he describe the land vis a vis

Page 12113

 1     Serbia?

 2        A.   Let me just add to clarify some things to you.

 3             Seselj and I promoted the party in Vienna also, and we said the

 4     same things in Vienna that we said in Eastern Slavonia.  It was a very

 5     similar speech, presenting the party platform.  Seselj drew the attention

 6     of the local population to the fact that they should not allow the

 7     genocide from 1941 to 1945 against the Serbs to be repeated, and he

 8     pointed out that this genocide could happen again.  Quite simply, he said

 9     they should not allow the Ustasha to take them to the killing fields and

10     to camps once again.  Maybe that's what made this speech different from

11     other speeches, but I felt that this was quite natural, quite normal.  I

12     supported that policy.  Privately, personally, I'm on bad terms with

13     Seselj, but I cannot deny his policy.  I cannot challenge his policy.  I

14     still support it.

15             It would have been wonderful if Croatia had not committed

16     genocide either in World War II or now, if they had not expelled the

17     Serbs from their age-long halves and expelled them from the territory.

18     What would happen now if the French were to get up and expel the Germans

19     from Alsace or some other region?  I can give you 150 examples.  The

20     Southern Tirol, for example, Italy is paying the Germans for remaining to

21     live in Italy.

22        Q.   Mr. Stefanovic, let's stay with the history and the time period

23     we're discussing, please.  Did Mr. Seselj, in giving those speeches, say

24     that the area called Slavonia was Serbian land?

25        A.   I apologise.  I seem to have got caught up in these wires here.

Page 12114

 1     Let me just take a moment to disengage myself.

 2             Well, what do you mean by your question?  That's the fact today.

 3     It's Serbian land.  The Croats expelled the Serbs.  My country is -- I

 4     apologise.  What belongs to me is Aleksandar Stefanovic's land.  That's

 5     my property, and I have land in the village of Zabari, near Valjevo, and

 6     that's my land, it's called my land.  Now, if there was some land

 7     belonging to some man Pantovic, and if there's a whole village of Serbs,

 8     then it will be Serb land by the same token.

 9        Q.   Mr. Stefanovic, do you need to take a break?  I notice that you

10     are coughing.

11        A.   No.

12        Q.   Was there a War Staff within the Serbian Radical Party?

13             JUDGE ANTONETTI: [Interpretation] One moment.  Sir, before we

14     move on to the War Staff, which is a very relevant issue, one question.

15             You said that you went along with Mr. Seselj when he gave

16     speeches.  Do you remember when Mr. Seselj went to Zvornik?

17             THE WITNESS: [Interpretation] No.

18             JUDGE ANTONETTI: [Interpretation] Fine.  So you can't tell us

19     anything about that.  It's just a matter I wanted to clarify.

20             Ms. Dahl, you may proceed.

21             MS. DAHL:

22        Q.   Was there a War Staff within the SRS?

23        A.   Yes.

24        Q.   Do you recall when it was created?

25        A.   Well, it was created when the need arose for a number -- with a

Page 12115

 1     number of people who were from Serbia wanted to go -- well, through their

 2     own personal motives, their ethnic affiliation, to go and try and help

 3     those Serbs over there who were under threat by the Croats, so that this

 4     War Staff was the result of the need to transfer people who wanted to go,

 5     well, if I can say, the battle front and who did not have the means to do

 6     so, nor could they be transported or transferred to those war areas

 7     without somebody's help, so that that War Staff was a transmission --

 8     well, it wasn't a nice name, "War Staff," but actually it was just a

 9     branch or section for where people would report to -- from Nis.

10     [Indiscernible] 17 people would then be transported to Belgrade.  They

11     would be accommodated there and be given food, and then they were sent --

12     well, not in the sense of being sent, but -- I'm not quite familiar with

13     the work of the War Staff.

14             But, anyway, they were sort of sent to the Army of Yugoslavia or

15     told to contact the barracks of the Army of Yugoslavia, and then the army

16     organised this later on.  I don't know what it did.  But it was this

17     transmission, like a transmission between the people who wanted to help

18     the Serbs in jeopardy in those war-engulfed areas and the Army of

19     Yugoslavia -- yes, let me say that, or Army of Yugoslavia barracks and so

20     on.  But, anyway --

21        Q.   To your recollection, was a War Staff --

22        A.   Special attention to that was paid by --

23        Q.   I'm sorry, Mr. Stefanovic, let me ask the next question.

24             Was the War Staff created after the incident at Borovo Selo in

25     May 1991?

Page 12116

 1        A.   I can't remember exactly.  I don't know why that should be

 2     important.  The War Staff was led by Ljubisa Petkovic.  He was in charge

 3     at first for conducting a humanitarian mission, which was, in fact,

 4     assistance and help that these people required.  So he was in -- or all

 5     people who were in exile.

 6        Q.   Who was Mr. Petkovic's deputy?

 7        A.   Mr. Petkovic's deputy was Drazilovic, Zoran Drazilovic, I think.

 8     Drazilovic, anyway.

 9        Q.   In Mr. Petkovic's capacity as head of the War Staff, to whom did

10     he report within the SRS?

11        A.   It's like this:  You're now trying to lead me to say that it was

12     Seselj and then that Seselj wielded influence and was the number-one man.

13     What I'm trying to tell you is how things actually stood, and this is how

14     they were.  A really humanitarian organisation -- I can call it that,

15     yes, I can, and --

16        Q.   Mr. Stefanovic, answer my question, please.

17        A.   Well, I am answering your question, that's precisely what I'm

18     doing.  So this section or branch called the War Staff started off as a

19     humanitarian organisation.

20        Q.   Mr. Stefanovic, I had a specific question.  In his capacity as

21     head of the War Staff, to whom did Mr. Petkovic report within the Serbian

22     Radical Party?

23        A.   Well, it's like this:  Petkovic was the vice-president of the

24     Serbian Radical Party, so he could not have reported to me.  He had to

25     report to the president.  There was only the president that was superior

Page 12117

 1     to him, so that's logical.

 2        Q.   Who was the president?

 3        A.   But I think -- Seselj.

 4        Q.   You mentioned that the War Staff was recruiting people who wanted

 5     to assist the Yugoslav Army.  Can you tell me how they did that?

 6        A.   Well, I explained that three or four minutes ago.  These 20 young

 7     men and girls or whatever, a group of people, Serbs, whatever you like to

 8     call them, from the interior of the country, come to Belgrade, and then

 9     they knock at the door of the Serbian Radical Party and ask for

10     assistance so that they could reach Slavonia or wherever, some area that

11     was engulfed by the war.  And at that point, Ljubisa Petkovic, I suppose,

12     probably took us to Bubanj Potok and handed them over to the Army of

13     Yugoslavia.  So that is that, in simple terms.

14             What I want to do is to explain to you how the War Staff came

15     into being.  It was envisaged first as a really humanitarian organisation

16     which would assist, first of all, refugees from those areas, and I

17     remember that full well.  I remember a priest from Pakrac, a Serbian

18     Orthodox priest.  His name was Dragan.  And with a young, petit wife, he

19     came --

20        Q.   [Previous translation continues]... because we do not have

21     unlimited time, and I want to focus on the recruitment of volunteers and

22     the transferring of individuals to the front-lines.

23        A.   It's like this:  There was no recruiting by the Serbian Radical

24     Party, no recruitment, and I say that with all responsibility.  Nor did

25     any of these, well, conditionally speaking, volunteers go through having

Page 12118

 1     been influenced by the Serbian Radical Party at all.

 2        Q.   I want you to take a look at paragraph 16 of your statement, the

 3     first sentence that reads:

 4             "The SRS War Staff started recruiting volunteers after the

 5     Borovo Selo incident in May 1991."

 6             Can you find that sentence in your statement?

 7        A.   Just a moment.  Let me just read through that.

 8        Q.   Did you find the sentence?

 9        A.   Can I analyse this paragraph 16?  This is the first time that

10     I -- can I just take a moment to analyse it?

11        Q.   Mr. Stefanovic, tell me if what I read appears there at

12     paragraph 16, first sentence.

13        A.   What it says here, well, I have a slight correction to make in

14     the first sentence, those first two lines, and then after that everything

15     is correct as it states here.

16        Q.   Which correction --

17        A.   Just a bit distorted, but for the most part correct.

18        Q.   What correction do you want to interject to the first line or

19     first two lines?

20        A.   Well, I'm trying to explain this to you, but you don't want to

21     listen, you don't want to hear me, to help you to understand what the

22     function of the War Staff was.

23             It is true that when I go there in the morning, I would find

24     people there from various parts of the country, and then they would be

25     taken to the park over there where Seselj made his speeches.  Now,

Page 12119

 1     whether he was careful in what he said or not, well, I never heard Seselj

 2     incite people to go, let alone do anything else, so that's -- or kill

 3     people, but -- so that can remain, that other part, but these first two

 4     lines are the ones that need correcting.

 5        Q.   [Previous translation continues]... correction, so what is it,

 6     because I need to bring your attention to another sentence and I want to

 7     move on.

 8        A.   Well, it's rather an unwieldy interpretation in those first two

 9     lines, unfortunate interpretation, but you don't want to hear me.  The

10     War Staff was not an SS division, it was a humanitarian organisation

11     which really did rally -- well, not go around collecting, in that sense,

12     just as in our poem about the little girl picking strawberries, but,

13     anyway, the volunteers came there and -- well, not volunteers, actually.

14     They were just people -- well, we refer to them as volunteers, but they

15     were just people who wanted to go and assist those Serbs under jeopardy

16     in the war-engulfed areas.  Otherwise, everything else is correct.  And

17     Seselj -- well, not only Seselj, but they would gather together in the

18     park, and then he would say --

19        Q.   Can I ask you to stop, please.  I want to turn your attention to

20     the paragraph immediately above that, in the middle, paragraph 15 in the

21     middle.  It says:

22             "The role of the War Staff was to recruit volunteers and send

23     them to the front-line on behalf of the JNA, although I am not aware of

24     any official agreement between the JNA and SRS."

25             Does your statement say that?

Page 12120

 1        A.   Well, look, here --

 2        Q.   Mr. Stefanovic, I want a "yes" or "no," not a, "Well, look."

 3     Either the statement says that or it doesn't.  Please answer the question

 4     that's presented to you.

 5        A.   For me to answer -- well, I can't give you a yes-or-no answer.

 6     I can explain it to you, explain everything it says here and what the

 7     truth of it was, but I can't just give a yes-or-no answer, because it's

 8     both "yes" and "no," the answer is both "yes" and "no," and I'll tell you

 9     what the "yes" is and what the "no" is in just a moment, if you're

10     interested.

11        Q.   Mr. Stefanovic, the statement says --

12        A.   If you're interested, that is.

13        Q.   In paragraph 15, the statement says:

14             The role of the War Staff was to recruit volunteers and send them

15     to the front-line on behalf of the JNA, "although I am not aware of any

16     official agreement between the JNA and the SRS."  That's what the

17     statement says; right?

18        A.   Well, that's what it says here, that's how it's written, but I

19     can't say that that's how it was.  The fact of the matter is that this

20     act of people arriving to the premises of the Serbian Radical Party you

21     refer to as recruitment, whereas it's quite a different action

22     altogether, and I would describe it in different terms.

23             The people that come to the premises of the Serbian Radical Party

24     were, yes, that's true, sent on to the JNA or the Army of Yugoslavia,

25     whatever it was called, and I have no idea whatsoever --

Page 12121

 1             JUDGE ANTONETTI: [Interpretation] Witness, Witness, we're losing

 2     time here.  I'll go to the point.

 3             This War Staff, in your view, did it have an operational

 4     function?  In other words, was it controlling the volunteers on the

 5     battlefields or was the role of the War Staff only to send volunteers who

 6     would come to the premises?  In other words, does that mean that the War

 7     Staff had nothing to do with the combat operations?

 8             Please, please, give an answer to that question, and I think that

 9     would help everybody.

10             THE WITNESS: [Interpretation] The latter is correct, the latter

11     part of your question.

12             Let me repeat and clarify.  What is correct is this:  That the

13     people came there, well, whether they were volunteers or whatever, people

14     who wanted to help those Serbs over there, and it is also correct that

15     the party would transfer those people to the JNA barracks and that every

16     further supervision over those people ceased at that point.  Now, what

17     the army did, the army probably armed them, gave them uniforms, was in

18     command of them on the battle front.  If somebody was killed, they would

19     send them back, and so on.

20             Is my answer clear?

21             THE ACCUSED: [Interpretation] I have an objection to make,

22     Mr. President.

23             If the Trial Chamber recalls, these questions were explained in

24     detail during Expert Theunens' testimony and some other witnesses.  This

25     is -- well, now we're having the witness go through these things again,

Page 12122

 1     which he wasn't aware of at the time, that wasn't his competence, so

 2     let's not trouble him with that.  And we know that the party sent

 3     volunteers to Serb villages in Slavonia up until September 1991.  From

 4     September 1991, everything was under the JNA afterwards, and we've

 5     clarified that here a number of times, whereas we're giving the witness a

 6     hard time here with leading questions on the basis of a statement

 7     compiled by the OTP, and who knows under what conditions he put his

 8     initials to that, and that is what I mean when I say "giving the witness

 9     a hard time."

10             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, nobody's giving the

11     witness a hard time, nobody's torturing the witness.  If he was under

12     torture, I'm sure he would be able to ask us to stop.  I think he's

13     provided an answer.  What you've said was already said many, many times

14     before.

15             So please, Ms. Dahl, proceed.

16             MS. DAHL:

17        Q.   From your knowledge, working at the headquarters of the SRS, can

18     you compare the volunteer units recruited by the SRS to the combat units

19     of, for instance, the JNA, or the Red Berets, or Arkan's?

20             THE ACCUSED: [Interpretation] Objection.  What kind of question

21     is that?  The Red Berets or Arkan's men?  That is impermissible.  The

22     Red Berets were never Arkan's groups, and when the Red Berets were

23     established sometime in 1996, a number of former Arkan's men joined up,

24     but the Prosecutor is making his own conclusion, that the Red Berets were

25     Arkan's groups or troops.

Page 12123

 1             JUDGE ANTONETTI: [Interpretation] Ms. Dahl --

 2             THE WITNESS: [Interpretation] Do I have the right to say

 3     something?

 4             JUDGE ANTONETTI: [Interpretation] [Previous translation

 5     continues]... your question in such a way that the witness can provide an

 6     answer.  Maybe you can ask him whether he knew that Arkan existed,

 7     whether he knew that there were particular units, and if he says "yes,"

 8     then you may proceed on that basis.

 9             Witness, wait until Ms. Dahl rephrases her question.

10             MS. DAHL:

11        Q.   Based on --

12             THE WITNESS: [Interpretation] Just a moment.  May I be allowed to

13     say something?

14             JUDGE ANTONETTI: [Interpretation] What do you wish to say,

15     Witness?

16             THE WITNESS: [Interpretation] Are you asking me, the witness?

17             JUDGE ANTONETTI: [Interpretation] Yes, yes.  You said, "May I be

18     allowed to say something," so I'm asking you, what do you wish to say?

19             THE WITNESS: [Interpretation] When the Prosecutor came -- what

20     was the person before Ms. Dahl?  He was an American from Boston.  What

21     was his name?  Anyway, he came, and he discussed this with me in detail,

22     he talked to me in detail, and I explained that I was in charge of

23     politics in the party, not the war or whatever else.  So I can improvise,

24     of course.  It seems a bit -- it would be ludicrous for me to take

25     Seselj's side and say, yes, that's how it was in September or whatever,

Page 12124

 1     because please believe me, I don't know about that.  I don't know that

 2     any volunteers were sent up until September.  If you want to believe me,

 3     then do.  But what I heard from him, I don't think it goes to his

 4     advantage.  Well, it does or it doesn't.  I haven't followed this trial,

 5     so I don't know what is in his interests or not.  But the fact that he

 6     just put forward, I say with full certainty that it is correct, but I

 7     couldn't remember it because at that time the Radical Party was engaged

 8     intensely on setting up boards in various parts of Serbia, and outside

 9     Serbia, too, in Europe, England, Germany, so that my involvement was

10     towards setting up these various boards rather than sending these --

11     well, there's been a lot of speculation about what the War Staff is, and

12     volunteers, and who is Ljubisa Petkovic going to beat.  It was a

13     humanitarian organisation.  We took Ljubisa Petkovic, who was a man who

14     was incapable of doing any army service.  All he could do was to take

15     them beans or potatoes or put up some -- accommodate someone from the

16     war-infested area.

17             Yes, it was called "the War Staff," but its function was not

18     that.  It was to feed people, to lodge people.

19             MS. DAHL:

20        Q.   Mr. Stefanovic, did the JNA have the most disciplined combat

21     units?

22        A.   Well, you know what?  I was never up at the front.  How should I

23     know?  You want me now to analyse this.  I don't think it had the most

24     disciplined units, or maybe it did.  Maybe Arkan had better men, or

25     whoever did.  I don't really know.  I didn't deal with war matters or an

Page 12125

 1     analysis of the war, an analysis of the JNA.  Had I been a JNA commander,

 2     I would have taken Zagreb and Ljubljana in three days' time and solved

 3     the whole problem in Yugoslavia.  The United States supported various

 4     proposals.

 5             JUDGE ANTONETTI: [Interpretation] Witness, please focus on the

 6     questions, because you say, "Had I been a JNA commander, I would have

 7     taken Zagreb in three days."  Maybe, but that's not really the question.

 8             Ms. Dahl.

 9             MS. DAHL:

10        Q.   You were interviewed in 2006 by members of the Office of the

11     Prosecutor; right?

12        A.   Yes.

13        Q.   And you told them during that interview that the JNA had the most

14     disciplined combat units; correct?

15        A.   I don't know what I said.  I really don't know.

16        Q.   And in --

17        A.   Do you expect me to remember what I told the investigators about

18     the JNA after all this time?

19        Q.   Paragraph 15 of your statement says that:

20             "The JNA had the most disciplined combat units."

21             Doesn't it?

22        A.   Well, what it says there, it says.  As far as the most

23     disciplined combat units were concerned, well, I suppose that's all

24     right.  What can I do?  So my answer is yes.

25        Q.   And the SRS volunteers --

Page 12126

 1        A.   And I think they ought to be the most disciplined.

 2        Q.   And the SRS volunteer units were men of poor quality; correct?

 3        A.   Well, what I meant is that they weren't officers, professional

 4     soldiers; they were ordinary citizens who had to go.  If they went to

 5     war, they had to have some training.  That's what I meant.  I didn't mean

 6     to say that they were not brave soldiers.  I think they were brave,

 7     but -- men, but they weren't trained properly.  I didn't mean to say that

 8     they were weaklings.

 9        Q.   What is a Chetnik vojvoda?

10        A.   Well, that's a man who deserves to be a Chetnik vojvoda.  It's a

11     title, "Chetnik vojvoda," and that title is something that emerges from

12     the traditions of the Serbian army, like a Superman, Tarzan.

13        Q.   Does Seselj appoint persons within the SRS to be Chetnik

14     vojvodas?

15        A.   I think so.  He didn't appoint me, and I'm sorry for that, and

16     I'm angry at him because of that and all the rest of it, but I don't know

17     much about that.  They went to some village over there on Mount Romanija,

18     a number of people went there.  Perhaps they didn't deserve to be given

19     these attractive titles, but they became Chetnik vojvodas over there.  He

20     had the right to promote people to vojvodas, since Momcilo Djuric

21     promoted him to a Chetnik vojvoda.  So all this was done with certain

22     norms, customs, whatever you like to call them, that were in force among

23     us Serbs and in the Serb army.  So I don't see why I wasn't awarded that

24     title.

25        Q.   Did Mr. Seselj appoint Ljubisa Petkovic to be a Chetnik vojvoda?

Page 12127

 1        A.   I think he did, yes.

 2        Q.   How about Zoran Drazilovic?

 3        A.   Can I repeat part of my answer?  I didn't take part in that.  I

 4     don't know what year that was.  Anyway, they went to Bosnia and I stayed

 5     on in Belgrade.  A group of men went there.  I think you have a list of

 6     the names and surnames and middle names of the people who were given the

 7     title.  I see that it says "19, Ljubisa Petkovic," and Zdravko Abramovic,

 8     Jovo Stojic, Tomislav Nikolic, Slavko Aleksic, Srecko Radovanovic,

 9     nicknamed Debeli, Tode Lazic, Branislav Vakic, Mirko Blagojevic, a whole

10     list there, Branislav Gavrilovic, Manda.  That's what it says in

11     paragraph 19, so let me just read that.

12        Q.   Based on your interactions with Mr. Seselj while you were working

13     at the party headquarters, did you have an opportunity to observe whether

14     Mr. Seselj kept himself informed of activities of the party?

15        A.   Well, I informed him on a daily basis.  He was very well informed

16     about party activities, so of course he'll follow the activities and

17     inform himself of the activities of the party.  So my answer is, yes, he

18     did follow the activities of the party.

19        Q.   Did you observe whether or not Seselj informed himself of the

20     activities of the volunteers at the front-line?

21        A.   At that time, everyone in Serbia, especially people involved in

22     politics, were very interested in what was happening at the war theatre,

23     so Mr. Seselj was also interested, of course.

24        Q.   Did you have the opportunity to observe that Seselj was worried

25     or concerned about the activities of the volunteers at the front-line?

Page 12128

 1        A.   You know what?  What do you mean "be concerned"?  I don't

 2     understand your question, I don't understand your question.  Excuse me,

 3     but I don't understand your question.  Could you clarify what you want me

 4     to ...

 5        Q.   In paragraph 19, your statement says:

 6             "I observed that Seselj was worried about the activities of the

 7     volunteers at the front-line."

 8             Perhaps, Mr. Stefanovic, you can clarify by what you meant in

 9     that statement.

10             THE ACCUSED: [Interpretation] Objection.  The Prosecutor is

11     suggesting to the witness that the witness actually stated this.  What he

12     meant when he wrote this or, rather, what did the investigator mean who

13     wrote this down?  The investigator should be brought here to answer the

14     question about what he thought when he was -- what he meant when he was

15     writing this down.  But now the Prosecutor is asking the witness what he

16     meant when he stated that, instead of asking him, "Did you really say

17     this?"  This was all written down by the investigator.  Every statement

18     is written down by investigators.

19             JUDGE ANTONETTI: [Interpretation] The Chamber observes that the

20     witness makes statements.  He explained that he was not in full agreement

21     with what he originally stated.  Now Ms. Dahl is putting questions to the

22     witness in order to obtain some clarification.

23             Ms. Dahl, you may proceed.  I don't think you have much time

24     left.  I'll turn to Madam Registrar so that she tells us how much time

25     you've got left.

Page 12129

 1             THE WITNESS: [Interpretation] Wait a minute.  Your Honour, you've

 2     just said something disastrous about me, or you may have the completely

 3     wrong impression.

 4             It's true, I couldn't say to you -- Your Honour, when The Hague

 5     Tribunal asked me to contact the Serb Radical Party and ask Seselj

 6     whether he wanted to come to Belgrade to be tried in Belgrade, and they

 7     said that he would not get more than ten years in jail and that he would

 8     be released provisionally as soon as the trial was over, I contacted

 9     Dragan Todorovic.  I spoke to him in a cafe, a pizzeria cafe in New

10     Belgrade, and I told him what the Tribunal wanted from Seselj.  I told

11     him to ask Seselj.

12             A few days later, Dragan Todorovic came to see me, and he said,

13     "Seselj rejected this in disgust.  He doesn't want to be tried in

14     Belgrade."  And I told this to the representatives of the Tribunal, and

15     they were surprised.  They said, "What a fool he is.  Why doesn't he want

16     to do this?"  I thought, and I still think, that all this is a farce,

17     whether there was an indictment against Seselj when he left.  Now they're

18     asking was there a staff, was there not a staff.

19             You say I made a statement and I don't agree with this statement.

20     I did give a statement, and I agree with it, but there are some things in

21     there that have nothing to do with what I said, especially these

22     ridiculous paragraph numbers here, which are ridiculous.  Whatever I say

23     as a witness is being doubted.

24             MS. DAHL:  Let me try to save some time, Your Honour.

25             The witness stated dated 16 June 2006 includes a document table

Page 12130

 1     that records Mr. Stefanovic's comments and observations about the

 2     documents.  I'd like to tender the 2006 statement with the document table

 3     and the associated documents.  Several of them are already in evidence.

 4             I can conclude my examination, and Mr. Seselj can examine based

 5     on the statement, but I think that the witness has demonstrated that he

 6     does not adopt this statement.  And we can lay the additional foundation

 7     of reliability that the Chamber might want through another witness, but

 8     the statement is what he told the representatives of the OTP that

 9     recorded the statement, and he's signed it and his signature is on every

10     page in his own language.

11             JUDGE ANTONETTI: [Interpretation]  Ms. Dahl, there are two

12     statements, the 2003 and 2006 statements.  Do you tender both?

13             MS. DAHL:  We tender the 2003, but it's subsumed completely

14     within the 2006.  I think it has the same indicia of reliability in the

15     fact that the similarities corroborate each other, but the 2006 stands

16     alone in its completeness.

17             JUDGE ANTONETTI: [Interpretation] I will confer with my

18     colleagues.

19             THE ACCUSED: [Interpretation] Objection.

20             JUDGE ANTONETTI: [Interpretation] We will give you the floor,

21     Mr. Seselj, but first of all I would like to confer with my colleagues.

22                           [Trial Chamber confers]

23             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, what would you like

24     to say?

25             THE ACCUSED: [Interpretation] It's absolutely impermissible to

Page 12131

 1     admit the statement into evidence, because the statement was not written

 2     by the witness.  The statement was written by The Hague investigators.

 3     If the statement could be admitted into evidence, there would be no point

 4     in bringing any witnesses here or examining any witnesses.  Then all the

 5     103 or 4 witnesses could be dealt with in the same way.  Their statements

 6     could be admitted into evidence, and we would get it all over with.

 7             This is all very cheeky.  This is very impertinent.  You're

 8     putting in statements under 92 ter, 98 bis, 92 quater, and so on and so

 9     forth, and this whole trial looks like a distance learning course.  And

10     these statements were signed by witnesses under God knows what

11     circumstances, and this witness is demonstrating here under what sort of

12     pressure he signed those statements, whether he wants to admit it or not.

13                           [Trial Chamber confers]

14             JUDGE ANTONETTI: [Interpretation] The Trial Chamber, at the

15     request of the Prosecution, decides to give two MFI numbers, one MFI

16     number to the 2003 statement and another one to the 2006 statement.  The

17     Chamber considers that it is in the interests of justice, even if the

18     witness challenges the very content of the statements.  There was one in

19     2003 and one in 2006.  The probative value of such statements will be

20     assessed by the Trial Chamber at the end of the proceedings, in the light

21     of other evidence, but of course you will have to ask for the document to

22     be added to the 64 ter list.

23             MS. DAHL:  Your Honour, in order to upload the statements and

24     make them available, they have 65 ter numbers 7416, which corresponds to

25     the 2003 statement, and 7417, which corresponds to the 2006 statement,

Page 12132

 1     and we would ask the Court to add that to our 65 ter list.

 2             JUDGE ANTONETTI: [Interpretation] Madam Registrar, can we have

 3     two MFI numbers for both statements, please.

 4             THE REGISTRAR:  Your Honours, 65 ter number 7416 will become

 5     Exhibit P633 marked for identification, and 65 ter number 7417 will

 6     become Exhibit P634 MFI as well.

 7             JUDGE ANTONETTI: [Interpretation] Very well.

 8             THE ACCUSED: [Interpretation] Mr. President, you asked for marked

 9     for identification numbers, whereas the Registrar has given you permanent

10     numbers, as far as I was able to observe.

11             JUDGE ANTONETTI: [Interpretation] Wait a minute.  No, because on

12     line 2, page 74, there's a reference to an MFI number.  But please, Madam

13     Registrar, could you please reconfirm that these are MFI numbers.

14             THE REGISTRAR:  Both exhibits are marked for identification.

15             JUDGE ANTONETTI: [Interpretation] Very well.  Ms. Dahl.

16             MS. DAHL:  I'd like to put into the record the 65 ter numbers

17     that correspond with the document table so that the Chamber can consider

18     whether to admit those documents, because they've been commented upon by

19     the witness.  65 ter 239, 65 ter 369, 65 ter 404, 65 ter 416, 65 ter 431,

20     65 ter 433, 65 ter 436, 65 ter 473, 65 ter 990.  The video material in

21     the document chart relates entirely to 65 ter 6066, which is a transcript

22     of Mr. Seselj's interview given to the filmmakers of "Death of

23     Yugoslavia."  65 ter 1836, 65 ter 778, 65 ter 192, 65 ter 1816, 65 ter

24     1636, 65 ter 1800, 65 ter 1802, 65 ter 1108, 65 ter 1039, 65 ter 1829,

25     and, finally, 65 ter 1018.

Page 12133

 1             I have skipped over the documents that Mr. Stefanovic commented

 2     on that have already been admitted into evidence.  The document index at

 3     the front of our binders indicates which ones I've skipped.

 4             JUDGE ANTONETTI: [Interpretation] Could we have MFI numbers for

 5     all these documents, Madam Registrar.

 6             Mr. Seselj.

 7             THE ACCUSED: [Interpretation] Mr. President, where did the

 8     witness comment on these documents?  Where did he state his position on

 9     them?  You never accepted anything like this previously.  This is the

10     first time you've done something like this.

11             And, secondly, by admitting these witness statements into the

12     file, this is something that no Trial Chamber has ever done in the

13     history of this Tribunal, which I think is the worst tribunal that has

14     ever existed anywhere in the world.  It only happened in the case of

15     Slobodan Milosevic because there was no one there to protect his

16     procedural rights, because Mr. Milosevic dealt only with the merits of

17     the case and there was no one to be concerned about his procedural

18     rights.

19             The Prosecutor even made up Rule 29 bis and a half because the

20     Rules 92 ter and 92 quater did not exist at the time.  You can look at

21     the transcript of that case.

22             MS. DAHL:  Could I respectfully request the Chamber to ask

23     Mr. Seselj to lower his voice, because I cannot hear the translation

24     because of the volume of his speaking.  Thank you.

25             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, we've taken note of

Page 12134

 1     your observations.  This is the reason why we're asking for an MFI number

 2     to be given to those documents.  It doesn't prejudge in any way our final

 3     decision.

 4             Madam Registrar, please, can we have MFI numbers for all these

 5     documents.

 6             THE REGISTRAR:  Your Honours, 65 ter number 239 is now

 7     Exhibit P635.  369 is Exhibit P636.  404 is Exhibit P637.  416 is

 8     Exhibit P638.  431 is Exhibit P639.  433 is Exhibit P640.  436 is

 9     Exhibit P641.  473 is Exhibit P642.  990, Exhibit P643.  6066 is

10     Exhibit P644.  1836 is Exhibit P645.  778 is Exhibit P646.  192 is

11     Exhibit P647.  1816 is Exhibit P648.  1636 is Exhibit P649.  1800 is

12     Exhibit P650.  1802 is Exhibit P651.  1108 is Exhibit P652.  1039 is

13     Exhibit P653.  1829 is Exhibit P654.  And 1018 is Exhibit P655.  All of

14     them marked for identification.

15             JUDGE ANTONETTI: [Interpretation] Ms. Dahl, you've completed your

16     examination-in-chief, then.

17             Witness, before the break, I have a number of quick questions to

18     put to you in order to supplement some of your answers.

19             As of today, I understand that you are running a company, but are

20     you still in politics or have you stopped altogether?

21             THE WITNESS: [Interpretation] I'm still involved in politics, and

22     you're right, I'm at the head of a company.  But let me say one thing.  I

23     see that there's a lot of fuss about something, and I can clarify some

24     points for you, something that would make it much clearer about these

25     statements.

Page 12135

 1             JUDGE ANTONETTI: [Interpretation] Witness, let me stop you here.

 2     What I'm interested in is your involvement in politics.

 3             You've just told us that you are still involved in politics.  In

 4     what party, in what political party?

 5             THE WITNESS: [Interpretation] Currently, I'm not involved in a

 6     political party, but two or three years ago, with a friend of mine, I

 7     established a party called Hrast, meaning "oak."  It's not established in

 8     the electorate.  But I'm involved in politics at a lower level, at the

 9     level of municipal committees and so on and so forth, but that's

10     something that one cannot bypass in these times.

11             JUDGE ANTONETTI: [Interpretation] Very well.  In your view, when

12     did you leave the Serbian Radical Party, when did you distance yourself

13     from Mr. Seselj in 1996?  Why, for what reason?  For political reasons,

14     for personal reasons, because you didn't get along with him anymore?

15             THE WITNESS: [Interpretation] It was -- well, how can I classify

16     it.  It was neither personal, nor did it have to do with the party

17     platform.  It had to do something with staffing issues, where I was

18     bypassed and overlooked, and I think that was the reason for our

19     disagreements, which led me to leave the Radical Party.

20             JUDGE ANTONETTI: [Interpretation] When I listened to your

21     explanations about your function as a secretary-general, I had the

22     feeling that you did not have any actual political role, you were dealing

23     with purely administrative matters.  Am I wrong?

24             THE WITNESS: [Interpretation] I had a large influence on the

25     organisation of the party on press conferences, which were very

Page 12136

 1     important.  It's very important in the party to get as much media support

 2     as possible, to hold as many rallies as possible, to have as many

 3     appearances on television and radio broadcasts and in the media as

 4     possible, so that my role was by no means small.  But ...

 5             JUDGE ANTONETTI: [Interpretation] Fine.  You remained in your --

 6     in that position of secretary-general until 1995.  During that period

 7     from 1991 to 1995, you know better than anyone else that a number of

 8     events took place.  Did you receive any information according to which

 9     volunteers of the SRS committed crimes?  And if that is the case, what

10     measures did you take at the highest levels of the party?

11             THE WITNESS: [Interpretation] I still think that the volunteers

12     of the Serbian Radical Party did not commit any crimes.  They knew

13     nothing about crimes, nor were they able to commit crimes.  They were

14     mostly under the command of the army and the local people there, the

15     Territorial Defence or whatever it was called, and I don't know that a

16     single member of the Radical Party committed a crime.  Had we known about

17     this, I would have been the first to react and to report that person, but

18     I have no knowledge of that.

19             In my statement, which I have never seen before, I am sure I said

20     at least ten times to the investigators that I did not know of a single

21     crime committed by Vojislav Seselj.  Why doesn't Madam Dahl want to talk

22     about her meeting last year?  Does it say that in the statement or not,

23     because I didn't read that statement.

24             JUDGE ANTONETTI: [Interpretation] No, we don't have this

25     document, and that's to do with your relations between yourself and the

Page 12137

 1     Prosecutor and it's not relevant.

 2             I read your statement with great interest, however.  You're

 3     challenging the veracity of your statement, but nonetheless I had the

 4     feeling that at the beginning of the Serbian Radical Party, you had an

 5     important role to play within that organisation.  I read, for example,

 6     that you organised a symbolic trial of Tito, and you stated that

 7     Mr. Seselj drafted the indictment against Tito.  You explained that this

 8     was done to do away with the cult of personality around Tito.  Do you

 9     remember that?

10             THE WITNESS: [Interpretation] Yes, yes, very well.

11             JUDGE ANTONETTI: [Interpretation] When did that take place?  Did

12     that take place after Tito or while he was still alive?

13             THE WITNESS: [Interpretation] It was ten years after Tito's

14     death, but the personality cult of Tito still existed in Yugoslavia.

15     There was a law on the protection of the name and work of Tito.  You

16     couldn't say that the existing regime was no good, because they would

17     immediately take out these paragraphs, put them on the table, and say,

18     "You spoke against Tito, and that's a crime under paragraph this and

19     that."  You had to remove the cult.  Mao Tse-tung had a cult, Tito had a

20     cult.  Even if they die, the cult persists.  After the death of Mao

21     Tse-tung, China did not change course politically or in any other way.

22     The existing regime could not be removed until Tito's cult was removed,

23     because there was a law under which you could not criticise the existing

24     system.

25             Do you understand me?  There was a law on the protection of the

Page 12138

 1     name and work --

 2             JUDGE ANTONETTI: [Interpretation] Okay.  There's maybe one topic

 3     where you could be very helpful to us.  I'm talking about the

 4     relationship between Milosevic and Mr. Seselj.

 5             If you were asked to define this relationship, were they good

 6     relations or rather difficult, politically speaking?  What is your

 7     feeling about that?

 8             THE WITNESS: [Interpretation] Well, look here.  If you want me to

 9     be quite honest and open, we have to go back to the beginning of my

10     testimony, when they tried to persuade me, when I said, "Hello, Prime

11     Minister, I don't know that Seselj committed a single crime."  He said to

12     me, "You don't have to talk about crimes.  Go and discredit him

13     politically.  Go and discredit him politically."  And that was a task

14     assigned to me, that I should say something bad about him.

15             And now, Judge, I'm looking at these points this lady gave me.

16     I'm looking at points 21 and 26.  Only a madman could say things like

17     that.  In paragraph 26, it's all invented, from "A" to "Z".  This is the

18     first time I've read my statement, so I cannot state my position on it in

19     the way that you and Madam Dahl are doing.  I just read points 21 and 26,

20     I scanned them, and what it says here in 26 I could have only said if I

21     had gone completely mad, because as for Jovan Marijanovic, I never saw

22     him, and Bozidar -- General Bozidar Stefanovic is a man I've never seen

23     in my whole life.  And now it says here that they were political allies,

24     and this tells me everything I need to know, Judge.  I've only read this

25     paragraph now.  General Domazetovic, I don't know if Seselj knows him at

Page 12139

 1     all.  Frenki Simatovic, of all people, I only met him a few years ago.  I

 2     did sign and I'm telling you, if they had told me then, "Go and discredit

 3     him," what could I do?  Seselj is a very decent man.  Had I said that,

 4     they would have said, "You've gone crazy."  They said, "Go and discredit

 5     him," I don't know of any crimes that he committed.  I'm asserting here

 6     that he did not commit any crimes.  I'll probably never speak to Seselj

 7     again in my life, but I'm telling you he's not a criminal when he was

 8     telling people off.

 9             JUDGE ANTONETTI: [Interpretation] Witness, could you please

10     explain something, something in relation to what you stated in 2005 about

11     assassination projects instigated by Mr. Seselj.  You, yourself,

12     supposedly stated that you had been threatened.  Why did you make such a

13     statement in 2005, on the 4th of August, 2005?

14             THE WITNESS: [Interpretation] I'll explain that in detail to you.

15     It was like this, here's why I said that:

16             When I saw what the Tribunal wanted and my role in discrediting

17     Seselj, then an idea came to me, and that is that some generally-known

18     facts which the papers wrote about, which were on television and so on,

19     I -- that I was asked to say, yes, that's what Seselj did, or I would say

20     that, but those were individual things.

21             The killing of Pasko, Slobodan [as interpreted].  After that

22     incident, I became interested about that killing and came by a file which

23     the Belgrade -- dossier which the Belgrade police compiled about the

24     killing of Pasko Jovic, and it still exists here in Belgrade at the

25     police station, and it said that a maniac, a sexual maniac, perpetrated

Page 12140

 1     that killing and then had intimate relations with this dead woman.  I

 2     don't want to talk about that here, but Jovic had at least 15 interviews

 3     saying that Seselj had killed his wife, and then he involved me and

 4     engaged some policemen, heaven knows what.  And then I skillfully went

 5     and said that -- well, I said that the grounds for that story were

 6     erroneous and that Jovic made false accusations against Seselj with

 7     respect to Pasko, and I said, "Well, there's this other man who is

 8     accusing Seselj of killings."  Now, as far as his threats to me, they

 9     were uttered by someone else.  I don't have direct knowledge of this.

10     Somebody who was angry and arguing with Seselj wanted to influence me and

11     persuade me to say things against Seselj and undertake certain acts and

12     so on.  So this is secondhand information.  It's not my direct knowledge.

13             I conducted an investigation, large-scale investigation, about

14     the killing of Pasko, and I came to these conclusions, so I'm not denying

15     what it says here.  I did say all that, but with a certain intention in

16     mind and not these silly things that it says in paragraph 21.  I don't

17     know what it says otherwise.  If I were to take over all these documents,

18     I would have to look at them and then say what I think.

19             JUDGE ANTONETTI: [Interpretation] You accused Mr. Seselj with

20     respect to a number of murders or assassinations, and because of that you

21     were granted protective measures.  But when you did all this, what was

22     your purpose?  Who were you trying to help?

23             THE WITNESS: [Interpretation] A service -- well, not a service,

24     it was a type of conditioned order by the president of the government of

25     Serbia, the prime minister of Serbia, and the then Prosecutor of

Page 12141

 1     The Hague Tribunal, Carla Del Ponte, because I talked to

 2     Dr. Zoran Djindjic about this directly, and he said, "You'll never appear

 3     as a witness in The Hague, I guarantee that, but go and clear things up.

 4     These people have not understood anything.  They started gritting their

 5     teeth and so on."

 6             JUDGE ANTONETTI: [Interpretation] So if I understand properly,

 7     you're telling us that the former prime minister, who later was murdered,

 8     he's the one who asked you to make a number of statements to accuse

 9     Seselj; is that what you're telling us?

10             THE WITNESS: [Interpretation] Politically compromise Seselj.

11             JUDGE ANTONETTI: [Interpretation]  We are going to break for 20

12     minutes.  We'll resume at 10 past 6.00.

13                           --- Recess taken at 5.50 p.m.

14                           --- On resuming at 6.11 p.m.

15             JUDGE ANTONETTI: [Interpretation] Fine.  The court is back in

16     session.

17             My fellow Judges have a number of questions to put to the witness

18     before we proceed to the cross-examination by Mr. Seselj.

19             Witness, Mr. Seselj will not be in a position to complete his

20     cross-examination today.  You will have to come back tomorrow for the

21     hearing at 2.15.  You will have to go back to the location where you are

22     currently, and obviously we'll make sure that your expenses are covered

23     by the Tribunal.

24             Before I give the floor to Mr. Seselj, I believe that my fellow

25     Judges have questions to put to you.

Page 12142

 1             Judge Lattanzi first.

 2             JUDGE LATTANZI: [Interpretation] Witness, please, could you talk

 3     to us about your current relationships with the members of the Serbian

 4     Radical Party?

 5             THE WITNESS: [Interpretation] It's like this:  I always -- I was

 6     always on good terms with some members of the Serbian Radical Party, and

 7     I still am today.  With others, I'm not on good terms, so I didn't revive

 8     our relationship and didn't have -- have not have a good relationship.

 9     For example, Tomislav Nikolic, we had an argument and we're still

10     estranged to the present day, although we are next-door neighbours, so to

11     speak, in our residential building.  I am "kum" to Dragan Todorovic, so I

12     always maintained good, intimate "kum" relationships, regardless of what

13     arguments we might have through the Assembly, or through the papers, or

14     other -- in other media.

15             JUDGE LATTANZI: [Interpretation] Have you recently met with

16     members of the Serbian Radical Party?  Have you had private conversations

17     with any of them?

18             THE WITNESS: [Interpretation] Yes.  At least on two occasions, I

19     was on some property owned by Dragan Todorovic.  He has some very good

20     wine, so I was on his estate and we drank wine once.  And Jelica Radeta

21     was with us on one occasion, and Dragan and I had a bottle of wine to

22     drink.  Well, we each had a bottle of very good white wine.  Otherwise, I

23     was invited to speak at a meeting organised by the Radicals, and then I

24     met just in passing a large number of those Radicals.  And this meeting

25     took place in the Trade Union Hall a month ago.  But that was a

Page 12143

 1     scientific meeting at which I presented -- it was nothing special.  I

 2     presented my views on why the West had these sentiments of hatred towards

 3     the Serbs, and the main thesis was that without conciliation between the

 4     Western states and the Serbs, there would be no peace in the Balkans,

 5     after the terrible crimes committed by the Germans from 1939 to 1945,

 6     which history attests to.  But Germany rose from the ashes, so to speak,

 7     so -- whereas us Serbs were betrayed 150 times.

 8             JUDGE LATTANZI: [Interpretation] Thank you, thank you.  Sir,

 9     there's something I would like to know, something else, if it's possible.

10             Have you met with some of the members of Mr. Seselj's Defence

11     team?  It would be rather natural if you had done so.  Have you met any

12     of them?

13             THE WITNESS: [Interpretation] I think that I met a lawyer called

14     Jerkovic, and I think he might be on the Defence team.  But we did not

15     discuss the Seselj trial at all, nor did we discuss anything -- any other

16     things which were linked to this specific case, because, well, I don't

17     know what he could tell me or what I could promise him.  We discussed

18     quite different matters.  A friend of mine needed a service done on the

19     territory of Zemun municipality, so that's what I wanted to ask him

20     about.

21             Now, as for these meetings, I don't know who's in the team.

22     I know Maja Gojkovic; Vucic-Milkovic; Krasic, Zoran, used to be -- I

23     think there's this man Jerkovic, too.  I don't know who else is on his

24     team.  So there was no specific discussion between me and any of the

25     Radicals in the sense of discussing the trial or anything.  So when I saw

Page 12144

 1     that things had gone astray, that I might be thrown into prison like

 2     Ljubisa Petkovic, I engaged Zoran Stojkovic, a lawyer, because I saw that

 3     matters had come to a head, that Jerkovic was taken from the asylum and

 4     taken to prison, whereas Haradinaj was -- there was direct cooperation

 5     between Haradinaj and the OTP until he liquidated all the witnesses and

 6     so on.

 7             JUDGE LATTANZI: [Interpretation] Thank you, thank you for your

 8     answer.

 9             THE WITNESS: [Interpretation] That's how I see things.  You're

10     welcome.

11             JUDGE HARHOFF:  Thank you.

12             Mr. Stefanovic, you told us during your testimony that in your

13     view, the War Staff of the SRS was a humanitarian organisation.  I think

14     that's the expression you used.  Do you remember that?

15             THE WITNESS: [Interpretation] Yes.  At the beginning of its

16     establishment, it was created to act in the way that would come under the

17     heading of humanitarian organisation; that is to say, that's how I see

18     it, humanitarian work, assistance, help in food, medicines, help to

19     people in the war-engulfed area, and dealing with the repercussions of

20     refugees and people coming in, women and children mostly, from the

21     war-affected areas.  And then later on it was as I described it,

22     something that was -- well, assisted people to go there.  And I was never

23     a member of the War Staff, and I never meddled in affairs where my place

24     was not.  That was done by Ljubisa Petkovic.  He was there.

25             So you're extracting every last drop out of me, but I can only

Page 12145

 1     assume, if I see what the investigator wants, he says -- he says

 2     something to me, then I nod my head, so that -- and agree, so that I can

 3     be allowed to go home as soon as possible.  But I'm under oath here now,

 4     so I say with full responsibility that it was established, and I know

 5     that at first all the assistants did go through this so-called War Staff.

 6             Now, it wasn't a humanitarian organisation, as such.

 7             JUDGE HARHOFF:  I understand.  But as secretary-general of the

 8     SRS, I guess you would have been involved in assistance to the victims,

 9     the Serb victims, those members of the SRS who fell victims to the war at

10     the front-line.  That is to say, I suppose you would be involved in the

11     provision of medicine to the wounded SRS members and volunteers at the

12     front-line, as well as to assistance to the victims' families back in

13     Serbia or Belgrade, would you not?

14             THE WITNESS: [Interpretation] No, never.  I never collected any

15     humanitarian aid.  All I dealt with was party business.  It was

16     Ljubisa Petkovic and the others around him, Zoran Drazilovic and another

17     group of people, men and women around him, dealing with that kind of work

18     exclusively.  It would be silly for me to go around collecting medicines

19     when I wasn't able to deal with the workload I have.

20             And please believe me when I say I got up at 6.30 in the morning

21     and went to bed after 11.00.  I lived in the Excelsior Hotel and the

22     Slavija Hotel, that's where I slept, and I knew the exact time I got up

23     and went to bed.  And I remember that in 1991, with my own car, it was a

24     Ford Fiesta, I think, anyway, I drove 130.000, over 130.000 kilometres.

25             JUDGE HARHOFF:  Mr. Stefanovic, let's focus a bit on the

Page 12146

 1     assistance that the SRS, either through the War Staff or through some of

 2     its other channels, was able to provide to the SRS volunteers who fell

 3     victims or to those victims' families.  I'm curious to know if you can

 4     tell us anything about if and to what extent the SRS was able to provide

 5     assistance in the form of medical care, hospitalisation, or other forms

 6     of assistance to the members -- to the volunteers who were wounded at the

 7     front-line or to these people's families.  That's what I would like to

 8     know, because even though if you were not directly involved in that, I

 9     would assume that you at least knew about it, being the secretary-general

10     of the party.

11             THE WITNESS: [Interpretation] Yes.  Superficially, yes, so my --

12     that's a very good question.  But you're forgetting one thing.  All the

13     Serbs -- you're characterizing all Serbs as members of the SRS.  Mostly,

14     those people -- well, none of them were members of the SRS.  If women and

15     children arrived, you don't ask them whether they're members of the

16     Radical Party or whatever other party, and usually they weren't -- these

17     women weren't members of any party, but they were provided assistance.

18             Now, you shouldn't raise it to the level of hospitalisation and

19     things like that, not at that level, to provide serious medical care,

20     but, yes, they did get some sanitary material or things that were stored

21     in warehouses, where the -- there was an expiry date that had -- a date

22     that it had expired, so we provided them with some of those medicines.

23             So I would otherwise be improvising if I told you more, because I

24     wasn't really well-versed in this kind of humanitarian work, I wasn't

25     involved in that side of things, but I knew that a group of women who --

Page 12147

 1             JUDGE HARHOFF:  Mr. Stefanovic, I only want you to tell us what

 2     you know, and please do not speculate.

 3             So you're telling us that the SRS was somehow assisting by

 4     providing medicine and maybe other sorts of supplies to the volunteers

 5     that the --

 6             THE WITNESS: [Interpretation] Food, too.

 7             JUDGE HARHOFF:  -- that the SRS had facilitated to the

 8     front-line?  Do you understand my question?  Maybe I'm not putting it

 9     very clearly, so I'll try once again.  I'm sorry.

10             You told us earlier on that the SRS was facilitating and helping,

11     assisting, people who came to the SRS headquarters and wanted, by their

12     own will, to be sent to the front-line in order to help against the Serbs

13     who were in trouble out there, and so I suppose that the SRS would then

14     feel some sort of responsibility for the persons that they helped to get

15     to the front-line, the volunteers who may or may not have been members of

16     the SRS.  But at least I suppose that there was some sort of

17     registration.  And then my assumption is, and I want you just to confirm

18     or to deny, my assumption is that the SRS would feel some sort of

19     responsibility for these people, so that if they were wounded at the

20     front-line, then the SRS would, by virtue of its humanitarian assistance

21     or otherwise, help them out; either to send them medicine, or if they

22     needed to go to hospital, then see if they could facilitate that, or even

23     if some of these persons were killed, then to help out with their

24     families back home, and that's what I want you to explain a bit to us, if

25     you can.

Page 12148

 1             THE WITNESS: [Interpretation] Yes, I fully understand your

 2     question.  I think that you're idealising things.  That organisation was

 3     not an ideal one.  They weren't fronts like the Magino [phoen] line, 300

 4     kilometres on the one side and the Medical Corps and so on and so forth.

 5     This was sporadical journeys of people, whether they were members of the

 6     party or not.  Many of them no, but they were volunteers or, rather,

 7     people who wanted to protect the Serb nation.  And all of them, including

 8     the Radicals and all the other parties, looked benevolently upon them,

 9     and that's what happens everywhere in the world when people go to war to

10     help their fellow compatriots, to stay in their own homes, on their own

11     threshold and so on, their own hearths and so on.

12             Now, when I say "assistance," well, you asked the question, I

13     remember a number of times that I bought sandwiches to feed the people

14     who came to the Party premises and spent the night there and were hungry,

15     so I went off -- I personally went off and, with my own money, bought

16     them sandwiches.  Now, do you consider that to be assistance to the War

17     Staff of the Radical Party, or how you're going to assess this, I don't

18     know.  That's what I did.

19             Anyway, with respect to people being killed, I can't tell you

20     exactly who transported the dead.  I think it was the army that was the

21     main organisation, because we Radicals did not have the logistics at the

22     front.  You need radio stations, medical corps, vehicles, ambulances, or

23     any kind of vehicles to transport men, especially if they're dead and you

24     have to transport coffins across borders and so on and so forth.  Anyway,

25     that was the kind of support, and that's how I see it today.  And I think

Page 12149

 1     it's quite normal.

 2             Now, whether there were any mistakes or not, I don't know, but I

 3     wouldn't have acted differently even today.  If I went back to those

 4     years, I think that I did the right thing.  And I say with full

 5     responsibility that Seselj didn't influence anybody and prevail upon them

 6     to go to the front.

 7             JUDGE HARHOFF:  Mr. Stefanovic, take it easy.  Just listen

 8     carefully to the questions that I'm putting to you.

 9             You said that the SRS would provide coffins if some of them had

10     been killed, and you also said that they would provide transport in order

11     for the volunteers, I suppose, to go to the front-line, and if they were

12     wounded, then to get back from the front-line.  So my question is:  Now,

13     you have substantiated your answer a bit more.  You said that they did

14     provide medical assistance, they did sometimes provide coffins if

15     somebody had been killed, they provide transportation to and back from

16     the front-line.  And before I move on, I just wanted to confirm, is this

17     correctly understood?

18             THE WITNESS: [Interpretation] Let me check.  You're talking about

19     the volunteers who were killed at the front-line; is that right?  Is that

20     what you're referring to, just to see that I've got it right?

21             JUDGE HARHOFF:  Yes.  The SRS volunteers or at least the

22     volunteers who came through the SRS headquarters and were sent to the war

23     front with the assistance by the SRS, those people, if they were killed,

24     did the SRS or could the SRS then provide some sort of assistance, for

25     instance, by getting a coffin, or getting in touch with the family, or

Page 12150

 1     otherwise providing support and assistance to those who had been -- who

 2     had taken off to the front-line through the SRS?

 3             THE WITNESS: [Interpretation] Yes, I understand the question, and

 4     I'll be precise now in giving you an answer, very precisely and

 5     correctly.

 6             It's like this:  All the people who were killed at the front, it

 7     was Zoran Drazilovic who was in charge of them.  He represented the

 8     party.  He would go to inform family members that their relative had

 9     died, had been killed.  Now, if he had the resources, then the party did

10     all this, it organised the coffin, the burial and everything else, the

11     funeral.  That comes under human solidarity, the heading of human

12     solidarity.  If not, then it would be the state or the army who would see

13     to that.  So that's as far as I know.  I never attended any funerals, to

14     be honest.

15             JUDGE HARHOFF:  And please just confine your answers to the

16     questions that I'm putting to you, because we should not take up too much

17     time.  Mr. Seselj is waiting to get on with his cross-examination.

18             Do you know if any of the volunteers were paid by the SRS?

19             THE WITNESS: [Interpretation] No, I don't think the Radical Party

20     financed the volunteers by giving them money.

21             JUDGE HARHOFF:  Do you know if they --

22             THE WITNESS: [Interpretation] I don't think it did.  I'm not

23     quite sure, but I don't think so.

24             JUDGE HARHOFF:  That's very fine.  I'm satisfied with the answer.

25             Do you know if the SRS was able to provide them with uniforms or

Page 12151

 1     weapons before they went to the front-line or as they were going to the

 2     battles?

 3             THE WITNESS: [Interpretation] What I know, and I think that is --

 4     was certainly the case, especially when it comes to weapons and uniforms,

 5     it was exclusively the JNA who would provide those.  We didn't have any

 6     weapons or anything like that, so that's the assumption.  We didn't have

 7     any uniforms or weapons, so we couldn't provide them with that, but the

 8     army did -- if they did, they would provide them with that.

 9             But, Your Honour, please believe me when I say that I never

10     crossed the Sava or Drina Rivers from 1991 to 1995 more than twice.

11             JUDGE HARHOFF:  I'm only interested in hearing what you knew or

12     what you can tell us about what happened.  I'm not implying that you

13     traveled around and saw the battlefield.  That is not my interest.  The

14     interest in my initial questions here have been to illuminate a bit the

15     responsibility that the SRS felt for the people who went to the

16     front-line, to the battles, through the SRS, and I think you have

17     answered these questions as best -- as well as you could.

18             Now, my next question would be:  If the young volunteers who went

19     to the front-lines were subjected to war crimes committed by, say, Croats

20     or Muslims, or war crimes committed by the other side against the members

21     of the SRS or against the volunteers who were at the battle and the

22     front-line through the assistance of the SRS, would that be something

23     that would be discussed or be addressed by the SRS?  Do you know that?

24             I'm speaking about war crimes committed against your people,

25     against the volunteers, and my question is if any such crimes were

Page 12152

 1     reported to the headquarters of the SRS in order to be addressed at some

 2     other level, perhaps passed on to the military police of the JNA or

 3     passed on to somebody else, but was that something that was recorded or

 4     discussed in the SRS headquarters?

 5             THE WITNESS: [Interpretation] Well, I'll be quite frank,

 6     Your Honour, to say that I never entered the War Staff, I never meddled

 7     in other people's affairs.  However, what is the objective truth is that

 8     all those who were invalids, for instance, it was the state, well, as

 9     members of the military units of the official Army of Yugoslavia, most

10     probably, I don't know for sure, but most probably they received some

11     invalidity remuneration, some pensions or whatever.  Now, as far as

12     assistance to those people goes, I know that two of them were taken care

13     of by the Radical Party, Dusica Nikolic and a man called Sima who fell

14     casualty in some actions, but they were activists of the Radical Party

15     before that, they were members beforehand and held important posts in the

16     party, and when they returned to the party, too, as if nothing had

17     happened.

18             I don't know of other cases, but I came across many people later

19     on who said that they had been volunteers, that they had been wounded,

20     but it was mostly the state that took care of them, the army, I think.

21     So I can't say anything other than that.

22             JUDGE HARHOFF:  But my question was --

23             THE WITNESS: [Interpretation] But there was no mention of that at

24     any official meetings.

25             JUDGE HARHOFF:  No, I understand.  But at the meetings that you

Page 12153

 1     took part in in Belgrade, at the SRS headquarters, did the issue of war

 2     crimes committed against the volunteers ever come up?

 3             THE WITNESS: [Interpretation] No, no, I don't think so.  At least

 4     I don't know about them.  That any item on the agenda was something like

 5     that, I don't think so.

 6             JUDGE HARHOFF:  So you never heard -- if I understand you

 7     correctly, you never heard that war crimes had been committed by the

 8     enemies to any of your volunteers?

 9             THE WITNESS: [Interpretation] No, I heard that many times, but it

10     wasn't a discussion at any official meetings of the Serbian Radical

11     Party.  The Serbian Radical Party dealt with political issues, and it was

12     those issues that were on the agenda of the Executive Board or the

13     Central Homeland Administration or whatever.  There was no discussion, as

14     far as I remember, about, say, point 4 on the agenda would be war crimes

15     against the Serbs, committed against the Serbs, as an item of the agenda.

16     I don't think anything like that ever happened.  Well, actually, I'm

17     certain we didn't discuss it in that way.  We dealt with political issues

18     and matters at the official meetings.  Otherwise, I had heard that

19     terrible crimes -- terrible crimes had been committed in many instances,

20     hundreds of them, both in Bosnia and Croatia.

21             And a friend of mine, Dragan Jovanovic, was killed on the 19th of

22     December, 1991, by the Ustashas, where they filmed it all on video, and

23     then five or six years later I happened to see this, his killing.

24             JUDGE HARHOFF:  Please understand me -- or, rather, I'm trying to

25     understand you, because I don't see the coherence in this.  If war crimes

Page 12154

 1     were committed on a large scale against Serbs, that would, I would

 2     imagine, be a very political issue in Serbia.  I mean, you have spoken,

 3     yourself, during this testimony about the genocide that was committed

 4     against Serbs during the Second World War.  So if anything of a similar

 5     kind would happen again against Serbs, that would be a political issue in

 6     any party in Serbia, would it not?

 7             THE WITNESS: [Interpretation] In any case, that would be a

 8     national issue, par excellence, but political activity in Serbia was such

 9     that one could not prevent crimes by political action.  One had to

10     support the government that was promising to assist the Serbs in areas

11     where they were under threat in order to help prevent crimes.  That would

12     have been the task of any serious political party.  If Serbia was willing

13     to help the Serbs escape crimes, then we would support the government

14     that was promising that, and vice versa, but what you're asking is

15     something new for me because I never attended a meeting where we

16     discussed specific crimes.

17             JUDGE HARHOFF:  I'm not sure that we understand each other

18     perfectly well, and maybe I have not been clear enough.  I'll try one

19     more time, and then after that I only have two more questions for you and

20     then I'm finished.

21             My question to you, Mr. Stefanovic, was if -- the issue of the

22     commission of war crimes, not any particular war crimes, but war crimes

23     in general, committed by the enemy against volunteers, Serb volunteers at

24     the front-line, was that not a political issue in the SRS, and how was it

25     addressed if it was?

Page 12155

 1             THE WITNESS: [Interpretation] I don't know how to reply to that,

 2     Your Honour.  I think I've said everything.  I've told you everything I

 3     know.  If you think I'm concealing something, tell me what you're getting

 4     at.  But to be quite honest --

 5             JUDGE HARHOFF:  My question was simple, and if you cannot answer,

 6     then you cannot answer and then we'll move on to something else.

 7             The next-to-last question I have is:  Do you know if any of the

 8     volunteers who went to the front-line, if they signed up to become

 9     members of the SRS?

10             THE WITNESS: [Interpretation] It's a difficult question again,

11     because no official records were kept of this, but I think that when

12     those people came to the party and stayed for an hour or two, it was not

13     usual for them to sign up then and there and become members.  They would

14     become members or not in their local boards.  We were a large party with

15     a large number of members, and we did not insist that volunteers be

16     members of the party.  That's my answer.  We did not insist that fighters

17     be members, but some of the volunteers certainly were party members.

18             JUDGE HARHOFF:  Thank you.  And the last question I have to you

19     relates to an issue that was brought up earlier by the Presiding Judge,

20     and I caught sight of it because you have mentioned the same thing twice;

21     that is to say, first in 2003, when you gave your statement to the

22     investigator, and then again in 2006.  So twice you have -- you raised

23     the issue of the president of the SRS, Mr. Seselj, being worried somehow

24     about the conduct of the volunteers at the front-line.  Do you recall

25     that?

Page 12156

 1             THE WITNESS: [Interpretation] I don't remember that, but if I did

 2     say that and if it's recorded, I don't know what the motive might be.

 3             Your Honour, I never saw this piece of paper before, the one on

 4     my left-hand side.  I could --

 5             JUDGE HARHOFF:  Forget about what you think you saw and what you

 6     didn't see.

 7             If I can just, as an example, pop back to the statement you gave

 8     in 2003.  In the English version, it's on page 14.  It's towards the end

 9     of the statement, and it's under a heading that is called "Crimes

10     Issues."  And I read out from what was taken down in your statement.  You

11     were supposed to have said the following, and I quote:

12             "I saw that Seselj was worried of the activities of the SRS

13     volunteers, and he tended to prove that he was not responsible for the

14     actions committed by the volunteers at the front-line."

15             And that's all I would like you to expand a bit upon.  What did

16     you mean when you alleged or indicated or suggested that Seselj might

17     have been worried about something that had happened at the front-line in

18     which, apparently, SRS volunteers had been involved?  What did you mean

19     when you said that?

20             THE WITNESS: [Interpretation] When giving the statement, I've not

21     been able to say this since the beginning of this hearing.  I see you're

22     all angry with me, the Judges, the Prosecutors and Seselj, all of you,

23     you're all yelling at me.  I'm not complaining, but forgive me for saying

24     this.  Believe me --

25             JUDGE HARHOFF:  Mr. Stefanovic, we are not angry at you and we

Page 12157

 1     are not yelling at you.  I'm putting issues to you that you have raised

 2     yourself twice in 2003 and 2006, and there is no mystery about it.  I

 3     just want you, because you're a witness and you're here to tell the truth

 4     and you're under oath, I just want you to tell us what you meant by

 5     saying what you said.  That's all.

 6             THE WITNESS: [Interpretation] I don't remember that at all.

 7     Probably that is an interpretation.

 8             JUDGE HARHOFF:  Thank you very much for your answers.  I have no

 9     more questions.

10             JUDGE ANTONETTI: [Interpretation] Very well.

11             We've got ten minutes left.  Mr. Seselj, maybe you could start

12     your cross-examination.

13             THE ACCUSED: [Interpretation] Yes.

14                           Cross-examination by Mr. Seselj:

15        Q.   Mr. Stefanovic, in these 10 to 12 minutes, we might be able to

16     clarify some minor status points.

17             You said that the Serb Freedom Movement was established on the

18     23rd of January, 1990.  Do you remember that the Serbian National Renewal

19     of Mirko Jovic and Vuk Draskovic was established on the 6th of January,

20     1990?

21        A.   Yes.

22        Q.   Up to the point when Vuk Draskovic was expelled from the Serbian

23     National Renewal, did this happen at the meeting of --

24             THE INTERPRETER:  Could the speakers please slow down and not

25     overlap.  This is impossible to interpret.

Page 12158

 1             MR. SESELJ: [Interpretation]

 2        Q.   At the meeting of you, Dusan Boskovic --

 3             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you're going too

 4     fast.  The interpreters are asking you to slow down.

 5             MR. SESELJ: [Interpretation]

 6        Q.   You and Dusan Boskovic refused to join up with Vuk Draskovic, and

 7     Vuk Draskovic and I, on behalf of our parties, although he had been

 8     expelled and he was only pretending to be at the head of the Serbian

 9     National Renewal, signed an agreement on the establishment of the Serbian

10     Renewal Movement; is that correct?

11        A.   Yes.

12        Q.   Do you remember that in early June, Vuk Draskovic was replaced

13     from the post of president of the Serbian Renewal Movement by a majority

14     of votes after the scandal when the Saint Sava play was staged in the

15     National Theatre?

16             THE INTERPRETER:  Could the witness repeat his answer?

17             MR. SESELJ: [Interpretation]

18        Q.   Kalinovica Piazza [phoen], is that the meeting you're referring

19     to?

20        A.   Yes.

21        Q.   18 Nevesinjska Street?

22        A.   Yes.

23        Q.   You are not yet a member of our party.  Do you remember that --

24             JUDGE HARHOFF:  The witness is sitting in Belgrade, and unless

25     you speak a lot louder, he won't be able to hear you.

Page 12159

 1             THE ACCUSED: [Interpretation] Well, it would be better if the

 2     witness was here, but what can I do about it?

 3        Q.   Do you remember that Vuk Draskovic, after he was replaced,

 4     established in the Rolex Restaurant a new party to which he gave the same

 5     name, the Serbian Renewal Movement, and then there were two parties

 6     having the same name?

 7        A.   Yes.

 8        Q.   And then at the end of June, to avoid confusion among the public,

 9     we changed the name of the party from the Serbian Renewal Movement to

10     Serbian Chetnik Movement?

11        A.   Yes.

12        Q.   Was that before the official registration of any political party?

13        A.   Yes, it was before the official registration of any party.  There

14     was not a single party that was registered at that time.

15        Q.   Registration started in August; is that correct?

16        A.   I think it was in August or September.

17        Q.   Your Liberal Party collectively joined the Serbian Chetnik

18     Movement only then; is that correct?

19        A.   Yes.

20        Q.   And you explained how the Serb Radical Party was established.

21     You mixed up some functions, but that doesn't matter.

22             Do you remember that as early as 1994, you put forward a

23     proposal, at a meeting of the party leadership, that you be relieved of

24     the duty of secretary-general and that we elect Aleksandar Vucic to that

25     post because it transpired that he was talented for propaganda

Page 12160

 1     activities?  Do you remember that meeting in my office?

 2        A.   I don't know what year it was, but superficially -- yes, I can't

 3     pinpoint the year.

 4        Q.   Yes.  You were never dismissed from that post, but you yourself

 5     proposed that you be relieved of that duty, and I assert it was in 1994.

 6        A.   I confirm that that's how it was, except that I'm not sure about

 7     the year.

 8        Q.   Unfortunately, we were wrong when we selected Aleksandar Vucic,

 9     but that's another issue.

10             Do you remember that in 1997, in an informal conversation with a

11     group of journalists in the Serbian Assembly, you said that you toppled

12     the monument to Draza Mihajlovic, although that was not true?  Do you

13     remember having said that?

14        A.   I do, but I think the year is not correct again.

15        Q.   I remember it was in 1997, because I have a photographic memory.

16     And then the journalists published this, and I summoned you and attacked

17     you fiercely because you said this as a joke, but it was detrimental to

18     the party; that's how it was?

19        A.   Yes.

20        Q.   And did you quietly withdraw from the Serb Radical Party after

21     that?

22        A.   Yes.

23        Q.   There were no conflicts; you simply disappeared.  Is that how it

24     was?

25        A.   Yes.

Page 12161

 1        Q.   I just wanted to clarify these few points if for no other reason

 2     than for this transcript, which will go down in history.

 3             Let me remind you of one more thing.  Do you recall that this

 4     so-called War Staff was first called the Crisis Staff of the Serb

 5     Radical Party and it was headed by Ljubisa Petkovic?

 6        A.   Well, it's silly to ask me about this War Staff.  I don't know

 7     what the logic is and why you're all asking me about the War Staff.  It's

 8     correct, I couldn't recall.  I thought it was some sort of humanitarian

 9     work.  I'm not sure.  It was humanitarian work, or it can be described as

10     activities which are usually referred to as humanitarian activities.  And

11     it's true that at the beginning, it was called the Crisis Staff, and I

12     never poked my nose in there, and I don't know what they did or what they

13     didn't do.

14        Q.   Mr. Stefanovic, there's no reason for you to become upset.  The

15     OTP has an abundance of documents showing that initially that Staff was

16     engaged in providing humanitarian assistance, and then gradually it

17     started sending volunteers.  But do you remember that it was only in

18     early October 1995 -- 1991 that the crisis --

19             THE INTERPRETER:  Interpreter's correction, 1991.

20             MR. SESELJ: [Interpretation]

21        Q.   ... that the Crisis Staff was renamed into the War Staff of the

22     Serbian Radical Party?

23        A.   I can't remember precisely, the precise date, but yes.

24        Q.   Do you -- well, did I ever threaten your life?  Did I ever

25     threaten you with death?

Page 12162

 1        A.   No.

 2        Q.   Did I ever threaten anyone's life?

 3        A.   To the best of my knowledge, no.

 4        Q.   Well, I have to remind you now.  I have to jog your memory,

 5     because the Prosecutor did the same.

 6             Do you remember that on one occasion, I threatened the Croatian

 7     Ustasha leader, Franjo Tudjman, and that for the Zagreb magazine

 8     'Globus,' as a joke, I said that the Chetnik court had sat a

 9     court-martial and sentenced Tudjman to death and they published this as a

10     serious piece of news?

11        A.   Well, I don't remember that.  It was the Chetnik corps, the

12     collective body, not you.

13        Q.   But it was done for propaganda purposes and as a kind of joke?

14        A.   Yes, that's how I see it.

15        Q.   Do you remember the statement that we -- that we Chetniks have

16     river submarines and that we would take those submarines through the

17     rivers to Zagreb and catch Franjo Tudjman?

18        A.   Yes, and it was said that they would be sending them to

19     Ljubljana also, and then they came to intervene and asked us not to send

20     them to Ljubljana.

21        Q.   And they made problems for the Serbs?

22        A.   Yes.  The priest Peran [phoen] in Ljubljana.

23        Q.   But it was a joke?

24        A.   I'm been given a single to slow down.  Yes.

25        Q.   Well, I'm really interested who else is with you in this room.

Page 12163

 1             THE ACCUSED: [Interpretation] Judges, I'm demanding that the

 2     camera crew lift the camera and that he take a shot all around the room

 3     so that we can see who is in the room.

 4             Mr. Stefanovic, don't say anything.  I want to see visually.  I

 5     have the right to that, and nobody should get out of the room in the

 6     meantime.  No one should leave the room in the meantime.  Judges, is that

 7     possible?

 8             THE WITNESS: [Interpretation] Can you see me?

 9        Q.   Well, I can see you and someone peeping behind you.  Is that

10     someone who's whispering what you should say?  Who is that person?

11             THE WITNESS: [Interpretation] I don't know.  What's your name?

12             THE ACCUSED: [Interpretation]  We have to know the names of all

13     those who are present in the Tribunal office in Belgrade in the course of

14     this hearing.  I have the right to that, and the public must know their

15     names.

16             JUDGE ANTONETTI: [Interpretation] Witness, there is somebody with

17     you.  I guess he's the Registrar; right?  Who is the person standing next

18     to you?

19             THE WITNESS: [Interpretation] Are you addressing me?

20             JUDGE ANTONETTI: [Interpretation] Yes.  Could you tell us who's

21     standing next to you?

22             THE WITNESS: [Interpretation] There's a man sitting next to me.

23     I don't know what his name is.  You see now.

24             JUDGE ANTONETTI: [Interpretation] Very well.  This person is the

25     Registrar.  We know him very well.

Page 12164

 1             Are you reassured, Mr. Seselj?

 2             THE ACCUSED: [Interpretation] Are we going to find out the name

 3     of this person, Mr. President?

 4             JUDGE ANTONETTI: [Interpretation] The Registrar.  He's always

 5     here in the courtroom.

 6             THE ACCUSED: [Interpretation] Have you rejected my demand that

 7     the cameraman lift the camera and take a circular shot all round the

 8     room, span all round the room so we can see who is in the room?

 9             JUDGE ANTONETTI: [Interpretation] Witness, how many people are

10     there in this room, because Mr. Seselj seems to be paranoid and thinks

11     there's a conspiracy against him, so how many people are in that room

12     where you are?

13             THE ACCUSED: [Interpretation] [No interpretation].

14             JUDGE ANTONETTI: [Interpretation] How many are you?

15             THE WITNESS: [Interpretation] There's me and another man.  There

16     are two of us.

17             THE ACCUSED: [Interpretation] Mr. President, paranoia is a

18     dangerous mental illness.  If I were suffering from paranoia, I would not

19     be sitting here in the courtroom.  So please refrain from such

20     statements.  I'm not paranoid.

21             JUDGE ANTONETTI: [Interpretation] Stop.  Stop this, Mr. Seselj.

22     You are questioning the integrity of this Tribunal, suggesting that there

23     were other people in the room than the witness.  You were told there were

24     two people.  I asked the witness to confirm, and he did say that there

25     were two people in that room.  That's it.

Page 12165

 1             We will resume tomorrow, sir.  We will resume this hearing

 2     tomorrow at 2.15.  I will ask you to refrain from any contact with the

 3     media about these proceedings, and we will meet again tomorrow at 2.15.

 4     But be there at 1.00, because there are some technical checks to be done.

 5             I wish everybody a good evening, and we will meet again at 2.15.

 6                           --- Whereupon the hearing adjourned at 7.02 p.m.,

 7                           to be reconvened on Wednesday, the 26th day of

 8                           November, 2008, at 2.15 p.m.