080401ED

Page 5495

1 Tuesday, 1 April 2008

2 [Open session]

3 [The witness entered court]

4 --- Upon commencing at 9.04 a.m.

5 [The accused entered court]

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

7 please call the case.

8 THE REGISTRAR: Good morning, Your Honours.

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

10 Vojislav Seselj.

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

12 So this is Tuesday, and I welcome the OTP, the representative of

13 the OTP, as well as the witness, Mr. Seselj, and everyone helping us.

14 We're in Courtroom II today. Normally, we're in Courtroom I or

15 III, but these courtrooms were unavailable, notably Courtroom III, which

16 is why we were sent to Courtroom II. However, this will only be

17 temporary.

18 Today, we shall be hearing the witness in the courtroom today.

19 But before this, I would like to move to private session quickly.

20 But before this, Mr. Seselj, on an administrative matter, I

21 believe you had something to say.

22 You have the floor.

23 MR. SESELJ: [Interpretation] Mr. President, I have three

24 administrative issues to raise, but they'll be brief.

25 I have to inform you, firstly, that the Prosecution, along with

Page 5496

1 this registrar of documents which it intends to use during the

2 examination of this witness, once again provided me with a list

3 exclusively in English, and it's a ten-page documents. I think you must

4 instruct the Prosecution never to repeat that again and to issue

5 instructions that I be provided with a copy in Serbian forthwith. There

6 are a number of descriptions here of various documents, and you can see

7 that it is a long document. That's the first point.

8 Secondly, over the weekend I looked through the documents to do

9 with the coming witness, VS-051, who is scheduled to appear next week,

10 and I found that I was lacking certain materials from his transcript, the

11 transcript of his testimony and another trial. The Prosecutor knows full

12 well what the trial is. I don't want to mention the name of the trial,

13 not to disclose the witness's identity, but anyway and I need his

14 testimony on the 16th of February and perhaps earlier on if it began on

15 the 15th too, as well as his testimony of the 22nd of February from 1805

16 hours in the afternoon, and if it went on to the next day.

17 I was provided by them by about 240 pages of transcript, and

18 reading through it, I found out that I was missing some parts. So I

19 demand that I be supplied with that as soon as possible, because without

20 it, I won't be able to cross-examine the witness next week. So they have

21 to provide me with that by Friday.

22 And the third point is this: To avoid writing a written

23 submission, I don't want to burden you, 15 minutes before I entered court

24 the representative of the Registrar provided me with a public document.

25 It was the request by the Stanisic Defence for access to confidential

Page 5497

1 testimony and exhibits in the Seselj rule [as interpreted] on the basis

2 of Rule 75 (G) and (I). Now, as I am expected to present my views and to

3 speed up the whole process and not have to write a written submission, I

4 telling you now, here and now that I agree that the Stanisic Defence be

5 given access to all confidential testimony and documents in the trial

6 against me, and I consider that it is enough for this to be on the record

7 of today's proceedings, that I don't need to submit this in writing as

8 well.

9 So that's all I had. Thank you.

10 JUDGE ANTONETTI: [Interpretation] Very well. So let's take

11 them -- let's take these three points in the reverse order. We'll start

12 with the last one, the Stanisic submission.

13 We have taken due note of your agreement, and the Trial Chamber

14 will make a decision very quickly on this.

15 Now, to the second point, for Witness VS-051, obviously you're

16 missing a few documents, so I would like the Prosecution to check this.

17 Yes, Mrs. Biersay.

18 MS. BIERSAY: Simply to say, Your Honour --

19 THE INTERPRETER: Microphone, please.

20 MS. BIERSAY: We'll certainly look into the matter. I believe

21 that we have attempted to make all the disclosures that we have

22 available, but I will not be leading that witness, and so I will confer

23 with the attorney who will be.

24 JUDGE ANTONETTI: [Interpretation] Very well.

25 Regarding the document written in English, according to

Page 5498

1 Mr. Seselj, I don't know which document it is. It seems to be -- could

2 you help us? Which document is it, Mrs. Biersay, please?

3 MS. BIERSAY: I believe the document to which Mr. Seselj is

4 referring is the index to the court binder that gives a general

5 description of the 65 ter numbers of the documents in the binder, as well

6 as the description and ERN numbers.

7 Certainly, I think given the fast turnaround that we had with the

8 binder, we didn't have the resources to direct to provide that index in

9 English -- in B/C/S, and so we had to make a judgement call in getting it

10 to Mr. Seselj as soon as possible of delaying it in order to provide the

11 index in B/C/S, and the decision was made to get it to him as soon as we

12 could in English.

13 JUDGE ANTONETTI: [Interpretation] Very well. Please, in the

14 future, try to ensure that Mr. Seselj obtains this document, this index,

15 in his own language. It's not very complicated, obviously, to translate.

16 The there are a number of photographs. Photographs in Serbian is

17 probably very simple to translate. There are two transcripts of phone

18 conversations, obviously. It should only take a few minutes to

19 translate.

20 Very well. Let me now ask for a private session for a few

21 minutes.

22 Mr. Seselj first, you wanted to add something or to respond to

23 Mrs. Biersay maybe?

24 THE ACCUSED: [Interpretation] Just a small correction with

25 respect to Witness VS-051. I'm expecting to be disclosed in all the

Page 5503

1 as a civilian. And I -- in our country, there was what was called

2 "streamed education" that was ongoing. That was the system. So the

3 secondary school of architecture, there were a number of branches.

4 MR. SESELJ: [Interpretation] I have an objection to make. The

5 microphone doesn't seem to be working, the witness's microphone, and I

6 can't hear him properly. My microphone is in order. It's the witness's

7 that isn't working properly.

8 MS. BIERSAY:

9 Q. Mr. Witness, for how long did you work as a civilian with the

10 JNA?

11 A. About four years and a few months.

12 Q. I'd now like to direct your attention to the period of time when

13 the JNA started mobilising reservists to Croatia in 1991.

14 At some point, Mr. Witness, did you decide to become a volunteer?

15 A. Yes, that's right, I decided to become a volunteer in 1991.

16 Q. And for which organisation did you decide to join as a volunteer?

17 A. I decided to join the Serbian Chetnik movement or, rather, the

18 Serbian Radical Party, Vojislav Seselj's party.

19 Q. And why did you decide to join that party?

20 A. Because my family nurtures monarchist traditions, so that seemed

21 to me to be most suitable. As far as I'm concerned, I didn't like

22 communism so it suited me, and at that time it was propagated that the

23 Chetnik Party -- well, that particular party. I didn't know at the time

24 they were not actually for the monarchy, but I wasn't politically

25 literate at the time so I didn't really know all these things.

Page 5504

1 Q. Is it fair to say that you were joining this party because you

2 thought it represented your monarchist ideas?

3 MR. SESELJ: [Interpretation] Objection. That question is

4 absolutely impermissible. The Prosecutor is asking whether it is true

5 and correct that you joined the party because you believed that it

6 represented monarchist ideals and ideas. The Prosecutor must not put

7 questions like that.

8 JUDGE ANTONETTI: [Interpretation] Just a minute, Mr. Seselj. I

9 don't understand your objection.

10 Mrs. Biersay is asking the witness why he joined the Serbian

11 Chetnik Party. She's asking for the reasons behind this. This is at

12 line 14 -- page 14, line 9. And he answers:

13 "Because my family had a monarchist tradition," which is

14 interesting. When we'd like to know why someone decides to volunteer and

15 joins the Chetnik Party. And that's the reason.

16 It's useful to know why this person volunteered, so I'll ask the

17 question, a follow-up question.

18 Witness, please, according to what you said, it seems that you

19 volunteered because your family was monarchist. It means obviously your

20 family wanted to have a king to lead Serbia. Was this the whole idea

21 behind your joining?

22 THE WITNESS: [Interpretation] Yes. Yes, that's right. My

23 family, before the war, before World War II, that is, were always in

24 favour of the king.

25 JUDGE ANTONETTI: [Interpretation] Very well.

Page 5505

1 When you joined this political party or this movement, this

2 political movement, did you have any friends who had the same ideas and

3 who joined the movement also because they were monarchists?

4 A. Well, in -- well, in 99 per cent of the volunteers, had the same

5 ideas I did.

6 JUDGE ANTONETTI: [Interpretation] 99 per cent of the volunteers

7 who joined the Chetnik movement were monarchists; is that it?

8 THE WITNESS: [Interpretation] 100 per cent.

9 JUDGE ANTONETTI: [Interpretation] Almost saying 100 per cent,

10 actually. Very well.

11 Mrs. Biersay, please continue.

12 MS. BIERSAY:

13 Q. Where did you go in order to join the Serbian Chetnik movement?

14 A. I went to the Serbian Radical Party, which was on Ohridska

15 Street, because I had information that that's where one could join the

16 volunteers. The media advertised this. They said, "You should go

17 through Seselj," and that the Chetniks were going to the front to assist

18 the people on the battlefield. So I joined them, that's where I went.

19 I asked around, asked my friends, and they said "That's the

20 place -- that's the best place to go, that's the best place for you,

21 because all the Chetniks are there."

22 Q. Approximately when did you go to this office?

23 A. That was in 1991, I think in July.

24 Q. When you went to the office, who did you meet there?

25 A. When I went to the office, I was received there by Zoran Rankic.

Page 5506

1 He was the deputy chief of the War Staff there, and he was wearing a

2 military uniform, all spick and span. I thought he was some sort of

3 general, but later on I came to realise that he wasn't. And he received

4 me, he wrote my name down, and said that I was automatically a member of

5 the Serbian Radical Party, having come as a volunteer, to apply as a

6 volunteer.

7 I was interested in other matters, and I asked him how I was

8 going to justify the fact that I was off work, and he said, "There's no

9 problem there. We're going to issue you with a certificate, so that will

10 settle that as far as your job is concerned." And he said -- well, he

11 wrote my name in as a member, and he said he'd call me up on the phone

12 when enough volunteers had rallied together to go to Western Slavonia,

13 that he would inform me when that would be, where, what day and what

14 time.

15 Q. Let's discuss that certificate, that document that Mr. Rankic

16 mentioned to you that would help you with your job. What exactly was

17 that document?

18 A. It was a certificate which Ljubisa Petkovic usually wrote out if

19 the volunteers needed it. We would go to ask for a certificate to let us

20 off work, to justify our absence from work. And, for example, the

21 volunteers didn't have to pay for their electricity. You would take your

22 certificate saying you're a volunteer to the electrical distribution

23 network and you wouldn't have to pay. And when you would have

24 certificates like that, too, when you did your military service of any

25 kind, they would write this down in your military booklet and then this

Page 5507

1 would give you extra years of service. Every year you served would be

2 counted as two years.

3 Q. What other types of professions received that double counting of

4 military service that you just described?

5 A. Well, the army, the JNA, and the police.

6 Q. So just so that I'm clear, people in the police and in the army

7 would receive credit for double the time that they actually served in the

8 military?

9 A. Yes.

10 Q. And if you were an SRS volunteer, a Serbian Chetnik Movement

11 volunteer, you would also get the same benefit; is that correct?

12 A. That is correct, yes.

13 JUDGE ANTONETTI: [Interpretation] Just a minute. The question is

14 complicated, Witness. This is the first time that we've been hearing

15 about this, which is why I'm quite interested by it.

16 We have just been told that a volunteer did not pay his

17 electricity bill, and secondly, that all the time spent in the army was

18 going to count double, probably for his pension and retirement. This is

19 what you just said; right?

20 THE WITNESS: [Interpretation] Yes, those are my words.

21 JUDGE ANTONETTI: [Interpretation] Very well, thank you.

22 Now, these benefits, which are quite important, according to you,

23 were they granted because you were a volunteer or because you were a

24 member of the Chetnik movement?

25 THE WITNESS: [Interpretation] Well, the benefits and credits were

Page 5508

1 authorised by the top people in the state, because Vojislav Seselj

2 collaborated very closely with the top authorities in the states, so we

3 enjoyed all the benefits that the officers in the army benefitted from.

4 And this was decided at the very top leadership.

5 JUDGE ANTONETTI: [Interpretation] You're saying it was the state

6 that granted these benefits, but you're drawing the conclusion that it is

7 because Mr. Seselj was collaborating with state authorities?

8 THE WITNESS: [Interpretation] Yes.

9 JUDGE ANTONETTI: [Interpretation] Very well.

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

11 In the Serbian armies, these volunteers, were they people who

12 were under the law, in general? They were under the law, but I would

13 like to know one thing. I'd like to know whether all the other

14 volunteers were granted the same benefits or only the volunteers who were

15 organised by the Serbian Radical Party.

16 THE WITNESS: [Interpretation] As far as I know, it was only the

17 volunteers of the Serbian Radical Party that enjoyed those benefits.

18 However, other volunteers most probably did, too, because this was

19 regulated by law. That's 100 per cent correct. And I'm sure they

20 enjoyed those benefits and credits too.

21 JUDGE LATTANZI: [Interpretation] Maybe it was a problem with

22 translation --

23 THE WITNESS: [Interpretation] [Previous translation continues]...

24 or that they could enjoy those rights, perhaps.

25 JUDGE LATTANZI: [Interpretation] Maybe there's a little problem

Page 5509

1 with translation, because it seems that there's a contradiction in your

2 answer.

3 You were saying earlier that only the volunteers from the Serbian

4 Radical Party were granted these benefits, and then later on you're

5 saying that maybe the other volunteers too, so could you be more

6 specific, as far as you're concerned, as far as you know?

7 THE WITNESS: [Interpretation] I added and said that other

8 volunteers probably didn't have the proper information telling them that

9 they could avail themselves of those benefits. They didn't know about

10 it.

11 We did have information from the chief of the War Staff,

12 Ljubisa Petkovic, that we were entitled to those benefits.

13 JUDGE ANTONETTI: [Interpretation] So if we understood you well,

14 as far as you're concerned, you are telling us that this possibility of

15 being granted benefits was told to you, which is why you took advantage

16 of it, as well as all your other friends from the Serbian Radical Party.

17 But you're saying for other volunteers coming from other parties, if they

18 hadn't gotten the information, they might not have benefitted from all

19 this? Is this what you wanted to say?

20 THE WITNESS: [Interpretation] Yes, that's right, that's what I

21 wanted to say.

22 JUDGE ANTONETTI: [Interpretation] That's what I understood.

23 Thank you.

24 Mrs. Biersay, you have the floor.

25 MS. BIERSAY:

Page 5510

1 Q. Mr. Witness, these certificates that you're discussing, where

2 they issued by the SRS or were they issued by another state organisation?

3 A. Those certificates were issued by the War Staff of the Serbian

4 Radical Party.

5 Q. In addition to the benefits that you just described, did you have

6 any discussions with anyone at the SRS, the Serbian Chetnik Movement,

7 about health insurance?

8 A. I did talk to Zoran Rankic and Ljubisa Petkovic. I did discuss

9 that, so that could be regulated as well. In principle, if the volunteer

10 needed anything, they would go to the War Staff and be issued a

11 certificate, and this would usually be issued by Ljubisa Petkovic. They

12 would be issued a certificate for whatever he needed, whether for his

13 electricity bills, or his work post, the employment bureau, or whatever,

14 for his social insurance, et cetera.

15 Q. During your discussion, when you went to register with the SRS,

16 during your discussion with Mr. Rankic, did he describe what role

17 Mr. Seselj played in the organisation?

18 A. He said that he was the chief there, that he was the main boss,

19 that he was the supreme commander. And he introduced himself to me as

20 the deputy of the War Staff, and he said that he was there to register

21 the volunteers who applied and to inform them about their departure for

22 the front, for the frontline, the war theatre. And he said that the

23 party would take all necessary measures to protect its volunteers.

24 Q. What was your understanding about the relationship between the

25 Serbian Chetnik Movement and the SRS?

Page 5511

1 A. I understood it to be a serious organisation, which is why I

2 applied. I thought that in time, as the JNA was down on its knees, the

3 Serbian Chetnik Movement would take over control in Serbia.

4 Q. And did anyone explain to you in what way the Serbian Chetnik

5 Movement was connected to the SRS?

6 A. In the beginning, no one did. I wasn't informed as to the manner

7 in which it was connected. Later on, I came to understand that it was

8 one section. It was rumoured among the people that they couldn't

9 register the Serbian Chetnik Movement, so they registered the Serbian

10 Radical Party instead.

11 Q. Why were they -- why could they not register the Serbian Chetnik

12 Movement, as far as you know?

13 A. I don't know that, but that's what people said to attract people,

14 to get them to come in and volunteer, in fact to misuse them.

15 Q. After you registered as a volunteer at the SRS office in

16 Belgrade, did you in fact get a call from Mr. Rankic later about

17 deployment to the front?

18 A. Yes. After about a month or two, Rankic called me up, and he

19 said that there would be buses leaving. They were parked in the 27th of

20 March Street and that they would be leaving at 8.00 or 9.00 in the

21 morning. I'm not sure about the time anymore.

22 Q. How much time passed between the time he called you and the time

23 these buses were supposed to leave?

24 A. Well, about four or five days, more or less. I can't be precise

25 about it.

Page 5512

1 Q. And where -- what was your understanding about where you were

2 going to be deployed?

3 A. I had already been told that we were going to Western Slavonia.

4 Q. And could you describe the circumstances when you went to the

5 area to which Mr. Rankic had directed you?

6 A. We set out in the buses --

7 Q. If I could stop you for one minute, Mr. Witness.

8 Could you describe for the Trial Chamber the situation where the

9 buses were? At what address did you go to meet the buses?

10 A. I went to the 27 Marta, the 27th of March Street in Belgrade,

11 near the botanical gardens. There was a clearing where the buses stood.

12 We were sitting in a restaurant across the road, waiting for Rankic and

13 the commander that the Serbian Radical Party had designated to come

14 along. Some of the volunteers were already drunk. When Radovan Novacic

15 came, Rankic told us he was our commander. We boarded the buses.

16 Radovan Novacic didn't want to take those who were drunk, he didn't want

17 to take them with him, and there was a small conflict with Zoran Rankic

18 because Rankic wanted to take them, but Radovan Novacic said, "Either

19 those who are drunk will leave or I will leave," so that those who were

20 drunk did not go. But we did go, and Radovan went with us.

21 Q. Mr. Witness, if I could stop you for one minute. How many

22 volunteers ended up boarding the buses to leave to Western Slavonia?

23 A. About 27 in all. I can't say whether there were 25 or 27, but

24 the first group was rather small. I mean, the bus wasn't full.

25 Q. And did Mr. Rankic go on the buses with the volunteers?

Page 5513

1 A. No, he went back to the War Staff.

2 Q. In addition to rejecting volunteers because they were drunk, did

3 Mr. Novacic reject volunteers based on what they were saying?

4 A. Yes, that did happen. The ones who were drunk said they were

5 going there to kill, to slaughter, to gouge people's eyes out, and that's

6 why he didn't want to take them. And when we got on the buses, he said,

7 "If anyone is going there in order to slaughter people, he can leave

8 right now."

9 Q. Do you know the ethnicity of Mr. Novacic?

10 A. I do.

11 Q. And what is he?

12 A. He is half Croat, half Serb.

13 Q. The number of volunteers that you described for the Trial

14 Chamber, were they all SRS volunteers?

15 A. Yes, they were all volunteers who had reported to the Serbian

16 Radical Party and applied to go to the frontline.

17 Q. Could you describe for the Trial Chamber what route the bus took

18 to get to Western Slavonia?

19 A. We couldn't go through Croatia, so we went through Bosnia. We

20 spent the night in Bosanska Gradiska. There was a prison there and the

21 JNA barracks --

22 Q. Just one moment, Mr. Witness. Before we discuss where you

23 stopped, I just wanted generally for you to describe the route that you

24 took to get to Western Slavonia.

25 A. At the time, there were lots of people check-points, since there

Page 5514

1 was a state of war, so we went through Bosnian territory because that

2 area had not yet been affected by the war. We went via Doboj. The

3 police greeted us along the way because they had been informed we would

4 be coming through, so that we didn't have any problems.

5 MS. BIERSAY: Madam Registrar, if we could see 65 ter

6 number 7187, please.

7 And while we're calling it up, 65 ter number 7187 is a map with

8 the northern-marked area being Vocin, to the south Banja Luka, and Sid to

9 the east.

10 Q. Mr. Witness, where was the first stop that you made on your way

11 to Western Slavonia?

12 A. Our first stop was Bosanska Gradiska. We stayed in the prison

13 there, and there was a JNA barracks there.

14 Q. When you got to Bosanska Gradiska, did anyone from that area

15 greet the bus of volunteers?

16 A. Yes, Goran Hadzic was there, so was Dzakula, and some other

17 representatives of the government of Western Slovenia. They greeted us

18 and they put us in the barracks to stay with the army. The army had

19 taken refuge there temporarily because it was a war area.

20 Q. How long did you stay at the barracks in that area?

21 A. Just one night, we just spent one night there.

22 Q. What happened the next day?

23 A. In the following days, the army from Vocin arrived by bus. They

24 came from Western Slavonia with a driver in a camouflage uniform, and

25 they took us to Vocin.

Page 5515

1 Q. This driver, was he armed or unarmed?

2 A. There were two of them, in fact, in camouflage uniforms. The

3 driver was armed with a pistol, and the other driver, also wearing a

4 camouflage uniform, was also armed. He had an automatic rifle. They

5 followed us, Hadzic and Dzakula, I mean. Dzakula was the president of

6 the municipality at the time. They followed us in a car: We, the

7 volunteers, were taken there by bus.

8 Q. The bus that you boarded in Bosanska Gradiska, was that the same

9 bus that you had boarded in Belgrade?

10 A. No, that was another bus.

11 Q. And from Bosanska Gradiska, where did you go next?

12 A. Yes.

13 Q. Where did you go next, where?

14 A. We arrived in Vocin. There, we had lunch. And later on, they

15 took us to a place called "Lager", where there was a reconnaissance

16 sector overlooking Sokolac.

17 Q. Is that area referred to as the Papuk area or is it referred to

18 by something else?

19 A. Yes, yes, it is the area of Mount Papuk. That's what it's

20 called.

21 Q. And when -- if someone referred to the area of Podravska Slatina,

22 what area would they be talking about?

23 A. That is a broader area, Podravska Slatina. It's lower down.

24 That's Podravska Slatina.

25 Q. When you arrived at the camp that you just described, were you

Page 5516

1 given any weapons or uniforms?

2 A. We arrived in the camp at around 5.00, and at about 9.00 in the

3 evening the army brought weapons and uniforms by truck. These were old

4 uniforms with the five-pointed star.

5 Q. And how did you feel about wearing uniforms with the five-pointed

6 star?

7 A. Well, I couldn't wear civilian clothes, so I had to put it on.

8 Q. Were the uniforms with the five-pointed star, were they

9 camouflaged or non-camouflaged?

10 A. No, they were olive grey, drab, these ordinary old uniforms, and

11 they were not intended for fighting, but for parades, because you

12 couldn't even crouch down in them properly.

13 Q. And could you describe to the Trial Chamber what type of weapons

14 you were given?

15 A. We were given new weapons. They were in crates which had not

16 been unpacked. And they also brought us a barrel of oil so that we could

17 take the grease off the weapons, so that we stayed up late into the night

18 cleaning the weapons. And we also showed each other how to use the

19 weapons, because many volunteers didn't know how to put the weapons

20 together. So that Radovan had the first part of the training with the

21 group about using the weapons, putting them together and taking them

22 apart again.

23 Q. When you say "Radovan," who do you mean?

24 A. I'm referring to Radovan Novacic.

25 Q. Mr. Witness, I'd now like to discuss with you the command

Page 5517

1 structure for the area in which you were in Western Slavonia. Could you

2 describe for the Trial Chamber the command that Radovan Novacic had?

3 A. Radovan Novacic was subordinate to Jovan Trbojevic, who was a

4 lieutenant colonel of the JNA, the Yugoslav People's Army. He could not

5 make a decisions, unless it was an emergency, without Jovan Trbojevic.

6 Q. Did Radovan Novacic have a title?

7 A. To the best of my knowledge, he was a reserve captain, but he was

8 the commander of the Serbian volunteers.

9 Q. Was he the commander of all the SRS volunteers in the Papuk area

10 or only part of the Papuk area?

11 A. The first authorisation he got was to command all the volunteers

12 in all of Western Slavonia, not just the Papuk area.

13 Q. Now, you said that he was subordinated to Lieutenant Colonel

14 Jovan Trbojevic; is that correct?

15 A. Yes, that is correct.

16 Q. And who else was subordinated to Lieutenant Colonel Trbojevic?

17 A. The police was also subordinated, as were the special units led

18 by Zoran Miscevic. Let me explain.

19 In wartime, everyone is subordinated to the army.

20 Q. One minute, Mr. Witness. Who is Slavko Misic?

21 A. I beg your pardon? I didn't understand your question.

22 Q. Who is Slavko Misic? I apologise for my pronunciation.

23 A. Slavko Misic was later sent to the Okucani area, which is also in

24 Western Slavonia, and he was issued with a certificate saying that he was

25 a commander in the area. So there was a conflict between him and

Page 5518

1 Radovan. He was also a volunteer of the Serbian Radical Party.

2 Q. Was Misic subordinated to someone else in that area, and if so,

3 who was it?

4 A. Yes, he was subordinated to Narandzic, who was an active-duty

5 military person in that area. I can't recall his first name.

6 Q. And who is Zoran Miscevic?

7 A. He was in charge of the special units of the Army of Yugoslavia,

8 and he was subordinated to Jovan Trbojevic.

9 Q. Now, you described the first -- you described the number of

10 volunteers who were on that bus with you. Did you have an impression

11 about whether or not your bus was the first bus of volunteers in the

12 area?

13 A. Yes, we were the first volunteers in that area. We were the

14 first group.

15 Q. Now, you described that there were over 20 volunteers -- SRS

16 volunteers on that trip. Did the number of SRS volunteers in that area

17 change over time?

18 A. Yes, it did. The groups arrived, one after another. Of as soon

19 as they had a full bus, they would inform Radovan, and we would go to

20 meet those volunteers and bring them to the war theatre, so that there

21 were quite a lot of volunteers.

22 Q. How many volunteers would you estimate were there at the peak?

23 A. Well, about 400, I would say, at the peak.

24 JUDGE LATTANZI: [Interpretation] Witness, of these 400 volunteers

25 that you mentioned, were they all organised by the Serbian Radical Party

Page 5524

1 service with the JNA; yes or no?

2 THE WITNESS: [Interpretation] I did my military service in two

3 parts, the JNA military service, but I didn't complete it; just the

4 training bit.

5 JUDGE ANTONETTI: [Interpretation] Very well. Therefore, you had

6 had some kind of military training.

7 Your other colleagues, who were also volunteers, had they also

8 done their military service with the JNA? You were volunteers, but all

9 of you were at least over 21?

10 THE WITNESS: [Interpretation] There were volunteers who hadn't

11 done their military service at all. The criminals came, too, and people

12 came -- volunteers came in from various parts and walks of life.

13 JUDGE ANTONETTI: [Interpretation] Now you're introducing

14 something new. You're saying that there were criminals. So in saying

15 this, did you mean that these were people who had been convicted in court

16 and who had then volunteered? Is this what you were saying?

17 THE WITNESS: [Interpretation] Yes, that's what I had in mind.

18 JUDGE ANTONETTI: [Interpretation] Very well. So these people who

19 had been sentenced hadn't been -- hadn't done their military service

20 within the JNA?

21 THE WITNESS: [Interpretation] No, no, but there were other

22 people, too that didn't do their military service, but were not convicted

23 of anything, and that's why Radovan Novacic emphasised the fact that

24 training was important, because most of them didn't know how to handle

25 weapons, so as to avoid inflicting wounds upon oneself.

Page 5525

1 JUDGE ANTONETTI: [Interpretation] Delinquents who joined as

2 volunteers, I'd like to know, Novacic found this in Vocin, and this is

3 when he found out there were these delinquents.

4 THE WITNESS: Yes, he would discover that in Vocin.

5 JUDGE ANTONETTI: [Interpretation] Very well. Why is it that he

6 didn't send them home at that point in time?

7 THE WITNESS: [Interpretation] In most cases, he did send them

8 back. If they didn't want to listen and lacked discipline, he would

9 mostly send them back in most cases, and then he would complain to the

10 War Staff about having sent all the riffraff to him and not having made a

11 selection.

12 JUDGE ANTONETTI: [Interpretation] So when Novacic found out that

13 someone had a criminal record, was an offender, he would send him back

14 right away?

15 THE WITNESS: [Interpretation] Yes, he would send them back

16 straight away. If they refused to listen to discipline, because there

17 were people who were ready to listen to discipline.

18 JUDGE ANTONETTI: [Interpretation] Very well. So the offenders

19 who obeyed were kept.

20 You were twice with the JNA, so when you were in Vocin, was the

21 discipline in Vocin identical to the discipline within the JNA or was it

22 more relaxed?

23 THE WITNESS: [Interpretation] The discipline, not in Vocin but in

24 Lager, was stronger than in the JNA, and that's why Jovan Trbojevic said

25 to Radovan Novacic on one occasion that he was happy to see him there

Page 5526

1 because his men began behaving in a more disciplined fashion up to his

2 arrival, and we set the example in terms of discipline.

3 JUDGE ANTONETTI: [Interpretation] So if I understood you well, as

4 a conclusion, you seem to be saying that the volunteer's who were with

5 you in that camp were even more disciplined than if they'd been in the

6 JNA?

7 THE WITNESS: [Interpretation] Yes.

8 JUDGE ANTONETTI: [Interpretation] Very well.

9 Please resume.

10 MS. BIERSAY:

11 Q. Mr. Witness, you just described that Novacic would complain to

12 the War Staff about the riffraff that they were sending him; is that

13 correct?

14 A. Yes.

15 Q. Do you know whether or not the War Staff kept on sending

16 riffraff, despite his complaints?

17 A. Yes, they did keep sending all sorts of people, despite his

18 complaints.

19 Q. I'd like to move back to the topic of the relationship between

20 the SRS volunteers, through Novacic, and the TO and JNA.

21 You mentioned that Novacic was in contact with the TO and JNA.

22 Could you describe how he maintained that contact with them?

23 A. We maintained contact through radio link, and we received that

24 from the JNA, or he would go directly to the headquarters to see

25 Jovan Trbojevic in Zvecevo to discuss some matters that needed to be

Page 5527

1 discussed regarding certain actions or weapons or things of that kind.

2 Q. How was coordination done in the field for military actions?

3 A. The plans were made by Jovan Trbojevic. Radovan would be there

4 to discuss the plans with him. But what do you actually mean? Did you

5 mean -- well, we used Motorolas for communication purposes and radio

6 links.

7 I didn't understand your question.

8 Q. If volunteers were to be sent out into the field for military

9 action, how would they know where to go and what to do?

10 A. Well, they would receive orders by radio communication. They

11 would tell us where we needed to go and what was happening on the ground.

12 Q. And who is "they"? You say "they would tell us."

13 A. The army would report to the War Staff in Lager, and the Lager

14 would convey it to Radovan, and he would tell the volunteers where to go,

15 pass the information on.

16 Q. Were there any situations where Novacic would take the initiative

17 as far as directing the SRS volunteers about where they should go or what

18 they should do?

19 A. As there were few of us at the beginning, he would make

20 intervention platoons in order to be able to assist all the locals and

21 the population generally in Western Slavonia in different areas, so that

22 when he would receive information that something was happening somewhere,

23 that's what he could do, but only in extreme situations; for example,

24 when the volunteers hit an ambush, JNA, then the intervention platoon

25 would go and pull them out. Then he would take the initiative. He

Page 5528

1 wouldn't wait for orders from Jovan Trbojevic or authorisation from him.

2 Q. Who provided the food for the SRS volunteers?

3 A. The army did, the army provided food.

4 Q. Who provided fuel for the needs of the SRS volunteers?

5 A. Once again, the army, the Yugoslav People's Army.

6 Q. Who paid the salaries of the SRS volunteers?

7 A. The army, the JNA again.

8 Q. With respect to salaries, were those salaries paid in the field

9 or somewhere else?

10 A. At the beginning, it was in the field, but later on it was paid

11 out at the 4th of July barracks in Belgrade.

12 JUDGE ANTONETTI: [Interpretation] Witness, the questions of the

13 Prosecutor lead me to asking another question which might make things

14 clearer.

15 You have just told us that the volunteers were dressed by the

16 JNA, armed by the JNA, that they executed the orders of the JNA, that

17 they were paid by the JNA. So according to you, what is the difference,

18 on the field, between a JNA soldier and a soldier belonging to your unit?

19 Is there a difference between the two or not?

20 THE WITNESS: [Interpretation] There was a difference, yes.

21 JUDGE ANTONETTI: [Interpretation] What is it?

22 THE WITNESS: [Interpretation] In ideology, ideology. We thought

23 differently than -- to them.

24 JUDGE ANTONETTI: [Interpretation] What were you thinking?

25 THE WITNESS: [Interpretation] We were in favour of the king and

Page 5529

1 the homeland, and they were communists. And we used them, thinking that

2 once we returned to Serbia, we would take over command over the JNA,

3 because already at that time it was on its knees, it was completely

4 degraded.

5 JUDGE ANTONETTI: [Interpretation] So if I understood you well,

6 because I believe that this is very important, you were saying that the

7 difference between you and the JNA is that they were communist, whereas

8 you were monarchists?

9 THE WITNESS: [Interpretation] Yes.

10 JUDGE ANTONETTI: [Interpretation] And if I understood you right,

11 your objective was, and I'm using your words, because the JNA was on its

12 knees, you were going to be able, through this, to take power; is that

13 it?

14 THE WITNESS: [Interpretation] Yes.

15 JUDGE ANTONETTI: [Interpretation] But taking power, for you did

16 that mean to set up a king?

17 THE WITNESS: [Interpretation] Yes.

18 JUDGE ANTONETTI: [Interpretation] And all your friends had the

19 same feeling?

20 THE WITNESS: [Interpretation] Well, most of them, yes.

21 JUDGE ANTONETTI: [Interpretation] Very well.

22 Mrs. Biersay.

23 MS. BIERSAY:

24 Q. Mr. Witness, you described for the Trial Chamber Novacic

25 contacting the SRS War Staff in Belgrade to complain about the quality of

Page 5530

1 the volunteers they were sending. Could you describe for us what kinds

2 of contacts Novacic had with the SRS or Staff in general?

3 A. Well, usually he would have telephone communication to tell him

4 who to contact from the war staff, various needs and requirements, or

5 when he went to Belgrade he would report personally to Seselj in his

6 office.

7 Q. Let's talk first about those telephone contacts. How often would

8 Novacic contact the SRS War Staff in Belgrade by phone?

9 A. Usually, every two or three days, he would call up from

10 Banja Luka or Bosanska Gradiska.

11 Q. Why did he call from those two places and not from where you were

12 based?

13 A. Because the telephone lines weren't working at the time in

14 Western Slavonia, they weren't operational.

15 Q. Were there any SRS offices in the two places that you just

16 described, either Banja Luka or Bosanska Gradiska?

17 A. Yes, offices did exist, and we would call from the Red Cross,

18 too, from their offices.

19 Q. Where was the SRS office from which you would call?

20 A. In Bosanska Gradiska, that's where the office was.

21 Q. What type of information would Novacic convey to the SRS War

22 Staff in Belgrade?

23 A. Well, usually he would recount what was happening on the ground

24 and what was the problems were on the ground, so that they could help him

25 solve the problems. At the beginning, there were problems with uniforms.

Page 5531

1 We asked for more uniforms and additional weapons, because the number of

2 volunteers had increased.

3 Q. What was your -- what was your perception of Novacic's duty to

4 call the SRS War Staff? Was it something he chose to do or something

5 that he had to do?

6 A. Well, as far as I understood, it was something he had to do,

7 because he had a superior above him, the War Staff. He was just the

8 commander to whom the War Staff would issue instructions for him to be a

9 commander, so he had to table reports to the War Staff, because in

10 hierarchal terms they were above him.

11 MS. BIERSAY: Your Honours, I'm about to move into another

12 segment. I'm not sure if the Court would like to take the break now or

13 if I should just begin.

14 JUDGE ANTONETTI: [Interpretation] It's almost time for the break,

15 almost 10.30, so we will have a 20-minute break.

16 --- Recess taken at 10.27 a.m.

17 --- On resuming at 10.55 a.m.

18 JUDGE ANTONETTI: [Interpretation] Well, we shall resume the

19 hearing.

20 MS. BIERSAY:

21 Q. Mr. Witness, before the break we were discussing the contacts

22 that Novacic had with the SRS War Staff in Belgrade, and you described

23 some telephonic contacts. When Novacic would call the SRS War Staff in

24 Belgrade, do you know with whom he would speak?

25 A. He would speak either to Vojislav Seselj or to Ljubisa Petkovic.

Page 5540

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 JUDGE ANTONETTI: [Interpretation] Something I don't understand,

10 and perhaps you can enlighten us.

11 You explained to us that the JNA clothed volunteers, provided

12 weapons, et cetera. Why was there a need to go via the Serbian Radical

13 Party, and why telephone directly to this general, whereas the military

14 chain of command was such that this type of problem could be solved?

15 That's what I don't understand. Perhaps you can explain this to us.

16 THE WITNESS: [Interpretation] Initially, they gave us weapons

17 because there weren't many of us and they were able to arm us. Later on,

18 the number of volunteers grew and there were a lot of us. The army at

19 Zvecevo did not have enough weapons for all of us, so that we had to try

20 and get weapons from Belgrade, from Serbia, for Western Slavonia.

21 JUDGE ANTONETTI: [Interpretation] You said to us that Novacic

22 depended on the colonel in the JNA, Trbojevic. Sorry about my

23 pronunciation. Why was it not this colonel from the JNA who called the

24 general to solve this issue?

25 THE WITNESS: [Interpretation] Well, quite honestly, I don't know.

Page 5541

1 I assume that Trbojevic was a bad officer.

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 Q. At some point when you were in Western Slavonia, did Mr. Seselj

25 come to visit?

Page 5542

1 A. Yes, he did, once.

2 Q. Did he address the volunteers who were there?

3 A. He did address the volunteers, yes, just briefly.

4 Q. Where was this?

5 A. That was at Lager.

6 Q. And could you describe the circumstances around his arrival?

7 A. We didn't expect him to come, but we were told that he was on his

8 way, and Radovan Novacic told everybody to get ready, there were about 50

9 of us there, to get ready for the visit because Seselj would be coming,

10 but not everybody managed to come out. He briefly said two sentences,

11 got into his car, and left for Zvecevo.

12 Q. How did the volunteers feel about that brief meeting or address?

13 A. Some were happy to see him, but most of them were disappointed

14 because it was such a brief visit.

15 Q. Do you recall what Mr. Seselj told those volunteers who were

16 present?

17 A. It was roughly this: "Kill all the enemy, but do not loot,"

18 something along those lines. I can't remember his exact words, but that

19 was the meaning of it.

20 Q. Were all 50 -- the 50 volunteers that you just mentioned, were

21 they all present for this brief address from Mr. Seselj?

22 A. No, not all of them were present. Some hadn't managed to get

23 ready for the visit. They were still in the barracks.

24 Q. So how many volunteers were actually present for that address?

25 A. Well, about 20.

Page 5543

1 Q. Mr. Seselj said, "Don't loot." Had there been looting by

2 volunteers before his arrival?

3 A. Not by the volunteers, there were no instances of looting. But

4 according to what we knew, everything had been looted when we arrived by

5 the locals and the army, the soldiers.

6 Q. Based on your interactions with the volunteers, could you

7 describe how they viewed Mr. Seselj?

8 A. Well, they viewed him -- most of them viewed him -- looked up to

9 him as if he were a god.

10 Q. Do you know why?

11 A. Well, because they considered him to be the person who would

12 bring the king back.

13 JUDGE LATTANZI: [Interpretation] Witness, as far as you know,

14 when -- well, Mr. Seselj, when he is said to have said that you had to

15 kill all the enemy, as you said before, did that mean that they had to be

16 killed during battle, in military terms, or was there a broader meaning

17 within this phrase?

18 THE WITNESS: [Interpretation] I don't know how the others

19 understood this, but I understood it as meaning that the Ustasha forces,

20 the Croatian forces, were those who were supposed to be killed. I don't

21 know how other people understood this.

22 JUDGE LATTANZI: [Interpretation] The Croatian forces who were in

23 combat or also all Croats in general?

24 THE WITNESS: [Interpretation] I personally understood it that it

25 meant the Croatian forces where the fighting was going on. I don't know

Page 5544

1 how other people understood it. I suppose every man understood it in his

2 own way. All I can say is to speak for myself.

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 JUDGE ANTONETTI: [Interpretation] Very well. Let's go back to

25 the sentence that Mr. Seselj allegedly said in front of the volunteers.

Page 5545

1 What was the meaning of this sentence, according to you? Did it mean

2 "kill them in combat, during the fight," according to rules of war, or

3 did it have a broader sense?

4 THE WITNESS: [Interpretation] Your Honour, I understood it that

5 they should be killed in combat. I don't know how other volunteers

6 understood this. That was my understanding of it.

7 JUDGE ANTONETTI: [Interpretation] Very well.

8 THE WITNESS: [Interpretation] Because in wartime, discipline is

9 paramount. If discipline is observed, then military rules and laws can

10 be obeyed. But if there's no discipline, then nothing is respected or

11 obeyed.

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 A. Yes, that information did arrive, and on television they showed

Page 5546

1 how the population of Western Slavonia were fleeing the area on tractors,

2 small vans, trucks and so on. And the reports said that there was

3 general chaos in the region, and they did have information that some very

4 strange things were going on over there. I personally didn't know what

5 it was all about.

6 Q. Let me stop you for a minute. Let's take that bit by bit.

7 You say that you saw on television that the population was

8 leaving Western Slavonia. What population, the Serb population or the

9 non-Serb population?

10 A. The Serbian population was leaving the territory of Western

11 Slavonia, and it was on the news, on television.

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 5547

11 Pages 5547-5551 redacted. Private session.

Page 5552

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 MS. BIERSAY: Madam Registrar, if we could see 65 ter

20 number 4153. And I'll also give you the numbers for the others that will

21 follow. I will ask for 4170, 4177, 4191, and 4221. And for the Court's

22 information, these are photo stills taken from video 40000278, which has

23 already been admitted into evidence.

24 Q. Mr. Witness, directing your attention to 65 ter number 4153, do

25 you see anyone that you recognise in that photograph?

Page 5553

1 A. This is Zoran Drazilovic, nicknamed "Cica" on the right.

2 Q. And what, if anything, is he wearing on his head?

3 A. He's wearing the "sajkaca" or peasant-style cap with a

4 cockade on the cap and also on his lapel.

5 MS. BIERSAY: Is it possible to have the witness mark with an "X"

6 the person he has identified?

7 THE WITNESS: [Interpretation] [Marks]

8 MS. BIERSAY: At this time, we'd move for the admission of 65 ter

9 number 4153.

10 JUDGE ANTONETTI: [Interpretation] Number, please.

11 THE REGISTRAR: It will be Exhibit P315, Your Honours.

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 MS. BIERSAY: If we could now go to 65 ter number 4170, please.

17 JUDGE ANTONETTI: [Interpretation] Just one question, a technical

18 question, before moving on.

19 This person that we saw that had two cockades, one on his head or

20 hat or beret and the other one on his jacket, what exactly does this

21 cockade mean ?

22 THE WITNESS: [Interpretation] The cockade designates the Serbian

23 Chetnik Movement. All Chetniks wore these cockades.

24 JUDGE ANTONETTI: [Interpretation] Yourself, did you wear one?

25 THE WITNESS: [Interpretation] I personally didn't have a cockade,

Page 5554

1 but some volunteers did.

2 JUDGE ANTONETTI: [Interpretation] Did you have to buy this

3 cockade or was it given to you?

4 THE WITNESS: [Interpretation] Usually, one would buy it in Knez

5 Mihajlova Street as a souvenir.

6 JUDGE ANTONETTI: [Interpretation] Very well.

7 THE ACCUSED: [Interpretation] Mr. President, for the sake of the

8 Chamber, I have to draw your attention to the fact that these two

9 cockades differ from each other, and you should bear that in mind, the

10 one that Razilovic [phoen] has on his chest and the man next to him who

11 is Chetnik, Vojvoda Jovo Ostojic and this witness doesn't know. I kept

12 drawing your attention to the fact that these cockades differ, depending

13 on who manufactured them.

14 JUDGE ANTONETTI: [Interpretation] Very well.

15 Witness, it seems that these two cockades are different. What

16 can you say about this?

17 THE WITNESS: [Interpretation] Well, quite honestly, I didn't pay

18 much attention to the differences among the cockades, between the

19 cockades. I only stated that, yes, he has a cockade.

20 JUDGE ANTONETTI: [Interpretation] Very well. It's on the

21 transcript, and the Judges will be very careful with this.

22 Mrs. Biersay, you may resume.

23 MS. BIERSAY: Thank you, Your Honour.

24 Q. Mr. Witness, you mentioned that these items could be bought as

25 souvenirs; is that correct?

Page 5555

1 A. Yes.

2 Q. Were there other types of memorabilia or insignia that could be

3 bought as souvenirs?

4 A. One could also buy SCP membership cards in various colours, black

5 with a skull and cross-bones, white, blue. I would take my membership

6 card and go to Zoran Drazilovic and say, "I want my membership card to be

7 different from the others." And I would take that to him and he would

8 put a stamp on it and sign it, and that was a sort of souvenir.

9 Now in Knez Mihajlova, they're selling t-shirts with pictures of

10 Ratko Mladic and Radovan Karadzic. At that time, they were also selling

11 membership cards with different colours, in gold letters, with

12 double-headed eagles, so anyone could choose what they like, whether a

13 separate coat of arms or --

14 JUDGE ANTONETTI: [Interpretation] To the extent that the

15 volunteers in your group seem to have all been monarchists, this cockade

16 that we see, was it a monarchist emblem or not?

17 THE WITNESS: [Interpretation] This one, now, I really don't know.

18 You can't see it very well.

19 JUDGE ANTONETTI: [Interpretation] But did monarchists have a

20 specific symbol or insignia?

21 THE WITNESS: [Interpretation] Yes, it had to have a crown, which

22 signifies the king.

23 (redacted)

24 (redacted)

25 (redacted)

Page 5556

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 Q. Mr. Witness, what did you hear the volunteers say about the idea

9 of greater Serbia?

10 A. Well, it sounded nice. Everybody liked the idea.

11 Q. Did the monarchists also like the idea of greater Serbia?

12 A. In principle, the monarchists were just helping the people. They

13 weren't thinking along those lines.

14 Q. And if I could now direct your attention to the photograph in

15 front of you, which is 4170, and again this comes from the

16 previously-admitted exhibit.

17 Mr. Witness, do you recognise anyone in that photograph?

18 A. The only person I recognise on this photograph is Brne. He's one

19 of Seselj's Vojvodas.

20 Q. And could you mark with an "X", and could we also capture the

21 electronic version as an exhibit.

22 A. I would have difficulty recognising him if he were to take his

23 cap off, but he always wore this cap at that time.

24 MS. BIERSAY: May we have an exhibit number for that photograph

25 and the electronic copy as well.

Page 5557

1 JUDGE ANTONETTI: [Interpretation] Yes. Registrar, please.

2 THE REGISTRAR: The photograph will become Exhibit P316, Your

3 Honours.

4 JUDGE ANTONETTI: [Interpretation] Witness, please, you just

5 talked about a Vojvoda. Looking at him, we see that he's in military

6 dress, he's wearing a camouflage uniform with a belt, maybe a weapon,

7 can't really see that, and as you said, he's got this strange headgear.

8 If you remember well, do you remember what the emblem is on this cap?

9 THE WITNESS: [Interpretation] You can't see very well here. It's

10 all white. I really don't see this very well, but he has these flaps

11 coming down like a sort of curtain from his cap, and he was really

12 distinguishable by that.

13 JUDGE ANTONETTI: [Interpretation] To what unit did he belong?

14 THE WITNESS: [Interpretation] Well, quite honestly, I knew that

15 he fought in Bosnia, and I know him only by sight. I saw him once in

16 passing, but I don't know the man personally. I heard from others that

17 it was him.

18 JUDGE ANTONETTI: [Interpretation] Well, what did the others say

19 about him?

20 THE WITNESS: [Interpretation] They said that this was Vojvoda

21 Brne, that Seselj had created him a Vojvoda.

22 JUDGE ANTONETTI: [Interpretation] And what is a vojvod, according

23 to you?

24 THE WITNESS: [Interpretation] In my opinion, Seselj can never be

25 a vojvoda because the king has to declare him to be a vojvoda. If Rajic

Page 5558

1 is a vojvoda, he can not create other vojvodas. He's simply turning

2 people's heads, misleading the people. He was making fun of the people,

3 what he did with making these vojvodas, he was making fun of the people.

4 JUDGE ANTONETTI: [Interpretation] So according to you, only a

5 king can create a vojvoda?

6 THE WITNESS: [Interpretation] Yes.

7 JUDGE ANTONETTI: [Interpretation] And when the king is not

8 reigning, what happens then?

9 THE WITNESS: [Interpretation] Well, then there are no vojvodas

10 either. I can declare myself to be an emperor, Emperor in Majentija

11 [phoen], if there's no king.

12 JUDGE ANTONETTI: [Interpretation] Right.

13 Mrs. Biersay.

14 MS. BIERSAY: If we can turn to 65 ter number 4177, please.

15 Q. Mr. Witness, do you recognise anyone in this photograph?

16 A. Yes.

17 Q. And who is it that you recognise, and could you indicate by

18 placing an "X"?

19 A. Milika, Ceka, Dacevic, that's him here, and this is Cele.

20 Q. Could you put a "1" on the first person you described and a "2"

21 on the other?

22 A. [Marks]

23 Q. Who is the person that you're marking with a "1"?

24 A. He's from Pirvoj [phoen], a Montenegrin. He was also declared to

25 be a vojvoda. Milika, Ceka, Dacevic.

Page 5559

1 Q. And who is number 2?

2 A. Cele another one of the vojvodas declared to be such, and I saw

3 him around in Belgrade. He was a deputy of the radical Party.

4 MS. BIERSAY: I move for the admission of this photograph as well

5 as the electronic, annotated version.

6 JUDGE ANTONETTI: [Interpretation] A number, please.

7 THE REGISTRAR: This will be Exhibit P317, Your Honours.

8 THE ACCUSED: [Interpretation] Mr. President, the Prosecutor knows

9 very well the first and last name of this Chetnik vojvoda and should tell

10 you so. If the witness doesn't know, the Prosecutor does, because this

11 photograph is entering the record. I don't object too it. That's

12 Miroslav Vukovic knows as Cele, a Chetnik vojvoda. The Prosecutor knows

13 this and should tell you so, so that the document in the file is properly

14 marked.

15 JUDGE ANTONETTI: [Interpretation] Witness, Cele has a name,

16 Miroslav Vukovic. Are you in agreement with this?

17 THE WITNESS: [Interpretation] Are you asking me?

18 JUDGE ANTONETTI: [Interpretation] Yes, yes.

19 THE WITNESS: [Interpretation] Well, I agree, but I only know him

20 by his nickname.

21 JUDGE ANTONETTI: [Interpretation] And what does "Cele" mean as a

22 nickname?

23 THE WITNESS: [Interpretation] I really don't know.

24 JUDGE ANTONETTI: [Interpretation] Very well.

25 MS. BIERSAY: If we could now move to 4191, please.

Page 5560

1 Q. Do you recognise anyone in this photograph, Mr. Witness?

2 A. Ljubisa Petkovic --

3 Q. Can you put a "1" on Mr. Petkovic?

4 A. Here it is. This is Aleksic and Drazilovic, the one on the far

5 right, Zoran Drazilovic.

6 Q. Could you please put a "2" on Aleksic and a "3" on Drazilovic?

7 A. [Marks]

8 MS. BIERSAY: And may we have an exhibit number for that --

9 THE REGISTRAR: This will be Exhibit P318, Your Honours.

10 MS. BIERSAY: And, finally, if we could move to the next

11 photograph, 4221.

12 Q. Do you recognise anyone in this photograph?

13 A. This is Aleksic. I don't know the others, but I saw him several

14 times in passing.

15 MS. BIERSAY: May we have an exhibit number for this photograph

16 as well.

17 JUDGE ANTONETTI: [Interpretation] Number, please.

18 THE REGISTRAR: Exhibit P319, Your Honours.

19 MS. BIERSAY: So just to be clear, Your Honours, the Prosecution

20 is moving for the original photograph as well as the

21 electronically-annotated ones as well.

22 JUDGE ANTONETTI: [Interpretation] You want two numbers, in other

23 words?

24 MS. BIERSAY: I'm not sure if it can be a collection where there

25 are two pages for one exhibit or if it's easier to do it as two numbers.

Page 5561

1 JUDGE ANTONETTI: [Interpretation] The original is the video,

2 isn't it?

3 MS. BIERSAY: Yes, yes.

4 JUDGE ANTONETTI: [Interpretation] But the video already has a

5 number.

6 MS. BIERSAY: That's correct, Your Honour. I believe it's P256.

7 But the photographs have a separate 65 ter number, so I think that's why

8 they're being given separate "P" numbers, exhibit numbers.

9 JUDGE HARHOFF: Excuse me, because I'm not sure I understand.

10 What is the purpose of having the blank photograph registered as an

11 exhibit as well?

12 MS. BIERSAY: In my very limited experience, when we get the

13 annotated photographs, they're generally not as clear as the

14 non-annotated ones, so I thought for clarity it would be best just to

15 have both versions, the annotated and unannotated.

16 JUDGE ANTONETTI: [Interpretation] Oh, I see. So you want the

17 non-annotated photograph with a number, two numbers per photograph, in

18 other words?

19 MS. BIERSAY: Yes, Your Honour.

20 JUDGE ANTONETTI: [Interpretation] A and B.

21 Madam Registrar, can you give us the numbers, photograph by

22 photograph, for the non-annotated ones, i.e., the original photo shown on

23 the screen before the witness put in his crosses.

24 (redacted)

25 (redacted)

Page 5562

11 Pages 5562-5567 redacted. Private session.