²²⁵

Thursday, 14 February 2002

[Open session]

[The accused entered court]

--- Upon commencing at 9.00 a.m.

JUDGE MAY: Yes, Mr. Milosevic.

THE INTERPRETER: We kindly request that the microphone be switched on.

JUDGE MAY: The microphone should be switched on. It's on now. Yes.

THE ACCUSED: [Interpretation] Can you hear me now?

JUDGE MAY: Yes.

THE ACCUSED: [Interpretation] I said that I hope and assume that, according to the Rules you explained to me, I won't be interrupted. I should like to start off by saying -- by showing a videotape, so I'd like to show a video first and then I'll continue speaking after that.

JUDGE MAY: Yes. Let that be done.

[Videotape played]

JUDGE MAY: Can we get a translation? Can we have a translation of this, please? Can the interpreters assist?

THE INTERPRETER: The tape is very fast and the interpreters do not have the text of it, but we'll do our best.

JUDGE MAY: Thank you. Yes, let's play the tape again.

[Videotape played]

THE INTERPRETER: [Voiceover] "Allegedly for humanitarian reasons, ²²⁶ people in Yugoslavia still suffering from the effects of war, the poisonous uranium dust and unexploded bombs are jeopardising the situation in Kosovo. The ecological consequences of the war cannot even be foreseen. It is well known that the war has not solved the situation in Kosovo but aggravated it. An important reason for the war was the alleged massacre in Racic. From the beginning, there were doubts with respect to that question, doubts which, after the latest research, has become ever more clear. A report will follow.

"The name in this village in Kosovo is Scorbac [phoen] but it is known as Racak. The Serbs suffered a terrible massacre here, a massacre which led to the attack by the NATO aviation. It occurred in 1999. The head of the verification mission of the OSCE arrived with a number of television crews. They found 44 bodies. Walker said this is a massacre and the result of a civil war between the Serbs and the other inhabitants. Many people were also wounded.

"I need several minutes to gather my thoughts. But what did actually happen in Racak? Here at the university in Pristina, the pathologist examined the bodies, and there was doubt that what happened in Racak was indeed a massacre. We hear her talking for the first time for television, Helen Ranta. I'm conscious of the fact that the whole scene was rigged and that is something that it is possible to do. There were many indications of this in the course of our initial investigations, forensic investigations later carried out on the spot in 1999, and the results of those examinations were sent to the International Tribunal in The Hague. ²²⁷ "Ambassador Walker came to Racak on a Saturday. This was his personal decision, and he qualified the event as a massacre. I systematically avoided the use of that term massacre myself. There is suspicion that it was indeed a massacre, but what could have led up to this event in Racak? Among the dead in Racak were members of the -- Racak was a stronghold of the KLA, and I'm sure that there are many pieces of information to show that in Racak there were undoubtedly conflicts between the Serb forces and the KLA.

"There's no doubt about that. [Interpretation] Apart from that, I was told and I read about this, too, that on that place on that day, KLA fighters were killed.

"What happened in Racak: From the 15th of January, 1999, Serb soldiers went round the streets of Racak. Only later were the 44 bodies to be found. Whether the alleged massacre was a result of the conflict between the Serb forces and the KLA, we're not sure. Here is what another member says: 'We saw the Serbs coming, we took up our positions and opened fire. We thought that they would take it out on the civilians after every one of our attacks as retaliation. Racak, the result of Provocation by the KLA.'

The State Department and Washington, a person well known, with secret reports in the US administration, says the following: 'They will be represented as victims in the world to allow for the West's intervention.'

"German Defence Minister quoted Ambassador Walker. In this secret report of the German Defence Ministry pertaining to the situation ²²⁸ in Kosovo, it says, 'The Albanians were probably killed in an attack by the Serb police on the 15th of January, 1999.' One day later there was an addition to this. Walker acknowledged, on the 22nd of January, in Pristina, that when he toured Racak he was not informed of all the circumstances surrounding the event. Racak and the United States of America was the main news item, and Mr. Walker made the following statement:

"This stepped up the world opinion that something had to be done, and this was the beginning of the developments that led to the bombing, ultimately. The dead in Racak, I don't think we will ever learn the real truth, but the air attacks and airstrikes covered the silence." "This is what Heinz Loquae had to say:

'Walker collected up a number of journalists. He went to the spot and, after a short period of time, said that what had happened was a massacre of the Serbs, in fact. At that particular moment, he was not able to make a judgement of any kind. This opinion was taken over by the OSCE, the United Nations, and all the governments of the world. One day later, NATO held a meeting. It was an extraordinary meeting, and this was quite unusual. With his conduct, Walker had ignited the flame for war, a war which was to be a violation of international law, a war in which many civilians paid with their lives, a war for which German politicians hold the responsibility. What really happened in Kosovo? What was the propaganda used to deceive German public opinion?"

THE ACCUSED: [Interpretation] There's more.

[Videotape played] ²²⁹

THE INTERPRETER: [Voiceover] "Dear fellow citizens, NATO this evening began its airstrikes against military targets in Yugoslavia. "The alliance will stop the further violation of humanitarian rights.

"Yugoslav President Milosevic is waging a merciless war over there. We are not waging war, but we have been called upon to find a solution, a peaceful solution, but even with the use of military means. "This footage shows that the population from the very first days of the war in Kosovo were led astray, deceived. This is how the facts were turned upside down in order to manipulate and to lie. This film shows why the bombs fell on Belgrade. The lies began. "NATO claimed that it threw the bombs to protect the lives of the Kosovo Albanians, but when the first bombs fell, we saw scenes of this kind. The Serbs who were afraid went to take cover in the basements and the shelters that existed in town, although there were few of them. The presenter of a Serb radio said that a group of planes were nearing Belgrade, and asked the citizens to turn off all the lights. "Attention. Attention. A large group of enemy planes are approaching Belgrade. Citizens please take cover and wait. "The fear was visible in Serb children even before the bombing actually began. These are images taken by Yugoslav television. The fear of war is indivisible. One -- this is the picture of war. The NATO power knew the power of images. The most important thing is that the enemy has the monopoly over pictures and images which would show the world public NATO's tactics and not Milosevic's. ²³⁰ "Rather than the deliberate brutalities being inflicted ... [Interpretation] Many journalists said that Milosevic has pictures, too, and words, but who do we believe? [In English] Pictures or the words. [Interpretation] Next time, when CNN or anybody else shows the columns of refugees, I will be able to say that I believe them. But you see this, mass graves, people who were intentionally killed and thrown into those mass graves. [In English] Whose side are you on? "But NATO didn't have the pictures of the mass graves. All it had was these pictures of Albanian refugees from Kosovo. And you can see fear and suffering on the faces of these people, just as you could on the others a little while ago. But what do these pictures tell us? What do they show? Do they help NATO? Do they act as an appeal saying, 'Save us?'

"Is not human suffering a terrible thing? Human rights to Kosovo Albanians, is that a priority or not?

"German Defence Minister Rudolf Scharping explains in 1999 why he sent German soldiers into the war in Kosovo:

We would never have taken military steps had a human catastrophe not taken place with 200.000 refugees in Kosovo and over 400 refugees, and the number of dead as yet unknown, countless dead even before the NATO bombing. The OSCE, European Security and Cooperation Organisation, should have known this because its observers in Kosovo reported regularly about events there in March 1999. One of the reports said there were 39 dead. Was a humanitarian catastrophe imminent?

"German generals or American diplomats who were in Kosovo had the ²³¹ following to say:

'The basis for German's legitimacy in its participation was the humanitarian catastrophe. A humanitarian catastrophe of this kind as an international legal category which would justify intervention in Kosovo existed before the war.'

"Up until the beginning of the NATO airstrikes, there was no humanitarian catastrophe. Of course, humanitarian problems did exist. There were a great number of refugees, but this is how it was. People left their villages when Serbs took action against the KLA and then returned to their own homes. The fact is that it was common knowledge that a humanitarian -- that people knew that a humanitarian catastrophe would take place only when the bombing began. We are discussing this problem on the spot.

"I am giving judgement. No reports from the OSCE speak of an imminent humanitarian catastrophe. The situations that did exist on the ground are similar to the images we are showing now: forces fighting against regular army units, a civil war. That is what the OSCE said in its report.

"The inhabitants of villages would flee in the face of onslaughts of this kind. Later on, for the most part, they would return to their homes, which were frequently destroyed.

"NATO in Brussels was informed with the OSCE reports which coincided with its own reports. However, these details and knowledge were not made public knowledge at any of the numerous press conferences. On the contrary, at the last meeting of NATO, on the 14th of March, 1999, ²³² before the war broke out, they said that we -- that it could be said that the violence came from terrorist actions by the KLA, and the Serbs reacted overly violently. But at that time, they thought that the situation could be kept in check. Nevertheless, NATO forces did prepare for an attack on Yugoslavia. At the same time, the German Defence Ministry held meetings but they, too, did not think that a humanitarian catastrophe was imminent. And in the Defence Ministry's documents with respect to the situation in Kosovo, it said something different to what Rudolf Scharping said. Here we have a quotation from a secret report, intelligence report of the German Defence Ministry. In the past few days, there were no significant clashes between Serb forces and the KLA. The Serb security forces limited their actions to routine operations, the control and patrolling of the area to check for weapons and checkpoints on the main roads.

"But preparations were nonetheless underway for an attack. When the first bombs fell, however, the NATO countries did not lend whole-hearted support to the drive.

"The political leaders now took the lead. They were the democratic representatives of the people and knew what news items were important for their countries.

"Rudolf Scharping really did a good job. It wasn't an easy one, especially for Germany for whom, for the past 50 years, defence was the only security of the country rather than intervention by their soldiers. Psychologically viewed, this new definition of a security policy is not an easy one. Not only Minister Scharping, but Chancellor Schroeder. They ²³³ were excellent examples of political leaders and in their attempts to shape public opinion, and I'm very happy that the Germans understood this. With all the collateral damage taking place, they remained on course. Had we lost German public opinion, we would have lost public opinion in the whole alliance.

"The fight for public opinion was stepped up. Wartime propaganda for domestic purposes was no longer sufficient. Pristina, the capital of Kosovo, was the scene of wartime propaganda, with the focus on the football stadium and we can see destruction and vestiges of destruction around the stadium today, although the grass is being tended. "At the time, the Serbs had a camp for Albanians in this area, and Rudolf Scharping spoke to the public in 1999, making this assertion. It is much more important what is happening in Kosovo now when we hear that, in Northern Pristina, there is a concentration camp, when I hear that teachers and pupils are being rounded up and the teachers killed in front of their pupils' eyes, when the Serb inhabitants are being appealed to write up a big capital letter 'S' on their homes so as not to be expelled. No civilised European must close his eyes to facts of this kind. "The letter 'S' for the protection of the Serbs in Pristina did not exist on the doors of Pristina either in the underground passages of the football stadium. There might just have been a football here or perhaps a cigarette end.

But Rudolf Scharping, even after the war, in his journal, he spoke about numerous prisoners being held here. And Germany's Foreign Minister compared the Serbs to the Nazis on many occasions. ²³⁴ "Up until the present day, Scharping and Fischer have remained by their views. I said that there was every reason to believe that people were held in the underground passages of the stadium. "We tried to clarify this issue but we have statements by eyewitnesses. If somebody knew anything about this, it must have been Kelmendi, a Kosovo politician. His house is right by the stadium. "As you can see for yourselves, we have a good view of the stadium from here. You can see everything. I didn't notice a single prisoner at that time. The stadium was just -- was just used as a Heliodrom. And while he's talking to us, we can see a team emerging on the stadium.

"You can helicopters landing here, that's all. Helicopters landed and the soldiers got out of them. They boarded the helicopters and got off them. The football stadium in Pristina, a concentration camp? No. That was wartime propaganda and something that had been concocted. "I would like to say that a comparison with Auschwitz and the situation in Kosovo is a -- is outrageous. I'm ashamed as a German that German Ministers are uttering things of that kind. And I think Germans could be taken to court for uttering similar phrases. When the German Minister speaks about concentration camps in Kosovo, that is on the same line as saying that concentration camps are a historical situation and existed during the Nazis in Germany. I think that it is unheard-of that the Germans were the ones to use comparisons of this kind. "This is not the only wartime lie that went into the world in order to obtain support from the rest of the world. This is Rogovo, a ²³⁵ small village in Kosovo. It remained virtually intact during the war. Now two years later, people are involved in agriculture again, everyday village life. However, Rogovo has this special importance for the war in Kosovo.

"The story starts at the farm of Sefik Berisha. This, a story that would hit the headlines in far away Germany at a later stage. This is the 29th of January, 1999, two months before the NATO airstrikes began. Neighbours all of a sudden heard shooting from the direction of Berisha's house. What happened? Then on the 29th of January, the following thing happened: It was a Friday, 5.00 in the morning, when this started in my neighbour's house, in Berisha's house. Bursts of gunfire were heard from automatic rifles. This lasted for three or four hours. We woke up. We heard all of this. Three or four hours later, the shooting abated. "About 10.00, a group of policemen came up to us from this direction. My father and I saw them. When they came about 50 or 60 metres away from us, I had no other way out but to flee. I went in the opposite direction.

"This drilled minibus, bullet-riddled, reminds of us of these days. However, what did happen in Rugova? A massacre of Serbs over innocent civilians. That's what Rudolf Scharping said. Two months later, on the 27th of March, 1999, the Minister of Defence presented his evidence.

"What we are showing you now requires good nerves, however, this shows the brutality with which all of this started. When you look at these photographs, you will be able to see easily what this was all ²³⁶ about. You can see the uniforms of the Serb special police. This clearly shows that Serb special forces and the Serb army took part here, and later on, hard criminals.

"These are terrible images, and I have to do my best to control my voice in order not to explode.

"This is what we are waging war for. That's what the headlines said in the newspapers that also carried the photographs. However, his co-workers knew that this had not been a massacre. The secret intelligence reports said that this was not a massacre over innocent civilians.

"On the 29th of January, one Serb policeman and 29 Albanians were killed in Rugova. This was, therefore, a conflict, not a massacre as the Minister of Defence had claimed.

"These images on the footage made by a Western TV station offer proof of what had actually happened. Military equipment and arms by the bodies of the alleged civilians who were wearing military boots with signs of the KLA. However, what happened before the Western journalists came? "The example -- as far as the example of Rugova is concerned, what did you actually base this on?

"Well, on the reports of the observers who first came there. "Did you paint a direct picture of what happened in Rugova as things actually happened?

"Yes, this is quite correct. The first observer of the OSCE who arrived is this man on the left-hand side. That is a German policeman, Hennig Hensch. ²³⁷ "It is correct at any rate what the Minister of Defence said on the first day in his statement, that I heard and saw on Dojcevele and this does not actually coincide with the way I had portrayed things to him. "The official report about the events in Rogovo makes no mention of a massacres over civilians. This is where we found a bullet-riddled minibus with a total of 14 bodies. Three bodies were outside the vehicle.

"In the garage, there were five more bodies of KLA fighters in uniform.

"Three hundred metres away, we found four more bodies. The bodies that were shown by the Minister of Defence, we gathered them altogether in one spot, the Serb policemen, I, and two of my Russian colleagues. "This is how this video footage was made concerning the alleged execution, as Minister Scharping had put it, nothing that have anything to do with the actual way these events evolved. It was quite clear that this was no massacre over civilian population because, according to OSCE reports, even KLA commanders stated that fighters for the great Albanian cause had lost their lives there. However, the German Minister turned this into a massacre.

"New York, April 1999. While Scharping was talking about a non-existent massacre and a concentration camp that had never existed, the process was proceeding at full steam. In Germany and the United States, a war atmosphere was being created because NATO strikes were against international law. Only the UN would have the mandate to wage this kind of war. However, there was no mandate of this nature. ²³⁸ "The security people were very busy then because heads of state or government were meeting. And the debates behind closed doors were becoming increasingly sharp.

"April 1999, in the United Nations debates were going on about the war. At the same time, airstrikes were proceeding. Six thousand times in total, without approval of the United Nations. This is no surprise because the policy of the United States is very well known in the United Nations and also its attitude toward the world organisation. "Already in 1993, Clinton, in a secret report, pointed out what America's policy would -- was charted in a report. If necessary, we will go with the UN. If necessary, without them. So NATO had to decide on behalf of the UN rather than having things the other way round. The intervention in Kosovo took place without the mandate of the UN and this is obvious violation of international law. The German Minister of Defence took part in this. But why?

"An important American advisor had access to secret American plans.

"Some of the administration members involved in foreign affairs said that Kosovo was only the beginning for future wars that NATO would wage in far away countries. Washington did not care about presenting its leading role in NATO because it was never questioned. We have seen that NATO was gaining a new role which was quite different for the reason why it had been established, which had originally been a defensive role. "This is the premises where NATO meets. Was NATO supposed to turn into a new policeman of the world? As far as the United States is ²³⁹ concerned, that is perhaps a usual stand, but it would be difficult to explain it to the American public and the world public because the war in Kosovo was increasingly being criticised, especially when the aircraft missed military targets and hit columns of people who were moving. They called it collateral damage, but the public became increasingly critical vis-a-vis the NATO strikes, especially in Germany. "The beginning of April 1999, NATO headquarters, and now calls were being made to restrict collateral damage.

"After the column of refugees at Djakovica was attacked, the approval of the public in many countries, including Germany, went down by 20 per cent. We had to work hard in order to win the confidence of the public once again. Milosevic made a mistake when he started expelling the Albanian population to Macedonia and Albania. There were these streams of people crossing the border and there were TV crews filming all of this at the borders, and that is how the public came to support NATO efforts once again.

"These are the images that Jamie Shea was referring to. And these documents were Milosevic's mistaken war propaganda. Images of Albanian refugees at the Yugoslav-Macedonia border, every evening, in every news programme, this kind of footage could be seen, suffering and expulsions. However, in Germany, obviously, these pictures were not sufficient. Now it was being said that the Serbs had planned the ethnic cleansing of Kosovo for a long time. The killings in Kosovo got a name, ' Operation Plan Horseshoe.'

"I'm now going to talk to you about what happened for months, ²⁴⁰ ever since 1998 on the basis of the Horseshoe operation plan. Some parts show that the Serb army had not only prepared the expulsion of the Albanian population but that this had actually begun. This shows that these systematic actions had been planned in October 1998 and carried out in January 1999.

"This was supposed to be this operation plan. The Serb units, deployed in the shape of a horseshoe, surround Albanian civilians and expel them. Before the bombing, Serbs were systematically carrying out actions against the Albanian civilians. That's what this brochure said, and this image was there to support it. However, the date here says April 1999, that is to say, after the NATO strikes began. That is why what happened in the village of Randubrava is no proof whatsoever of the existence of a plan called Horseshoe.

Randubrava today. There are very few signs of war. This is reconstruction. Tiles that are covering roofs now, the villagers got them from a German organisation. However, was it really the Serbs that attacked the village and torched the houses as Minister Scharping had said? In that case, that would have corroborated the existence of plan Horseshoe.

"The villagers left the village after the 25th of March, after the NATO airstrikes. In the evening, we received orders from the KLA that we were supposed to evacuate the population. On the 26th of March, here in this village, there was no one left. We took everyone to the village of Malusha, and it was only then that the Serbs shorted shooting. We were fighters of the KLA. We were defending ourselves but this was ²⁴¹ impossible. We were helpless against tanks and guns. "There were 85 fighters in all, but there were other people, too. There was a total of 120 fighters.

"This has little to do with planned expulsions of a civilian population. Was Minister Scharping dispelling -- dispensing with the truth in his brochure?

"It is not easy. After all, there were witness statements as well. There are people who fled. There are people whose lives were threatened and who testified nevertheless. There were no OSCE monitors there before the fighting started.

"Rudolf Scharping, in his brochure, does not only refer to the village of Randubrava as proof of the operation of Horseshoe. Another village was attacked but this photograph was also taken in April 1999, when the airstrikes had already begun.

"This is where the village is, the one that is mentioned by the Defence Minister in his brochure. However, the village is not Crkvice but Krsnica.

"Even nowadays traces of the war can be seen. Many houses were razed to the ground. The 100 or so villagers will need a long time to rebuild their village.

"Thank you, say the children in the German language, because the construction materials came from the German humanitarian organisation over here as well. In Pregadica [phoen], the Serbs wanted to destroy the homes of these children forever in a particularly perfidious way, says the brochure. First the Serbs would light a candle by the roof and then they ²⁴² would turn on the gas in the basement. However, this was not a reaction to the airstrikes but to the operations related to Horseshoe plan, says Scharping, that is to say, planned destruction before the NATO attacks began. However, in Pregadica, people seem to remember something else. "All of this happened already in June 1998. There were many people there from the Yugoslav army then who were getting closer from the direction of the neighbouring village. However, we managed to turn the army back. Then we attacked them and we opened fire from heavy weapons. And this went on for four days -- four weeks. Practically, there was not a single place where a shell had not fallen. That is the way it was throughout this area.

"The destruction took place in June 1998. However, according to Scharping's words, Milosevic elaborated Horseshoe plan only later in December 1998. What happened with the candles and the gas that Scharping was talking about? "No. The houses in our village was not torched in that way. This happened in different ways, but not in that particular way. The houses were ablaze because of the shelling, but not due to candles and gas that were lit.

"Again, there is no proof of this alleged Horseshoe plan, but there is evidence of manipulation and forgery by the Ministry of Information. This story that Serbs were entering villages and turning on the gas on the ground floor and lighting candles by the roofs and the attics show that this method does not work at all. You can't really torch a house that way. Really? No, this doesn't function that way. Chemically, physically. No way. This must be information that ^{243 BLANK PAGE 244} you got from eyewitnesses which is either incorrect or that not checked at all. Therefore, I would recommend to you that you do this test once again but not with a gas but with a gas bottle. However, neither of the variants worked. Gas is heavier than air. The Minister also noticed how easy it is to detect such lies and manipulations. Later on, photographs of these two villages were shown once again but without the mentioned texts.

"This is an edition from 1999, and that text was removed altogether.

"May 1999. This is the second month of the war. There are more and more German pilots preparing to take part in the attack, and we know that it was civilian targets that were hit, not only military targets. NATO used especially destructive bombs in Kosovo. Despite the unpopular regime in Belgrade, the German public opinion began to wonder whether the war intervention in Kosovo was justified.

"Despite Scharping's assertions that Operation Horseshoe existed, there was not enough proof to bear that out.

"Two years after the war, we asked Rudolf Scharping once again what happened with Operation Horseshoe. We had intelligence information which I received at the beginning of April 1999 via the Foreign Minister. I asked our experts to check out that information and to compare them with information from the electronic surveillance service for intercepting Serb paramilitary formations, which was done. And only when this comparison confirmed our suspicions, we used them publicly. "I asked for a meeting in the Defence Ministry, and a meeting was ²⁴⁵ accorded me in November. They told me that there was no Operation Horseshoe in existence but just that the events in Kosovo were shown events that had already taken place, and we were able to check those events out on the basis of OSCE reports. Operation Horseshoe or Potkovica did not exist. That's what the experts at the Defence Ministry told me. "These are the Albanian refugees from Kosovo, the victims of the Serbs, but not as the results of the Horseshoe operation. This was just a fabrication of the German Defence Ministry. Wartime propaganda, just as the alleged concentration camp in Pristina was or the massacre of villagers in the village of Rogovo. The suffering of civilians was also the consequence of NATO strikes.

"The political debacle of the war in Kosovo was now being talked about, but the German government did want to involve its soldiers in the operation, and it had to win over public opinion. But the fate of these people was unknown. What would happened to them, nobody knew. "In the past, the German military leadership was often criticised for keeping silent where they ought to have spoken out. I wanted to say something, too, faced with a situation of that kind. I did not wish to leave propaganda of this kind intact, untouched. However, lies and propaganda are very often stronger and more powerful in wars. It is the weapon with which truth is slain."

THE ACCUSED: [Interpretation] This is just an atom, even smaller than an atom, of the truth, even less than an atom of the truth in the ocean of lies and the product of propaganda and the abuse of global media as a means of war against my country. ²⁴⁶ You have heard the German general, and we selected Germany on purpose, Germany, England, their broadcasts. We did not show Serb programmes. We don't know those people, but you heard the German general who said he was ashamed as a German of how his government behaved. And as you read all my mail - I get a lot of mail and I'm sure it gives you a lot of work - then I'm sure you were able to read the letters of American officers who are ashamed of their own government, the letters I received from English intellectuals and soldiers ashamed of their own government, letters from French war veterans who are likewise ashamed of their government, and so on and so forth.

In the West, where we see a complete media darkness, if I can use that term, when it comes to Yugoslavia, because world global networks have been assigned the task of being an instrument of war and of disinforming the public. In the West, people of this kind are raising their voices increasingly frequently, people who like truth more than the comforts they get from a mute implementation of the tasks assigned them by their bosses. And I'm sure that the public will realise this, that these voices will become ever louder, the voices of truth, and that the shame will be ever greater, the shame that falls on those who lied about Yugoslavia and who used a media war to make a front detachment of war, a war in which people died, a war in which there was great destruction. But let me move on and say what I wanted to say.

This is the first opportunity that I have been given, after seven months here, to address the public.

Over the past two days, all the Prosecutors that we have heard ²⁴⁷ here have uttered one particular sentence; that is to say that they are just trying an individual, that it is an individual who is on trial here. Now, that is a very sensitive -- it is a sensitive point to link this up with a nation, with a people. So they're trying an individual and not a nation. All three Prosecutors said that. But in all the indictments, they are accusing the whole nation, beginning with the Serb intelligentsia. They have accused the Serbian intelligentsia, led by the Serbian Academy of Arts and Sciences. And we even heard quotations from the memorandum issued by the Serbian Academy of Arts and Sciences which were allegedly the ideological groundwork and foundation for the crimes committed against the Albanians. We are talking about a memorandum in which Serbian academicians set out the situation honestly, and that was 15 years ago now. They spoke responsibly about -- and authoritatively about the situation in Kosovo.

But the fact that they have accused the Serbian academy and Serbian intelligentsia is just one aspect. They are accusing St. Vidovdan and the battle of Kosovo Polje. They have even made the remark that they don't know what it is we celebrate and why these 2 million people rallied together at the field of Kosovo Polje to celebrate their 600th anniversary when we lost that battle. What he does not know is the following: That is to say, if he can accuse Serb history and the battle for Kosovo, it was a battle for Serbs and for Europe, for both Serbia and for Europe. But it is not only the Serb intelligentsia and the Academy of Arts and Sciences and the St. Vidovdan battle of Kosovo, but everybody who lent support, the government, the parliament, the various political organisations, the ²⁴⁸ media. They all stand accused here. All this stands accused. The citizens stand accused, citizens who lent their massive support and elected their representatives at free party elections. We just agree on one point here, that my conduct was the expression of the will of the people. But the Prosecution is accusing the population of supporting me and let me say that my behaviour here is an expression of the will of the citizens as well, the will of the people. They are accusing the army and the police, the volunteers and the Territorial Defence. And as he says so himself, he will be referring to these collectively as Serb forces, and that is what the Prosecutor has indeed done.

He has accused Serbia and all Serbs who supported me in Serbia and those Serbs who supported me outside Serbia, and all the people who support me in Serbia to this day. And then he is accusing the people, the nation.

We have heard all this in the past two days. We have heard everything.

And then he says that he is just accusing an individual, and that individual is myself. And he probably thinks that I am superhuman, having these superhuman powers of influencing people and responsibility and accountability outside the territory of my own country. He has subscribed to me some magical God-like powers, and he keeps dealing with my emotional state, what was in my head, what I wanted to achieve, and things of that nature.

The Americans go right the other side of the globe to fight ²⁴⁹ against terrorism. In Afghanistan, a case in point, right the other side of the world. And that is considered to be logical and normal, whereas here the struggle against terrorism in the heart of one's own country, in one's own home, is considered to be a crime.

That means that you are not master in your own home, that you can't react to terrorism in your own home. And I'm going to show the nexus, the link between the two.

In this false indictment, they have gone even further than anybody's imagination could have forecast or conjured up. They even claim, and we have heard this over the past two days, that I intentionally caused the NATO aggression and war against Yugoslavia and the sufferings of millions of its citizens for the sole purpose of using this occasion to kill the Albanians. Now, I have to ask myself, Could they have thought up anything more intelligent?

They even go further. Yesterday we heard the following: They say I was not interested in any borders but just one single border, the border between what was Serbian and not Serbian, the Serb and the non-Serb, although it is precisely Serbia, and indeed Yugoslavia, which throughout those years of the Yugoslav crisis was the sole country, the only country on the territory of the former Yugoslavia in which there was no national discrimination and which wholly preserved its national structure. It is exactly the same as it was 12 years ago when the crisis broke out. Yugoslav reality shows that this terrible position is incorrect, this terrible fabrication. So these nebulous constructions we're going to have to hear here, but we're going to shut our eyes to the Yugoslav ²⁵⁰ reality. And it is not only present-day reality, but it has been reality for more than one decade. And it is precise and completely -- renders null and void nonsenses of that kind.

Serbia, and I personally, therefore, are alleged to be waging a political genocide outside Serbia. But this policy of genocide somehow does not seem to exist in Serbia for which we are solely responsible, because as the President of Serbia, I am responsible for Serbia. Whereas they want to ascribe to me responsibility and accountability for everything that they themselves did and all the crimes that they perpetrated themselves. They claim, and I have been listening and hearing this for the past two days, and I consider the defence to have been a heroic defence. Our defence was a heroic defence, a heroic defence from an aggression launched by NATO, the NATO pact. But this was only a mask for us to use the occasion to commit crimes against Albania. Now, this is an outrage against a whole people, against a whole nation. It is insulting to a whole nation.

What you are doing is taking a fact, a fact that is common knowledge to this whole world, to this whole planet of ours, and that fact is the day and night bombing of Kosovo. Day and night bombing, 24 hours, round the clock, every day for 78 days at which the alarm was sounded every day. People were on the alert for 24 hours. Now, they wish to negate that fact by bringing witnesses here who are going to say that they in fact fled from Serb forces, as you call the army and the police. Now, this well-known fact, a fact that is well known to each and every citizen on this planet of ours, will be denied and challenged by ²⁵¹ witnesses who will be coming here and say, "No, we didn't flee from the NATO bombs, we fled from Kosovo in the face of Serbian forces." And you saw a moment ago Western footage that denies this. You heard Western generals and there are many more of them. All of them will have to come here -- not have to come; many of them wish to come. They want to come to tell you and your bosses what the truth is, where the truth lies and what are lies. This is a whole construction, a prefabrication, and it is all lies.

And this fleeing that you refer to, using the term "deportation," that coincides with the bombing, too. In the indictment itself, the dates that exist there, they all coincide with the bombing period. So even that is proof that is yet further proof that this whole thing is a manipulation of facts and an attempt to make crimes appear as victims. NATO bombed and massively killed the Albanians themselves who were only returning to their villages, who did not listen to the KLA when the KLA told them to flee, because the KLA beat them and killed them, endeavouring to force them to flee because that was the conception that Mrs. Albright talked about. We are expelling the Albanians. That means that the Albanians have to leave Kosovo to -- for the world to see that we are the ones expelling them. Slogans were being thrown out from aeroplanes, written in the Albanian language, appealing to citizens to flee Kosovo, and the KLA did the same. And they killed those that set up resistance. Nonetheless, Albanians did return to their villages and did not want to flee Kosovo, and they remained in Kosovo. Those who were in the war zone and operations, of course they fled. They had to flee. They ²⁵² fled -- Serbs fled to Hungary. They fled to Republika Srpska. Many people who fled during the war went to Republika Srpska, for example. And I am -- and would you say that the Serb forces, according to the indictment, made them leave? You could make a construction of that kind. Perhaps in the next ten years, you will think up another accusation for something that your own people did.

I really wonder whether there is a court that is going to look at 78 days of bombing, day in, day out, and is there a court that is going to disregard that fact in favour of witness statements in which people say that they had to flee on the basis of this kind of a claim, that they were being expelled by Serb forces.

I want to state here with full responsibility this horrible and incredible lie is being uttered by the Prosecutor as a means of crime. After all, perhaps the best would be for you to accept this lie uttered by the Prosecutor so that this whole farce could have that as its crown. What we have heard insults the intelligence of an average inhabitant of this planet.

Yesterday we heard a composition, so to speak. Where there are deportations, there are killings there, too, as well. The truth is this is a conflict with terrorist, with terrorist bands, and also where there is bombing. And most often there is a conflict with terrorists and there are bombings. Because it was not a rare occurrence that terrorists, when they would set out during the war, would receive support from their allies who waged the war against Yugoslavia with them. So the truth is that where there is a conflict and where there is bombing or most often both, ²⁵³ that is where one can see flights of the population. And then we have been listening to this interpretation for two days, this conflict with these bands and the bombing. And we heard this and saw this in Western footage, not Yugoslav footage. This is considered to be killings by the Serb forces. And when people were fleeing from these places of conflict, then this was qualified as deportation.

I repeat, the population from Kosovo was expelled by the KLA because they ordered people to do so. They beat them, and they killed them. That was number one.

Number two, NATO, through their airstrikes. That is the truth behind your story about deportations.

And I want to say here something that everybody in Serbia knows. In the Serb tradition and in the tradition of the Serb military, a prisoner of war and an unarmed person is held sacred. Whoever violated this sacred principle has to be held accountable. However, this was not done by the military or by the police.

I'm not trying to say that this had not been committed by some individuals or some groups, but this was not done by the army or by the police. The army and the police defended their own country with honour and chivalry. Armies and groups that may commit crimes exist anywhere in the world and are condemned and prosecuted anywhere. Such dirty crimes cannot be ascribed to an army, a police, a people, a nation, a country, their government. It is precisely the members of this army and the police who know the best how many terrorists had escaped from them ²⁵⁴ precisely by mingling with civilians. They would actually see them from a few hundred metres away and they would easily recognise them in the masses of civilians because usually they were only wearing their underwear, having thrown away their uniforms so that they could escape. They all managed to escape because there was a strict prohibition from the top downwards because nobody was allowed to fire even at terrorists if this would endanger the civilians or even lead to their killing. A multitude of them escaped.

The American representatives knew that full well, those who were criss-crossing Kosovo. And we talked to them about this. And of course the terrorists knew as well that the army and the police had strict orders that they were not allowed to open fire wherever there were civilians, and of course they abused this. And they easily escaped that way, having just taken off their uniforms. And then they would mingle with civilians and that's how they would run away. Many comments were made in respect of this. However, these orders remained standing.

That is to say that the task of the military and of the police was to neutralise the actions of terrorists and to protect civilians at the same time, to protect citizens. All orders, all actions taken by commands and individuals corroborate this. After all, this fabricated deportation, could it have been organised, especially in massive proportions, without an order, without an organisation? And there was no idea of this nature. There was no action of this nature. This was never mentioned. Never, not in a single variant. Not even in the variant when a witness could be brought. ²⁵⁵ Yesterday you heard witnesses who were calling TV stations and saying that they were not prepared to support what they heard reported from the courtroom yesterday. No way. They were phoning yesterday when they were watching the broadcast, when during your break here in this courtroom they would phone journalists and say, "You have said such-and-such a thing. No way. I'm not going to testify. That's not the way it happened." Well, bring these witnesses. Let us finally hear who are these people.

I personally am not going to prevent any witness from coming here. Whoever will speak the truth here will not say anything that is dishonourable or that has anything to do with my personality, my policy, and the work of my government. Nothing. And you can bring as many of them as you want.

An incredible number of things have been mentioned here by way of proof. Please. Yesterday, I heard the following: Three generals had received decorations. Well, what's wrong with that? Several thousands people were decorated for having defended their country. We are the only country that managed to shoot down a so-called invisible NATO plane. When I saw it at the Wright-Patterson base and when I touched it with my own very hand, Holbrooke explained to me that they paid 2.5 million dollars in order to construct that. And then the commander of the base told me it costs $40 million nowadays. He was whispering in my ear and saying, "He's lying. It costs at least 250 million now." This is a wonder of technical achievement and they said nobody could shoot it down. We managed to shoot it down. ²⁵⁶ Well, this man who shot down an invisible aircraft that had come to sow death among children, didn't that man deserve a decoration? He deserved 50 decorations. Everybody who shot down a plane got a decoration. Everybody who shot down a cruising missile was decorated as well, all kinds of cruising missiles. All kinds of cruising missiles you used over Yugoslavia. And not to mention how many thousands, tens of thousands of sorties were flown. We heard the conversation between General Short, who commanded the air force from the base in Florence, and his son who was wounded. He was worried then. However, we will come to this in time and, after all, that tape also exists. In due time, that will be clarified like many other things over here. Several thousands of people in Yugoslavia were decorated for their courage in the war. Also, thousands of people were decorated for their efforts in the reconstruction of the country because only in a few months' time we managed through a superhuman effort of many citizens to reconstruct the country, to go back to a normal life, to try to go back to a normal life, including these people who had been misled and they did not know what they had been doing to their own detriment. I heard yesterday the Prosecutor literally mocking the fact that Serbia was not at war with Croatia or with Bosnia. Gentlemen, Serbia was not at war with Croatia or with Bosnia. Why do you want to make Serbia and Serbs responsible for the war in Croatia and Bosnia-Herzegovina? And now in your indictment you have been moving from one event to another in Bosnia and Croatia and neither I, nor anyone in Serbia, know anything about this. Many people, as a matter of fact, in Bosnia itself hardly ²⁵⁷ know anything about this except people locally. Of course, I'm not talking about major events. They just knew that there was fighting going on there, and that we were making an effort to make an end to the fighting as soon as possible.

The corridor near Brcko. Why was it portrayed yesterday as some kind of a criminal operation, so to speak? It's included in the indictment. This corridor near Brcko was the subject of at least 50 conversations between Owen and Stoltenberg and the representatives of the Muslims, Serbs, and Croats in Bosnia: Karadzic, Izetbegovic, Boban. I was present and so was Tudjman as well. At least 50 times this was discussed because this corridor by Brcko links eastern and western parts of Republika Srpska. When you look at the map, you will see this easily. The entire region of Banja Luka and the Bosanska Krajina communicate with the eastern part, and further to the east with Serbia through this corridor. This was a vital route all ways, and I don't see what the meaning of this is in this regrettable opus of yours. All of Bosnia-Herzegovina was actually a small-scale Yugoslavia, just as the big Yugoslavia consisted of several peoples, ethnic groups who lived together in harmony and developed. That is how Bosnia and Herzegovina consisted of Serbs, Croats, and Muslims. Your bosses broke up Yugoslavia, also the small-scale Yugoslavia, and now they want all three peoples in Bosnia on Herzegovina to foot the bill, all these people that they had pushed into a civil war, in order to keep the true responsibility as far away from themselves as possible, and this was a war that they had caused. After all, why were they forcing ²⁵⁸ Bosnia to leave Yugoslavia if they didn't want a conflict? When they finally threw Bosnia out of Yugoslavia and when all three parties accepted the Cutilheiro plan for the organisation of Bosnia, why did they say to Izetbegovic that he should withdraw his signature? The US ambassador, Warren Zimmerman, who said that to him and could not deny it, wrote in his book that perhaps he had made a mistake when he said to Mr. Izetbegovic that he should do that. And that's how the war began. The war began by the killing of the father of a bride at a Serb wedding party that was moving through the centre of Sarajevo. The war started with the first killings of Serbs in various locations in Bosnia. The Serbs did not start a war. They did not start any conflict. That's the way it was in Croatia. The massacre in Borovo Selo, the massacre in Plitvice.

There are true historic facts that speak of all of this, and it is nonsensical to accuse the wrong side.

Now people speak of three peoples, three nations in Bosnia-Herzegovina, and this is a formula upon which Bosnia rests. And why did you accept a referendum in Bosnia without the Serbs if there are three peoples there, if before and now, the basic principle has been that something can happen only if all three peoples agree? Only when the succession of Bosnia was supposed to take place was it possible to do this without the participation of one people, and that is to say a people who owned more than a third of the territory, of the land of the country and also that comprised more than a third of the population of that country. Scholars will be coming here, academicians, if they dare come. Of ²⁵⁹ course, I'm not saying this against them because we have just heard that they have been accused here as well as ideologues of some Serb crime. And yesterday the Prosecutor even suggested that ethnic cleansing in Bosnia was rewarded and that the territory of Republika Srpska was grabbed. I wonder what your objective here is, and why are you saying or how do you dare say that Kosovo borders with Serbia? Kosovo does not border with Serbia. Kosovo is Serbia. The Hague does not border with the Netherlands.

Many things would have to be understood. If you don't understand them, then you should ask people who know, have someone explain this to you, that in any army, in any army that I know of, there is a principle of single command and that a single link is not missed in the chain of command when decisions are carried through. There is no anarchy. And if there is any deviation from this chain of command, this always results in a criminal act, and that is subject to appropriate sanctions. These stories of yours, who contacted which unit, whatever, all of that is nonsensical. If there was this kind of organisation, this would be the greatest possible chaos that anybody would be establishing. And who would organise and establish chaos in his own country?

JUDGE MAY: Mr. Milosevic, it is time for the interpreters to have a break.

THE ACCUSED: Okay. I would be glad to have a cup of coffee for your break.

JUDGE MAY: We will adjourn for 20 minutes.

THE ACCUSED: Half an hour. ²⁶⁰

JUDGE MAY: Twenty minutes.

--- Recess taken at 10.30 a.m.

--- On resuming at 10.50 a.m.

JUDGE MAY: Mr. Milosevic, we'll take the next break at 12.15.

THE ACCUSED: [Interpretation] In the break, I was informed that there was a portion of the tape, a small portion of the tape, that was not shown, so I should like to ask that the tape be shown in full and then I will continue with what I have to say.

JUDGE MAY: Yes.

[Videotape played] "When Serb forces pulled out in the afternoon, they announced they'd killed 15 KLA men in the action. The international monitors entered the village and reported nothing unusual. Only next morning did the full force of Serb retaliation become apparent. William Walker went to see for himself.

'We progressed up the hill and every 15, 20 yards there was another body. We kept going up the hill, and I don't know how many bodies we passed before we got to a pile of bodies.'

"By the time Walker arrived, the KLA had retaken control of Racak. "I think it's going to take me a few minutes to determine what I really should say and I'd like to hold a press conference in Pristina later this afternoon.

"The facts as verified by KVM include evidence of arbitrary detentions, extra judicial killings and the mutilation of unarmed civilians of Albanian ethnic origin in the village of Racak by the MUP and ²⁶¹ VJ.

"In other words, he claimed the Serbian police and the Yugoslav army. Walker was supposed to be an independent international official, but did he seek direct instruction now from the Americans? "Without calling on any of my capitals, I told what I thought I'd seen, which was the end result of a massacre.

"William Walker, the head of the Kosovo Verification Mission called me on a cell phone from Racak.

"But you don't remember calling Washington at all. "I got a call from Bill Walker. He said, 'There's a massacre. I'm staying here. I can see the bodies.' "And you didn't speak to General Clark or anybody like that?" "Walker's comments gave America the green light to enter the Kosovo war. The KLA had pulled in its mighty ally. "With Racak and lots of others, Serbs were playing in the KLA hands. It will remain, I would say, an eternal dilemma whether the KLA initiated these battles in the civilian inhabited areas because it knew that the Serbs will retaliate on them. Personally, I don't think so, but of course it was a war.

"Clark: Clearing after Racak extraordinary measures had to be taken.

"It clearly is a galvanising event, and the President really felt that we could move forward, make clear that the US was going to be a part of an implementing force.

"But Albright knew the galvanising effect of Racak would not last ^{262 BLANK PAGE 263} long. She had to get her European allies on board."

THE ACCUSED: Has it finished? [Interpretation] Have they finished the tape? Is that the end of the tape?

Let me continue where I left off in commenting the fabricated facts that we heard.

You mentioned a scorched earth plan. I don't know where you got that from, probably from Vietnam. The scorched earth plan is the same thing as the Horseshoe plan, and everybody knows that that was a pure fabrication. And even when it was presented allegedly in the original, in the original it was called "Podkova," which is in fact a Croatian word. The Serbs would never have written the word "Podkova." They would have used the word "Podkovica," meaning horseshoe.

And I don't know what this explanation in the indictment means, that the Serbs had arms in Kosovo. Everybody knows that everybody had arms in Kosovo. Everybody was armed, and there are countless documented examples of the fact that the Albanian terrorists stormed the houses of their own compatriots, the Albanians, in order to seize weapons from them, countless documented examples of this.

And when I listen to everything uttered here, anybody with any reason must ask themselves How can criminal responsibility, criminal accountability, let alone any political, moral, or any other kind of responsibility and accountability, and nobody could even put forward that kind of responsibility. But you were talking about criminal responsibility for the forcible secession of Croatia and to ascribe that to me. ²⁶⁴ It is not contested that Croatia affected a secession, neither was it contested that that succession was by force. And how should that have and could that have been stopped by me as President of Serbia, to stop the conflicts which the Croatian paramilitary had with the Yugoslav People's Army, which it was expelling out of the citizen bases in which that army had been stationed for a full 50 years? And they did not get to those bases, of course, from Serbia, because it was the SFRY. The Yugoslav army was deployed throughout the territory of the SFRY. And here we see in fact that you have absolutely no notion, neither do you know anything about the republican ministries of defence. They did not have any competencies and authority. Their main job was to keep lists of military recruits and conscripts, recruits for the army and to see to the civilian part and the administrative section, of course, all with a view to the country's defence.

You quote the political opinions of generals, General Simovic, and none of his competencies and activities. Everybody has the right to express political opinions and speak about anything he deems necessary. What do we mean by internal displacement of persons in Kosovo, and what could be a motive for internal displacement in Kosovo, and what is the explanation when conflicts occur in one area when terrorist bands and groups storm villages, killing inhabitants? And you will see later on just how many Albanians were killed before the war began, two and a half times more than the Serbs that were killed. But more about that later on. So of course the inhabitants of that village will flee to a neighbouring village to stay with their friends or to the town. Or if ²⁶⁵ they had no relatives there, to a collection centre organised by the authorities. So internal displacement of the population. I don't understand it. What could be the purpose of internally displacing the population, other than a malicious interpretation of the fact that people were running away? They were fleeing from an area they did not feel safe in and where they thought their children would not be safe, and they moved to other places. Can maybe claim that somebody used force to displace persons internally or to expel people from the territory of their own country? That would be the greatest crime imaginable, and who would do such a thing?

Furthermore, I wonder what sense there is in proving the alleged ill-intentions towards the Albanians by concentrating troops in the south of the country during the NATO aggression, and particularly in Kosovo, when it is clear to every child that that territory, the territory in question, was the forefront of our defence from an expected ground invasion by NATO troops from the direction of Albanian Macedonia. So where in the opinion of the Prosecution should we have deployed our forces if enemy forces were concentrated in Albania and Macedonia? Should we have deployed them perhaps on the Hungarian border or should we have deployed them at the Albanian-Macedonia border?

And let me also note that for 24 hours, 24 hours round the clock, during the B-52 bombers bombing the positions along the borders with an offensive and the Albanians were in the forefront to storm the territory, and they were never successful in this, thanks to the firm defence set up at our borders. ²⁶⁶ So what sense is there to explain the ill-intentions towards Albanians or to say that that was so if you position your forces to stand up in defence of an attack, and not an imaginary attack but a very concrete attack, an ongoing one that actually took place, and that is something that the whole world knows.

I should like to say that it is nonsensical and malicious to show us to be in favour of a military solution. What we were doing was to try to effect a political agreement, and the contents of that political agreement offered by the Government of Serbia and our leadership was made public. It was publicised.

The sole point of dissension, where we did not agree in the American delegation, was that -- and the Americans were our partners in the negotiations. So apart from some separate meetings that I had with Rugova, and they were again contacts of this kind, because they wanted to control the whole issue. So the only point that there was disagreement on was that we asked that the political solution be founded parallelly on the equality of citizens and the equality of national communities. Because in Kosovo, as was partially mentioned in what we heard here, we have Albanians, Serbs, Turks, Muslims, living together, as well as the Goranis, the Romanies and Egyptians, seven national or ethnic communities. And in order to realise a solution of this kind, we had a very normal and concrete approach that it should be implemented in such a way that the house -- that the Assembly of Kosovo should have two Chambers, the Chamber of the citizens and one man/one vote was applied here, where the vast majority would be in fact Albanians and nobody had anything ²⁶⁷ against that because they were the majority population in the province. And a second house or Chamber, the Chamber of national communities or ethnic communities, in which each of the ethnic communities, Serbs and Montenegrins - who were taken to be one ethnic community and not two ethnic communities - as well as the Albanians and Turks, and Muslims, and Romanies, and Goranis, and Egyptians would have a parity relationship and would have their own members elected.

Look at the United States, for example, Rhode Island. Rhode Island is smaller than Belgrade. It has two senators, just like Texas, which is bigger than half of Europe. It is logical that in a complex structure that is how matters are resolved. That was the only contested point or stumbling-block. And it was not to be accepted because the plan was not to accept anything, to find a pretext for an invasion on Yugoslavia, whereas we see that -- that it is only the Albanians creating an ethnically pure Kosovo and greater Albania, and I'll be saying some more about that later on.

So that is what I would call the neo-Nazi idea according to which Yugoslavia was broken up and in which the map of the Balkans was replotted, and a greater Albania is behind it all. And what we have heard here from the Prosecution, it is in that context that I wish to state that the Prosecutor -- it was not by chance that the Prosecutor mentioned Nuremberg. He did not mention Nuremberg symbolically. They are not satisfied with the crime committed over Yugoslavia and the settling of accounts with Serbia because of their defeat in both world wars. They want to proclaim us the culprits, who were the victims of their ²⁶⁸ aggression, and me, with the help of this Tribunal, to bring me before Nuremberg to reverse the roles.

That crime, which was the crime of the killing of Yugoslavia, and crucifying me here, they are doing that with the help of their -- today's allies and one-time enemies. All the facts bear this out and all the moves actually implemented bear that out.

World public opinion will not be able to turn a blind eye to that, despite the efforts being made by the Prosecution and the great efforts made by the media. But the Yugoslav public, and not only the Yugoslav public, are well aware of the real truth.

Now, the question arises when you hear what has been said here over the past two days, what you're trying to prove with the different photographs that you're showing, the supreme councils. I was a member and the meetings convened by the president of the supreme council. You could have shown my photograph with Mr. Rugova, for example, or perhaps with Christopher or Kofi Annan, or any one of those people. So I don't understand what you're trying to prove, what it means. What are you trying to prove with the photographs showing police putting order into rallies and demonstrations and many, many times less brutally than we see on your own television programmes and how you restore law and order in your own countries when there are demonstrations and rallies and riots, and when the public law and order are being threatened and the lives of citizens as well? What do you think you are proving when you show photographs of funerals, where you see somebody standing there and you can recognise him standing behind me, with a thousand people ²⁶⁹ attending the funeral? What is it you are trying to prove by showing photographs of that kind, the photographs you're presenting to the Trial Chamber here?

What are you trying to prove with your assertions that I did not hand over some people that you thought were the perpetrators of crimes? It is no secret. I would never hand over anybody to you because I consider that it is an illegal tribunal, and I have already stated that. I said that to Albright when she asked me to hand over some people, and I don't want to mention names here, to name names. But go ahead, tell our own organs and institutions that your organs and institutions supply our own ones with the truth and at the law courts in Yugoslavia will not -- will comply if you have proof.

In Yugoslavia, already in 1992, we tried for war crimes our own citizens for whom it was established that they had killed some Muslims in Bosnia, storming a group and killing some people. That was in 1992. Nobody knew that this Tribunal would be set up at the time. Nor is that important at all. Every civilised country in its criminal code has war crimes as the most grievous crimes, and we tried people for war crimes back in 1992. And I said at the time, "Go ahead. Let's see the proof. Let's see your documents. And don't worry, if somebody really did something dirty, did some dirty work, killing women and children somewhere, abused prisoners or anything else of that nature, shot at people, shot at a Red Cross vehicle, and I will show you pictures of NATO bombing Red Cross vehicles on a bridge and it says the Romanian Red Cross -- it has the Romanian Red Cross emblem on the roof, that people doing ²⁷⁰ that will be arrested and brought to trial.

So I don't understand what you mean when you say I didn't hand over. I would never hand anybody over. And even the handing over that is going on now is a violation of the constitution and a crime in itself. But they are doing this because it is a puppet regime that is in place today, a puppet regime which has to listen to orders, but not supported by the people.

I am wondering what you are trying to prove with the existence of volunteers. You mentioned the existence of volunteers, Serb volunteers that went across the Drina River as volunteers. Of course their conduct -- the authorities on whose territory they have gone to fight as volunteers are responsible for them, but what do you intend to prove with the existence of Serb volunteers who went to help their own brethren, their Serb brethren? And you have no regard at all, you're not interested at all in how many Mujahedin came to Bosnia or to Kosovo, who had sabres with them that were used to cut off heads. And later on, at the request -- at well known request, they were released. Furthermore, when the person came from Saudi Arabia with his sabre to cut off heads, he travelled 2.000 kilometres to come to Bosnia and to help Alija Izetbegovic. But if Serbs go to help their fellow Serbs, assist their fellow Serbs, then that is something that the Prosecution deems necessary to take into serious consideration. What are you trying to prove by quoting a sentence from a speech of mine held at Gazimestan which was, let me tell you, a very good speech. I can say that it was an excellent speech, in fact, and I don't think that ²⁷¹ you could find any criticism of that speech.

You quoted the latter part of a sentence, a small part of a sentence in which I state that we will have to fight many battles, which of course are not armed, although such battles are not excluded. That is an ordinary type of sentence that everybody uses today because peace has still not become a stable, secure category in the present day world, in the modern day world. And if that were not so, why do states have armies? But then you are very skilful in skipping -- and sly, in skipping over everything else.

I have received a fax. I received the speech by fax, so I shall try and find your quotation to demonstrate how you pulled it out of context. You pulled your quotations out of context. In that speech, I say, "Equitable relations amongst Yugoslav peoples are a necessary prerequisite for the preservation of Yugoslavia for it to emerge from the crisis and particularly necessary for its economic and social prosperity. In that way, Yugoslavia is not extracted from the social ambience of the modern and particularly the developed world. The world is prone to national conciliation, national cooperation, and national equality. Modern technology and the political and cultural development indicates that people should cooperate and depend on each other and that they must be more and more equal amongst themselves. A civilisation in which the world is moving --

JUDGE MAY: Mr. Milosevic, if you're reading, can you slow down for the interpreters.

THE ACCUSED: Okay. I understand that interpreter cannot follow ²⁷² fast reading.

[Interpretation] "In the kind of civilisation to which mankind is moving, it is only equitable united people that can step forward. If we cannot lead the world into civilisation of this kind, then we must certainly not be at its back end. So nowhere on the soil of our homeland do the words speaking about solidarity and harmony and cooperation among people have so much meaning as they do have here at Kosovo Polje and the field of Kosovo, which is the symbol of treachery and disaccord -- discord.

"In the memory, collective memory of the Serb people, that discord was decisive for losing the battle and for the ill-fate that the Serbs have had to contend for a full five centuries. And from the historical -- if that were not so from the historical viewpoint, we know that the people experienced this as their greatest misfortune, and it is the responsibility of the people to do away with this in order to protect itself from defeat, from stagnation, and from failure. "The people of Serbia this year have become fully conscious of the need for harmony amongst themselves as a necessary prerequisite for their life today and future development. I am convinced that this consciousness about unity and harmony will enable Serbia not only to function as a state but also to function as a successful state. That is why I think that this must be said here at Kosovo, where discord jeopardised the Serbs long ago and where revived harmony can promote it and give it back its dignity.

"This kind of consciousness, the consciousness of mutual ²⁷³ relations and how they are governed, represents an elementary necessity for Yugoslavia because its fate is to be found in the allied hands of all its people.

Six centuries later today, once again we are fighting battles and we are facing battles."

And this is where I come to your quotation. "They are not armed battles, though even ones of that kind have not been excluded."

So that is one sentence. And I go on to say -- but you did not quote that.

"Regardless of the type of battles they are, they cannot be won without courage, self-sacrifice and the kind of characteristics that were present a long time ago at Kosovo Polje.

"Our main battle today relates to the realisation of economic, political, cultural, and general social prosperity for the faster and more successful joining of a civilisation in which people will live in the twenty-first century. And it is for that battle that we need courage and bravery, a different kind of courage and bravery, but the kind that comes from the heart, without which nothing great can be achieved in the world. That remains the same and that remains eternally necessary." I don't want to go on to quote the entire speech. I have just given you portions of it, excerpts from it, to show you how malicious the extra that was quoted is, because I say that our major battle is the major -- is the battle for economic, social, and cultural prosperity. And you were able to see how they abused the quotation. ²⁷⁴ I'm also going to quote just a few more things.

"In Serbia, Serbs were not the only people who lived in Serbia." That is what I said before 2 million people. "Today more than ever before we have people of other ethnic groups, ethnicities, living there. And that is not a handicap for Serbia. Serbia is not handicapped by that fact. I am profoundly convinced that it is its advantage. And in that sense, the national composition of practically everybody is being changed, especially the developed countries of the modern world. Evermore and evermore successfully, different ethnic groups are living together, people of different religions and different races. Socialism, as a progressive and just democratic society should not allow itself that people be divided on an ethnic and religious basis. The only differences that can be allowed in socialism, and should be allowed in socialism, are between the honest and the dishonest. That is why everybody living in Serbia, on the basis of their own work, as honest citizens, showing a respect for other people and other ethnic groups and nations in their own republic. Yugoslavia is a multinational community, and it can survive only if there is full and complete equality of all the nations and nationalities living within it.

"The crisis that has hit Yugoslavia has led to national but also to social, cultural, religious, and many other less important divisions. And amongst all these divisions, the most dramatic were ethnic divisions. And if we do away with ethnic divisions, we shall be able to do away with the other divisions and mitigate the results that those division -- of those divisions." And so on and so forth. ²⁷⁵ So at Kosovo, the greatest holiday of the Serbs, the St. Vidovdan holiday, and the event that is described as the eruption of Serb nationalistic feelings, this is what was authentic. This is what was said. If you don't believe that, you can take the newspapers of the 29th of June, 1989, and you can read all about it. You'll be able to read that exact same speech in those newspapers. And I wouldn't change a single word in that speech even now, even today. I considered at that time that I, as the president of Serbia, should tell the Serbs that where they are the majority, the national key and national equality is the only key. And now you can see the degree of maliciousness that this excerpt, this excerpted quotation was taken, if you look at the whole. I don't want to take up my time by reading the speech in full, and I wouldn't have done so had they not interpreted it in such a malicious and ill-intentioned way. But let me continue. Let me continue with the issues that I wish to address before the public and not my responses to the Prosecution, because the degree of maliciousness has been demonstrated to such an extent that it can leave nobody blind to the facts. What do you prove when you say the Socialist Party appointed Ministers? I know of no country in which a party with wins the elections, wins the free multi-party elections and gains a parliamentary majority, is not able to appoint its Ministers. I don't know in your countries. I know that in your countries parties appoint their own Ministers. Although I can say that that was not the case in Yugoslavia, because sometimes we appointed persons that were outside parties as Ministers, and we had the idea of national unity where many parties took part in the government, ²⁷⁶ even non-party personalities.

What do you prove by that, that their material status depended on it? I don't know. In the countries that the people working at this Tribunal come from, do Ministers have other kinds of revenue? Do they not receive salaries? In our country, Ministers receive salaries. However, those who abuse their office by taking money have always been held responsible. Of course, if they are caught. We are the only country in the world over the past ten years that arrested two of its Ministers because of embezzlement of 700.000 Deutschemark, if I'm not mistaken. Of course, not only were they replaced but they were also charged before a criminal court and were sentenced.

So what does this statement mean, that Minister's salaries depend on their ministerial post and that when a party comes to power, that it appoints Ministers? What does that mean? Also, what does it mean when you use the wrong name for the Socialist Party of Serbia by calling it the Serbian Socialist Party, as opposed to many parties that are called Serbian? We were never a Serb party. We were simply called the Socialist Party of Serbia. And, of course, the majority of the party members are Serbs, but there is not a single ethnic group in Yugoslavia that does not have its members in the Socialist Party of Serbia: Hungarians, Albanians, Romany, Gorani, Egyptians, Muslims. Do you really think that all of these ethnic communities that live in Serbia would join a party that was carrying out some kind of discrimination? After all, it is senseless trying to prove this any further because, after all, there is a reality that speaks of this. ²⁷⁷ Over the past 12 years, the ethnic structure of Serbia and its population was not changed, and that fully refutes everything that has been said here.

There was complete nonsense uttered here, saying that a superior Assembly had disbanded the Assembly of Kosovo. According to the Constitution, when this assembly violated the Constitution, the other assembly dissolved it. Why would that be a criminal act? Why do you say that all the directors of the media were members of the Socialist Party? The director of the Politika daily newspaper was not a member of any party. And there were other editors in chief and directors of newspapers who were not. They can write letters to you. They can report to you, these people who were directors of the media and who were freely operating in Yugoslavia, opposition newspapers, pro-government newspapers, et cetera. After all, the very fact that there is such a large number of opposition media in a country speaks of its democracy, and they were all operating.

What are you trying to prove by saying that we had a Ministry for Communications with Serbs outside Serbia? There are over 2 million Serbs living from Australia to Latin America, to the US, Canada. All the countries of Europe, including this country, the Netherlands. These contacts are nurtured. After all, such Ministries exist in many countries. That is with contacts with the diaspora. Every year we have an Assembly of the diaspora. There are people coming from New Zealand Australia, India, America, North America, and South America, et cetera. So what are you trying to prove by this, by saying that we had a Ministry ²⁷⁸ for contacts with Serbs outside Serbia?

How can you be so impudent and quote an alleged statement of mine that Yugoslavia is finished when everybody knows that I advocated whole-heartedly that Yugoslavia should be continued and that as a basis for this continuity we established a Federal Republic of Yugoslavia when the former Yugoslavia fell apart? Do you think that in Serbia there were not voices, strong voices at that, that Serbia should secede from Yugoslavia? Especially according to those who were strongly anti-communist. Yugoslavia had been a dungeon of nations and it had to be broken up. I told them then, too, that Yugoslavia was in the interest of all the Southern Slavs, that they should all live together on a footing of equality. It is also interests in the interests of the Serb people whose interests you claim to be advocating. And you don't know what you are advocating because Yugoslavia is the only option under which Serbs can live in a single state because they live in all the republics. You abused that as well. The press abused that. That this was a programme of a Greater Serbia and that that is why this was carried out. But what I added then is that in this way, all the Croats live in one state, all the Muslims live in one state, all the Macedonians live in one state. Do you know that in Serbia there are more Muslims than in Bosnia? And that the greatest misfortune was for Yugoslavs to have Yugoslavia broken up. And this was in their interest least of all. Wasn't it in their interest to live in a single state, even though in two republics? So what?

I really don't know where this fabrication came from stating that ²⁷⁹ in Karadjordjevo I talked to Tudjman about the dismemberment of Bosnia. I did meet with Tudjman in Karadjordjevo and not only in Karadjordjevo. He first came to see me in Karadjordjevo. That is near the border. After 10 or 15 days, I also went to visit him also nearby. We met at a facility that was similar to Karadjordjevo. We also talked. We informed the public that we met and talked. We thought that relations should be promoted.

I'm not trying to say that there weren't some ideas but they were never my ideas and I never accepted them, to the effect that Bosnia should be divided, because I thought that not a single solution could be found that would be to the detriment of any one of the peoples in Bosnia-Herzegovina. That position of mine is well known. It was well known before Dayton, at the Dayton conference, and since. That is a formula that I had advocated publicly for years. And if you really wanted to be impartial, you would find that in any newspaper. The problem in Bosnia can be resolved only by way of a formula that would equally protect the interests of all three peoples. That was the key that I was advocating, and that is the key upon which the future of Bosnia-Herzegovina can be built if the interests of all three peoples living there are respected. There is no other way. Any other solution would be a fiasco.

How can you possibly speak of a so-called policy of ethnic cleansing which was allegedly launched from Belgrade when everybody in Serbia knows that this expression was used exclusively for crimes. In Serbia, there is not a single person who does not know that the expression ^{280 BLANK PAGE 281} "ethnic cleansing" was used for crime only, not to go back to the reality of Serbia and Yugoslavia now.

I don't know what you wanted to prove by that when you said that when visiting Sarajevo, I also visited the headquarters of the Serb Democratic Party. So what? I visited it. So what? At this meeting in Sarajevo, where the representatives of all the Yugoslav republics were, that was hosted by Alija Izetbegovic, all the presidents were there, Izetbegovic, Tudjman, Gligorov, Kucan. All of them were there.

On behalf of Serbia, I accepted the Izetbegovic Gligorov plan, which did bear in mind some kind of state, though a looser one, just in order to avoid any further tensions. I asked Izetbegovic about it then. I'm sure that there are tapes on which this was recorded. "Tell me, Mr. Izetbegovic, on the basis of everything you've said, will this be a state nevertheless?" He said, "Yes, it will be a state." And then I said to him, "You do not need to explain any more of this to me. We accept this plan." And we did.

And then his protocol people, et cetera, took me there because I was invited to visit them and I wanted therefore to visit them. And I met the entire political leadership there, prominent Serbs from Bosnia-Herzegovina, members of the Academy of Sciences and Arts, and I talked to all of them. What are you trying to prove by this, that I visited it them? Even if I had visited them a hundred times, what can you prove by that, some kind of criminal enterprise? You said here yesterday that my picture was there throughout. And ²⁸² I say that it is the image of neo-Naziism and the crimes that were created in -- that were committed in Bosnia and Croatia and also the spectre of breaking up Yugoslavia because of this neo-Colonialism. That is what loomed over, not my picture. And this is how a country was broken up, a country that by its freedom, security, safety, and its advocacy of justice throughout the world. This was an exemplary country, and it was broken up.

What are you trying to prove in connection with Serbia, in connection with Serbia when you talk about the shelling of Sarajevo? If you were to employ this enormous staff that you are spending so much money on, if you would find this in the newspapers, and if you would see how many times Serbia in its official government statements while I was the President of Serbia condemned the shelling of Sarajevo. At the time when Dobrica Cosic, President of the Federal Republic of Yugoslavia from 1992 -- he can testify. He is a famous Serb writer, a member of the academy inter alia. The entire leadership -- I can't even remember who was there. But everybody was there, all the Serb leaders from Bosnia-Herzegovina. We were sitting and together. We all met in Dobonace [phoen]. And they promised me and him that they would not shell any built-up areas. When I heard that there were some camps, I asked for an explanation. Is it possible that Serbs were setting up camps? And the explanation I received was the following: There are no camps. There are only prisons for prisoners of war, which spend short periods of time there and then they are exchanged on the principle all for all. Those are the assurances that I got several times. And nowadays I see people who worked ²⁸³ in camps and who say that we were all deceived in this connection, perhaps even the people up there in the leadership of Republika Srpska, because I almost cannot believe that in such a way people can deceive other people. I don't understand what you're trying to prove by inventing some kind of charts in a non-existent organisation. You have said yourselves that it was not authentic but that you are trying to imagine that this is the way it was. Why would you write these charts, that there is a Constitution that states what the powers of the President of the republic are, the government, ministers, ministries, everyone. Why would somebody establish an organisation in order to undermine his own state? Because any deviation from the system -- I mean, after all, we adopted this Constitution. If we wanted to adopt a different Constitution, we would have adopted a different Constitution. So I don't see what you're trying to prove when you say that services cooperated. Well, the services of many countries cooperate. The services of all your countries cooperate. Half of the things that were fabricated here were created in cooperation with these services, and no court in the world would accept that. And then you're trying to prove something through that. They had a helicopter unit, you say. Well, of course they were transferring people who were ill, wounded, injured, to the military academy hospital in Belgrade. Well, you also transport your sick people by helicopters and so on and so forth. But I really don't want to take up my time with these comments regarding this expression of powerlessness.

Perhaps I should put it that way, because these things that we have been listening to for two days show that you basically have nothing, ²⁸⁴ and that is why you have to concoct things. You have to invent things that at first sight everybody from Yugoslavia would know that this is untrue. And when the rest of the world looks at it again, they will realise that that's not true either.

What we saw here on our monitors coming from western sources, I'm sure that there will be more and more honourable people in the West who will not bow their heads and trample upon their own honour in order to be engaged in a media campaign. That is why this show which is supposed to take place under the guise of a trial is actually a crime against a sovereign state, against the Serb people, against me. You wish to try me for deeds carried out in the capacity of head of state, in the defence of that state, and that people from terrorism and from the greatest military machinery that the world ever had, and it acted in conjunction with terrorism.

This is also a crime against the truth. What makes it particularly cynical is that it is a crime against justice as well. This is a competition between justice and injustice. The whole world knows that this is a political trial and that it has nothing to do with law whatsoever. Not only because this is an illegal court - you said that you had rejected that altogether - but for many other reasons too. Let me digress at this point, Mr. May. Yesterday you gave me an answer and then you interrupted me. You told me that you had made a ruling, that I did not appeal it, and that for you that was the end of the story. I cannot accept that explanation not only on moral grounds but legal grounds as well, because you know very well that habeas corpus ²⁸⁵ cannot be ruled upon without a hearing. That is guaranteed. That is guaranteed by the -- by Article 9 of the universal declaration on human rights, Article 9.1 of the international covenant on basic civil and political rights, Article 5 of the European Convention on the protection of human rights and freedoms, and also Article 7.6 of the American convention on the protection of human rights, because in this way, it is not only physical freedom that is violated but basic human rights as well. It is for me to emphasise this once again. You were duty-bound to schedule a hearing to hear the staff members of your Tribunal here, those who took part in committing this crime, who were engaged in a conspiracy with the warden of the prison in Belgrade, who committed a crime and that he is therefore undergoing criminal proceedings right now. You were supposed to hear from all the participants and only then could you rule on whether these documents for which you say is the law that is applied in this court, only then can you rule whether these rules were violated or not.

So this has nothing to do with justice or injustice, because this court is illegal and because it is financed through donations including source like, for example, Saudi Arabia that inter alia finance things like international terrorism, but also because this Court accepted a false indictment without evidence. And in this way, they inverted the basic principle that it is the Prosecutor who bears the burden of proof, not the victim. The victim does not have to prove his innocence. In this way, we go back to the times of the inquisition. So all the forces that carried out a crime against my country and my people are in this way no doubt ²⁸⁶ engaging in a war. And by introducing so-called protected witnesses, secret witnesses, the category of false witnesses is given the right to exist and obviously might becomes right rather than having the rule of law prevail. There is not a single element of a fair trial or of equality between the parties.

Look at this. There is an enormous apparatus on one side, a vast media structure on that same side. All kinds of services on this same side. Everything is at your disposal. What's on my side? I only have a public telephone booth in the prison. That's the only thing I have available in order to face here the most terrible kind of libel addressed against my country, my people, and me, everything that you mentioned here.

Also, this other Chamber that was presided over by Mr. Jorda. I said, "Let me go free. The entire world knows that I'm not going to run away from this battle which has to come up with the truth." This would bring shame not only upon me and my family but also my people and also the entire freedom-loving world that believes in freedom and justice. You know full well that I'm not going to escape. Let me go free so that as a free man, I can take an active stand in this regard." You want us to engage in a swimming competition, 100 metres, but you want to tie my hands and feet and let me swim that way. You consider that to be a fair trial. And you are doing all of this in order to make the victims of aggression into the perpetrators and in order to carry out the orders of your masters. And I can say to you with full certainty that through this crime, the crime they committed cannot be legalised, although ²⁸⁷ concealing one crime by another crime is something that most criminals invariably do. The crimes committed by NATO will never be legalised among my people.

A pro-NATO power in Serbia, with authorities in Serbia, can accept and take over the tasks and assignments that it was given to condemn Serbia and subjugate it. But it does not speak for the people. It is not for the voice of the people, and nor does it have the right to do so, to speak on the people's behalf.

The first and greatest crime was the aggression itself, which represents a crime against peace. And the crimes of genocide were perpetrated, crimes against humanity, and war crimes from the 24th of March, 1999, when NATO attacked Yugoslavia, up to the present day. In all countries, in all the NATO countries, the European Union, and others under the influence of NATO, a great anti-Serbian and anti-Yugoslav propaganda was effected in order to keep quiet the mass crimes against the civilian population.

Is this too fast for the interpreters?

THE INTERPRETER: The interpreters are following. Thank you.

THE ACCUSED: [Interpretation] I can hear an echo here, so I shall try and adapt my speed of speech to the capabilities of the interpreters.

JUDGE MAY: They are following, but bear them in mind.

THE ACCUSED: [Interpretation] That is why, in the majority of countries, true information was lacking about the crimes committed in Yugoslavia by virtue of their intensity and military power. Aggression against the Federal Republic of Yugoslavia was the greatest aggression in ²⁸⁸ the world after World War II. The alliance included 19 of the most highly developed countries, 676 times more powerful than Yugoslavia on the basis of facts and figures, statistics. But these figures are available to everyone. And countless times more powerful, militarily speaking, than Yugoslavia.

NATO did not choose its victims. Children suffered, women, elderly people. All of them suffered: Ailing people, pregnant women, serious patients having to undergo dialysis, refugee columns, journalists and cameramen doing their jobs, farmers in the fields, salesmen at marketplaces, passengers on trains, passersby on bridges. Whole housing blocks were destroyed. Whole centres in towns were destroyed. Everything was done in conformity with the statement made - and you all read it in the papers - that Serbia must be sent back to the Stone Age. Of the total number of civilians killed, 30 per cent were children. Of the total number of civilians seriously wounded and injured, 40 per cent were children. And I'm only talking about civilians now. The bombing jeopardised 120.000 pregnant women, as well as the lives of new-born babes, some of which were born during airstrikes. 1.300.000 pupils during the bombing were not able to go to school. The entire civilian population, especially children, were under the effects of bombing which went on round the clock, day and night, which caused trauma and other psychological disturbances and disorders that will be with them for the rest of their days. More than half the people that were victims in Kosovo were Albanian citizens, precisely those people for whose alleged protection the aggression was implemented, and the perpetrators named the ²⁸⁹ aggression humanitarian intervention. And you will soon be able to see what this looked like.

So a flagrant violation of Article 2 of the United Nations Charter without acquiescence from the United Nations. I don't think that that can be challenged. It was a grave violation of the United Nations Charter and that this was done without acquiescence from the Security Council. Among others, the conventions on war law dating from Geneva 1949 and the Additional Protocol II of this convention dating to 1977 were violated. Other rights dating back to 1996 were also violated, and other international conventions as well.

In addition to the international conventions, NATO violated the provisions of its own Statute, according to which it is a defensive, regional organisation which can go into action only on the territory of its Member States. With the aggression on Yugoslavia, it violated the Constitutions and laws of the majority of NATO member states, according to whose provisions it is forbidden to engage into these forms of armed aggression.

The government of the Federal Republic of Yugoslavia has filed a lawsuit with the international court of law with respect to the NATO aggression, demanding that the court acknowledge that NATO violated the provision on the use of force against other states and that in financing, equipping, and supplying terrorist organisations in Kosovo, they violated their pledge not to meddle into the internal affairs of other countries, that by attacking civilian targets and killing thousands of women, children and elderly persons, they violated what they took on with respect ²⁹⁰ to the civilian population.

You will also be able to see that it was the civilian targets that were NATO's main targets, and that can be seen by the victims themselves and the whole dynamics in which the operation was conducted. In Kosovo, in all the bombing campaigns, they only succeeded in destroying seven tanks, but on the other hand, they did succeed in destroying many more hospitals. They hit many more hospitals than they did tanks. They hit many more schools than they did tanks. They hit many more health centres and nurseries and kindergartens than they did tanks. And all the other possible obligations that they had taken on.

They used cassette [phoen] bombs and violated the use of prohibited weapons. And Shea is lying on television, and he takes the grand prix prize that year for lies. They said they did not use cassette [phoen] bombs and they kept maintaining that until Mary Robinson came to Nis and saw these bombs and said on television that they had indeed used those bombs and then they acknowledged the fact that they had used them, only after she said so on television.

That the oil refinery and chemical facilities were bombed, which led to great ecological catastrophe. The use of weapons containing depleted uranium was a violation of the use of weapons of this kind, weapons that have detrimental effects, far-reaching effects on the population and ecology, that companies were destroyed, health institutions, communication networks, all this violated the regulation regulating the right to life, the right to work, the right to information, the right to health protection, and other basic human rights. That the ²⁹¹ destruction of bridges on international waterways was a violation of the maritime laws, and that all that represented a crime which violates the obligations taken on with respect to the implementation of conduct aimed at the physical destruction of that particular group. For the crimes committed and the war -- war damages done, it is the alliance that is responsible and the Member States that took part in the aggression on Yugoslavia as well as all other states which indirectly assisted NATO. In addition to the States, there are physical persons also responsible and accountable: Those who issued orders, the heads of state and government, the ministers of defence, the Secretary-General of NATO himself, the military commanders and others, right up to the perpetrators themselves.

I should now like to ask, because I have been promised the opportunity of showing photographs, as I'm moving on to another area with concrete illustrations, I shall like to have the set of photographs shown, please, and I'll tell you what they're about. I'll explain them to you in just a moment.

On the 14th of April, 1999 --

JUDGE MAY: Get the photographs from Mr. Milosevic.

THE ACCUSED: [Interpretation] I should like to have this set of photographs placed on the ELMO, please, in order, one by one. And they all illustrate the event which took place on the 14th of April. From 1330 hours to 1530 hours in Djakovica, on the road between Djakovica and Prizren --

JUDGE MAY: Just a moment, Mr. Milosevic. Yes. ²⁹²

THE ACCUSED: [Interpretation] As I was saying, on the road from Djakovica to Prizren, by the village of Madanaj, on three occasions, a column of Albanian refugees was bombed, Albanian refugees, mostly women, children, and elderly persons, who were returning to their homes in vehicles, tractors, and other trucks and trailers. What has happened to the photograph, the image?

Would you take a look at these photographs, please? I can see them on my screen. May we go on to the next photograph, please?

JUDGE MAY: No, I'm not getting it. We have them now. Yes, we have them now on the screen.

THE ACCUSED: [Interpretation] Uh-huh. You can continue. These are all peasants, farmers, a mother and daughter, victims in the village of Madanaj.

Let's go on to the next one. They weren't going in buses of any kind. They were using tractors and trailers, and everybody could see that they were civilians and peasants in their carts. Next, please. Carbonised bodies. And bear in mind that the photographs are on both sides. Each piece of paper has a photograph on each side.

Let's go on. Next, please. Next. Next. A little girl. Next. An old woman. Next. Next. Do I need to go further? Let's have some more. Next. Next. Next. Carbonised people; burnt. Next. Next. Next. Next.

That then happened on the 14th of April, undoubtedly, as we're talking about the 1330 hours to 1530 hours, in broad daylight, broad ²⁹³ daylight. They were intentionally targeted. But let me tell you why they were targeted. They were targeted because they were going back to their village, contrary to the conceptions of the aggressor, who through the media launched lies saying that the Albanians were fleeing in the face of the Serb army and police. Everybody had to leave their villages and nobody should have dared to go back to them.

In addition to the bombs during the aggression, there were pamphlets thrown out of aeroplanes, appealing to the citizens to flee. And the terrorist KLA organisation worked along those lines, too. It even killed the heads of families who were disobedient and did not wish to obey the order to flee from their homes and villages. This is yet further proof of the collaboration between NATO forces and this terrorist organisation that was used in order to destabilise Yugoslavia. On the 25th of March, at 5.00, Rozaje was bombed. I won't be able to quote all the examples because that would require ten days, and I would become too tired after speaking for ten days. So I'm just going to give you a few illustrations and examples.

On the 26th of March, the village of Grlic, in the Danilovgrad municipality was bombed. On the 2nd of April, the village of Nogavac in the Orahovac municipality in Kosovo and Metohija where the large number of people killed and wounded and injured -- many seriously wounded and injured. Let me also -- I will also let you see Nogavac. Four photographs from Nogavac.

On the 22nd of April, 0145 hours, the Kursumlija region, the village of Smokovo, many people were killed and wounded there. So may we ²⁹⁴ now see those photographs, please.

On the 4th of April, another date, Cacak. On the 5th of April, Vranje was bombed. You can show this set of photographs together. You have photographs on both sides.

JUDGE MAY: We'll see the photographs, and then we'll adjourn.

THE ACCUSED: [Interpretation] Perhaps this will take up too much time. May I just give you one more -- or let's do the first lot first, and then I'll give you an additional one.

JUDGE MAY: Show the photographs one by one.

THE ACCUSED: [Interpretation] I assume that you can see the people killed better on your screens. They were mostly peasant women, villagers. Many people were buried.

This peasant woman practically burnt to death as a result of the bomb.

This is the photograph from Vranje that I mentioned. And generally they targeted housing blocks, from the very beginning. You see the dates, the 25th, the 26th, the 27th of March, the beginning of April. They targeted family houses, civilian facilities and targets. They were the priority targets of the evildoers who decided to undertake this action.

Once again, an old woman.

JUDGE MAY: We'll adjourn now for 20 minutes.

--- Recess taken at 12.17 p.m.

--- On resuming at 12.35 p.m.

JUDGE MAY: Yes. We'll go on now until quarter to 2.00, when ²⁹⁵ we'll adjourn for the day.

THE ACCUSED: [Interpretation] On the 5th of April, 1999, at 2145 hours, Aleksina was bombed. Aleksina is a small town in central Serbia. It is a mining town. Everybody in Serbia knows of the Aleksinac mines. These are coal mines. Being a miner is the most difficult job conceivable. This town has no military facilities whatsoever. It is of no strategic importance. Its destruction can be compared only with the bombing of towns by Nazis in the Second World War, that is to say, without any reason whatsoever, without any target whatsoever, except to kill as many civilians as possible, especially poor people. When Chirac was in Belgrade, I heard on television that he said that he had saved the Belgrade bridges. Truth to tell, he did not save all of them. The biggest one was bombed and destroyed because he had vetoed it. That shows that heads of state were deciding on the targets. When he comes here - and as you know, I have the right to ask for that and I have the right to question witnesses - I will have to ask him why he did not, for example, veto the destruction of a small mining town and the killing of so many citizens, civilians, women, children. What kind of a war target could that have been except for the crime itself, if it is possible for a crime to be its very own object?

I'm just going to ask for the pictures from Aleksinac to be shown so that you can see what the centre of town looks like and what the people killed in Aleksinac looked like. Practically the entire centre of town and beyond, of course.

A corpse can be seen on the previous photograph, half buried. ²⁹⁶ Destroyed houses, as you can see. These are family houses. It says here where the corpses were found, the corpses of people in these houses.

JUDGE MAY: Is that it? Yes.

THE ACCUSED: [Interpretation] On the 6th of April, Dubina was bombed, in the most underdeveloped part of Serbia, in Sijenica. This region of Sijenica is a region that is predominantly populated by Muslims. On the 6th of April, Podgorica was bombed?

On the 7th of April, Pristina was bombed. The building of the post office in Pristina was totally destroyed. People were killed, many people were killed. Many people remained under the rubble, both Serbs and Albanians and the Gorani, and the Turk, but mostly Albanians. Not to interrupt, I'm going to put forth a set of photographs with several localities on them, but I am going to ask the gentleman who is showing this to include the caption underneath the photograph so I can comment on it.

On the 8th of April, Cuprija was bombed, also a small town in the centre of Serbia, from 0040 hours until 0050 hours. As you can see, towns, especially small towns, were always bombed during the night when people were asleep in their homes. Then they were sure that these people would get killed. In towns like Aleksinac and Cuprija, there are no anti-aircraft shelters at all. Even there are some, they are so small that not even a single digit percentage of the population can find shelter there.

You will see the photographs of the destroyed pictures in ²⁹⁷ Cuprija. On the 9th of April, Mionica and an adjacent village was bombed. Mionica is one of the most underdeveloped municipalities, and you can imagine what a village in that municipality looks like. It is a livestock growing area.

Pricevici was also bombed in the municipality of Valjevo on the 9th of April. The hamlet of Boskovici, to be precise. Between the 10th and 11th of April, there were three waves, as a matter of fact, when the municipality of Kursumlija was bombed and particularly the village of Merdare was heavily destroyed. Devastating missiles were launched and also cassette [phoen] bombs. The list of killed persons will be presented to the public and to you, just like in the case of many other events that I am quoting. At 4.00 a.m., on the 11th of April, the village of Smaila in the municipality of Krajina was bombed. On the 11th of April, the village of Turekovac in the municipality of Leskovac.

Serb peasants are the most resilient peasants in the world. They endured all wars. Only Nazis could have conceived of this massive bombing of villages.

I have a report here. There are many of them. But it says, "I passed out, and I don't know what happened to me after that. I just know that now I'm in Belgrade and that I'm being treated at the military academy hospital." Nerez Colaku, an Albanian who was brought from the bombed Pristina to the most elite medical institution that Yugoslavia has. And here we have been hearing that we had organised the deportation of Albanians, that we even caused a war in order to kill Albanians. ^{298 BLANK PAGE 299} The 14th of April, the village of Pavlovac in the municipality of Vranje. You will see the corpses in front of farmhouses and village houses. Among them is the corpse of Milica Stojanovic, a 12-year-old girl.

On the 16th of April, Subotica was bombed. On the 17th of April, Batajnica was bombed. That is very close to Belgrade. You will see the corpse of the young Milica Rakic, a little girl born in 1996. On the 17th of April, the same day, Belgrade was targeted practically, the outskirts of Belgrade. This is a blue-collar neighbourhood, Rakovica. We are going to submit a separate list in this regard. You're going to see the list of houses in a few streets and also the corpses of people.

On the 20th of April, the village of Dolovi in the municipality of Novi Pazar, also an underdeveloped part of Serbia. On the 21st of April, the refugee settlement of Meja in Djakovica, where you will also see corpses. Refugees were there, refugees from Republika Srpska.

In connection with what we've seen here about the alleged resettlement of Serbs in Kosovo due to the fact that there were refugees from Republika Srpska in Kosovo, I can say that all facts refute these ill-intentioned assertions, very low insinuations. Yugoslavia took in 1 million refugees, least of all in Kosovo. If we were to judge by that, I would probably have been indicted for trying to change the demographic map of Belgrade because most of the refugees went to Belgrade and to big towns. Nobody forced the refugees to go ³⁰⁰ anywhere. Refugees went wherever they could. And 80 per cent or even more were staying with families who had taken them in. Sadako Ogata told me once that she did not see such good care for refugees anywhere as she saw in Yugoslavia.

There is another thing I can tell you. You can find this, if you really want to do that kind of thing, that during the war in Bosnia, over 50.000 refugees who were Muslims came to seek shelter in Yugoslavia. What do you think? Fifty thousand people coming in from a country in connection with which we hear claims here to the effect that we had committed aggression against them. And then 50.000 of them seek shelter with the aggressor. What can this mean? What do such assertions mean? But paper can take anything, that kind of thing included. You will see corpses. You will see destroyed buildings. You will see killed persons. I haven't even covered the first month yet. As a special misdeed, although this is too mild a word, I would like to mention the bombing of medical centres in Kraljevo, in the village of Milojica, the pharmacy in Ladjevci, at the medical centre in Ladjevci, that is. Then the Leskovac health centre, the general hospital, the medical centre in Pristina, the medical centre in Rakovica, that is the blue colour neighbourhood in Belgrade. Then the medical centre in Zemun, then also within in a farm in Zemun, then the Sima Milosevic medical centre in Belgrade, then the medical centre in Sremcica, which is also in Belgrade, on the outskirts of Belgrade. The medical centre in Sremcica, the pharmacy in Gnjilane, the medical centre in Leskovac, the general hospital, the general hospital in Djakovica, the medical centre in ³⁰¹ Djakovica, the Raska medical centre, the Lethovic [phoen] medical centre, the Hotovic [phoen] medical centre, the Vracka [phoen] medical centre. The medical centre of the industry in Nis, the medical centre in Cacak, in the village of Leskovac, the medical centre there; the medical centre in Cacak, the medical centre in Lucani, the clinic of the tobacco industry in Nis, then also of the Jasrebac industry. The institute for treating the thyroid gland and metabolism in Cigota, Cajetina. This is in the mountains. Then the southern Banat, Pancevo, the medical centre in Cuprija, Prokuplje, the medical centre in Cuprija, the medical centre attached to the factory called the 21st of May in Belgrade, the medical centre in Kursumlija, the institute for orthopaedic surgery in Banjica, the medical centre in Valjevo, the unit -- a ward of the general hospital in Valjevo, and so on and so forth.

In addition to that, schools were bombed. I'm going to present this list to the public for them to see. However, in order to save up time, I would not want to read it now because this is a list of educational institutions that were damaged or destroyed during the aggression carried out by NATO only during the first month. On every page there are about ten schools, and this list contains exactly 34 pages for the first month, and 34 pages is the list of damaged and destroyed schools, schools that were damaged and destroyed during the NATO aggression.

In Belgrade, it was mostly primary schools. In Trukarica [phoen], Rakovica, Zemun, Sanski Venac, all of these being Belgrade municipalities, including Zvezdana, Palilula, new Belgrade, Obrenovac, Sopot. And then in ³⁰² the town of Bor in the Jablanica district, in Leskovac, in Nis, and in the Niseva district. From primary schools to universities, vocational schools, technical schools, teaching colleges, student dormitories, student cafeterias, kitchens. But most were primary schools. That is to say, on 34 pages, schools.

Also, I'm not going to read the entire list of cultural monuments that were bombed. My associates are also going to present this to the public and to you. It contains 18 pages. It so happens that on the last page, the eighteenth page, is a picture of the damaged building in Kosovo. However, before I continue, I would like to ask for photographs to be shown of these bombings. Most often, these were villages, towns: Dubinje, Doreta [phoen] Podgorica, Pristina, Mioica, Pricevici, Vranje, et cetera. This is what I had just informed you about. These are buildings in the centre of Pristina. I did not look on time.

This is a -- this is the building of the medical insurance in Pristina. This is the department store of Grmija in Pristina, also bombed.

You saw at the outset the completely demolished post office building. All of these houses around the post office were destroyed, near the post office in Pristina. Family homes, apartment buildings, et cetera.

This is rubble where the five members of the Gashi family, an Albanian family, were found. They were taken out. This was on the 7th of April, 1999. ³⁰³ This is the corpse of Radovan Aleksic from the Zanatska Street. Please go on. Also corpses, also in Pristina. I can't see well. I can't see the captions very well.

These are destroyed houses in Cuprija. I already told you this is a small town in central Serbia. As you can see, it's family homes again. Please go on. Also in Cuprija. Also in Cuprija. These are houses of peasants that were bombed in the municipality of Valjevo. Please go on. These are destroyed houses in the village of Merdare in the municipality of Kursumlija, also belonging to peasants. Specifically in this house five persons were killed, including a one-year-old child. That's the house that you can see here on this photograph. Most of this is from the documents that were compiled then. Please go on. Go on. All of this is in the same village. This is the village of Turekovac in the municipality of Leskovac. Go on. These are parts of unexploded missiles.

Destroyed houses in the village of Pavlovac near Vranje, and the corpse of Mijalko Trikovic [phoen] who was killed by a cassette [phoen] bomb.

Go on. The house of this person who got killed. These are the effects of cassette [phoen] bombs that kill people and do not destroy buildings. That is why they have been prohibited. Go on. No comment is needed here, I hope. Go on. There's a little girl who had been killed in this photograph. You can see that. This 12-year-old Milica. A crater. Go on. This is Subotica on the 16th of April. Go on. ³⁰⁴ This is the house of Mihalj Retfali [phoen] in Subotica. Also a single-storey building, a family home. Go on.

This is the house where a little girl called Milica Rakic was killed.

Next, please. Next. This is a little girl. Also a destroyed house in this came complex. Go on. Go on. You can see for yourselves that all of these are single-storied houses. You can see the corpses here. Go on.

This is in the village of Dolovi by Novi Pazar, on the 20th of April. As you can see, this is a poor looking houses. This is an underdeveloped area. Go on. Go on.

This is the refugee settlement of Maja that I mentioned to you, on the 21st of May in Djakovica. Go on.

These are buildings housing refugees. Go on. These are corpses of refugees. As you can see, most of them are females. Go on. Go on.

I wish to draw your attention to the fact that there was a terrible bombing, a savage bombing of communication roads. On the 1st of April the Varadin bridge was built -- was bombed. It is the bridge in the town of Novi Sad, on the banks of the River Danube. So that the destruction of that bridge severed the water communication line, and the Danube was closed to navigation. This occurred at 0455. At 0505, another bridge on the Danube River, Beska, was bombed. It is the main road and the crossing of the motorway from Belgrade to Novi Sad. On the 3rd of April, the Sloboda bridge in Novi Sad was bombed. ³⁰⁵ On the 3rd of April, the 25th of May bridge was bombed, which links Backa Palanka in the SRY to Croatia. The bridge by the village of Jezgrovici, the bridge in Biljanovac. The Zeleznicki bridge, railway bridge, in Novi Sad. The bridge at Ibar near Brodanik. The bridge in Bogojelo. The bridge in the village of Lozno. The railway line running from Kraljevo to Lapovo. That was on the 6th of April at 3.30 a.m. In the morning between the 11th and 12th of April, the Pristina airport and the bus station in Pristina.

May we go through those photographs briefly, please, because they show a systematic destruction of all the vital communication lines vital to the lives of civilians and also that were prohibited and not to be targeted according to the Geneva Convention.

We can just go through the photographs. This is Varadin bridge. This all the town of Novi Sad. The bridges of Novi Sad were a particular target in order to paralyse life completely.

This is the Sloboda bridge in Novi Sad across the Danube, which was destroyed. Novi Sad-Kamenica.

Next, please. That is the 25th of May bridge on the Danube between Ilok and Backa Palanka, which was bombed on the 3rd of April. Next, please. Next. This is the bridge by the village of Jezgrovici.

Next, please. We can go through these pictures of bridges faster now. Let's see them one by one. The bridge at the village Biljanovac at Ibar.

Next. This is the railway bridge in Novi Sad. ³⁰⁶ Next please. This is on the Ibar at the village of Drvenik near Kraljevo, in Kraljevo municipality.

Next. This is the bridge at Sombor with the motorway passing across it.

Next, please. The bridge at the village of Lozno near Kraljevo. That's what it looks like. This is a destroyed house. Next, please. And near it was this. This is the bridge across the Danube at Bogojelo. The railway line at Bogutovac. Next, please. The railway line running from Kraljevo to Lapovo. And the same sorts of images we saw in World War II when we were taught it at school. When we went to school after the war, they would show us pictures like this.

Next, the airport in Pristina. The bus station in Pristina. Next, please. That was the bus station, a closer view of it, a close-up of it.

This crime is the kind that needs no comment. On the 12th of April at 11.40, we saw the destruction with missiles of the Sarajevo bridge along the Leskovac-Vranje road, 12 kilometres away from Leskovac. The railway bridge was hit near a place called Grdelica at which there was a train composition which was running from Belgrade to Ristovac. The train was destroyed. The passengers were carbonised. It was a passenger train on a regular line train line, an international train line which has its set schedule, timetable. And at 11.40, that is to say almost at noon -- and we'll supply you with a list of the victims, you and the public. And I would like to have those photographs shown now, please so that you ³⁰⁷ can get an idea of what it looked like.

With some of the photographs, you will not be able to see -- you won't be able to conceive of people being burnt in this way, but I would like to show the photographs now.

That is the bombed bridge with the train on it. These are the cars, the carriages that were destroyed. The carbonised corpses. Nine passengers on this photograph. That is another view of the passenger train. These are people that fell out of the train. As you can see, their corpses are semi-carbonised. This is a female corpse. You can see that this is a female corpse. Perhaps the only recognisable person in any of these photographs. This is the corpse of Petar Mladenovic, who was born in 1952. And this is an unidentified body of one of the victims. Next, please. Once again, we see the same thing. Next, please. All these people were travelling by train, and that's the only crime they had committed, travelling by train, or perhaps because they were citizens of Serbia.

Next. As you can see, it is unbelievable what a burnt body can look like.

On the 12th of April, the Efendi bridge by Ponosevac was bombed. On the 13th of April, the bridge in Biljanovac. On the 14th of April the railway bridge by the Limsko lake. Between the 14th and 15th, during the night, the bridge by Pepeljevac. On the 15th of April, the bridge across the river Morava near the village of Jaskika.

I'll skip over the descriptions because I wish to save time. So I won't describe what this looked like. ³⁰⁸ On the 15th of April, we have the bridge Smderevo Kovin, also across the Danube. And all the facilities in the environs of the bridge were destroyed too.

These -- this is another set of photographs. I don't want to show all the photographs of the bridges that were destroyed at this point in time because I have some more things to say to you today, and I don't have enough time.

On the 22nd of April, the post office in Uzice was bombed. Uzice is one of the largest towns in Serbia.

On the 23rd of April, the bridge -- the Sava bridge towards Surcin Ostruznica was bombed. Relay stations and repetition stations were bombed. I don't want to go into that, but the relay and repetition stations were bombed in many places.

On the 21th of April, the Usce commercial centre at Novi Belgrade, New Belgrade, was shelled, and there were a number of companies. It was also the headquarters of the Socialist Party of Serbia. Some 20 companies had their headquarters and offices there, and several television and radio stations were located in the building as well.

I have pictures of the destroyed TV channels here. The SOS, the Pink Television Station, the Kosova television station which my daughter headed. She was at the head of that one. And we heard from NATO press conferences that that particular television station of which my daughter was the head was destroyed as being the centre of Milosevic's propaganda. And the truth is, and the whole of Yugoslavia knows this to be true, it was a music television station. That particular television station never, ³⁰⁹ let me repeat, never broadcast a single informative programme or documentary programme, but all it -- it didn't broadcast the news. It played music, predominantly American music, and films. Those, too, were mostly American films. The only piece of information that could be heard from that television station was the weather forecast. And that was the conception of that television centre. And they said that that was the centre of Milosevic's propaganda apparatus and, therefore, it was targeted.

Two days later, after the Usce commercial centre was targeted, NATO targeted Radio Television Serbia and killed all the journalists, crewmen, and technicians who happened to be in the building and therefore perpetrated a crime not only by targeting journalists while they were on their job in their workplace but targeted Radio Television Serbia and all the people who were in the building at that time, and we will be providing the Tribunal with a list of victims.

What I want to say here and now is the following fact: The pro-NATO government in Belgrade arrested Dragoslav Milanovic, who was the director general of Radio Television Serbia because allegedly he didn't protect in an adequate way his employees and workers. So it was through his fault that these workers were casualties. I think that the whole public can see the same line of logic between the arrest of Milanovic and the logics used by the Prosecutor in this courtroom over the past two days.

NATO bombed Radio Television Serbia. It destroyed it. It killed the people and the regime in Belgrade arrested the director general ³¹⁰ because allegedly he was responsible. It was his fault that that happened.

May we now take a look at the photographs of television -- Radio Television Serbia, although you can only see legs and fingers and bodily parts. But let's have a look, because this was one of the grievous crimes that were committed. Here you are. Here are the photographs. We can go through them one by one. I won't be commenting on them because I have already commented. Photographs like this, you won't be able to see much, just the tips of people's fingers or parts of the bodies of the casualties.

This is in the centre of Belgrade. The building of Radio Television Serbia was located in the central part of Belgrade. And it is no second-rate building. It is the number one master television centre and building.

Here you can see a fist. You can see the fist and the remains of that body.

Next, please. Would you go through the photographs one by one. Next.

The bodily remains of the victims. A separate target were the commercial facilities and buildings in keeping with the demands and appeals for Serbia to be thrown back to the Stone Age. The factory of farm planes in Pancevo, the 23rd of March, the 24 of March, 1999, and then on the 27th of March, and again on the 29th of March.

The Mladost factory farm, and in Gnjilane Kosovo Metohija on the ³¹¹ 26th of March. Both of these the Sloboda Cacak factory on the 28th of March at 0443 hours, and on the 30th of March again, 0410 hours. The washing machine factory and cooker factory, the Sloboda factory of Cacak, was famous for household utensils and electrical appliances. The furnaces were also produced there.

On the 4th of April, the 6th of April. The Sloboda factory is the largest industrial factory in Cacak and many, many families in households lived from people working in the factory. And the heating plant of Novi Belgrade which supplies heating to the whole of new Belgrade, or Novi Belgrade.

On the 5th of Belgrade, the tobacco industry of Nis, the chemical industry of Miloje Blagojevic in Lucani on the 5th of April. On the 9th of April, at 0120 hours the Srveno Zastava [phoen] factory in Kragujevac was targeted, and over 30.000 employees worked in the factory. That is the automobile factory. It produces passenger vehicles and other manufactures. 30.000 families were left without a livelihood because they lived from working in the factory.

Sixty-four more facilities were destroyed in the environs of the factory, and I won't be reading them out now. Actually, it's not one factory. It's a complex of factories, a factory compound, many together.

On the 12th of April, a plantation in Orahovac. On the 12th of April, the village of Rznic in the Decani municipality. On the 13th of April, a series of commercial enterprises in Pristina. ³¹² On the 14th of April, the complex of factories called Krusik in Valjevo. It was the largest factory in Valjevo, the largest enterprise. Once again, many people lived by working in the factory. And they destroyed the textile factories, the factories producing textile machinery and many other facilities, batteries and so on. It was a very prosperous company and factory.

On the 15th of April, from 5.00 to 5.15 a.m., the 14th of October factory in Krusevac was destroyed. On the 15th of April at 0130 hours, Belgrade saw the bombing of in Rakovica municipality, a blue collar neighbourhood which I mentioned a moment ago, which is where a major part of the industry of Belgrade is located, generally the metal industry. The Jugostroj enterprise producing cooling devices, the Belgrade baking industry which means bread baking and production. The tyre and motor industry of Rakovica and tractor factory. The 21st of May motor factory. The Minel enterprise producing sophisticated energy devices. The monastery of Rakovica was another casualty, as well as the PTT building.

Schools, primary schools, nurseries and kindergartens for the children of workers, blue collar workers. The Zvorcici and the Hajdi kindergartens, the Dimitrije Koturovic nursery, the 21st of May Hotel, and the medical centre of Rakovica. Facilities in Kragujevac on the 15th of April were destroyed and targeted. The centre of Kragujevac. The urban centre near the railway station and bus station was targeted where many people were located at the time. Facilities in Nis. On the 15th of April, a large number of civilian building and facilities were targeted. ³¹³ On the 17th of April, we see the targeting of the Prva Iskra enterprise in Baric. And so on and so forth, when we're talking about commercial enterprises, factories and the like.

Perhaps we could show a set of photographs and go through them one by one quickly, please, because they show the terrible destruction that took place.

In the Utva factory we see the aeroplanes for agricultural purposes that were manufactured completely destroyed. And the Crvena Zastava [phoen] that employed 30.000 employees, but you can't see anything of that because they were razed to the ground. There were no remains. It was completely destroyed. And it was an enterprise that was completely liquidated and eliminated in that way.

While you're preparing those photographs and going through them one by one, please continue, let me tell you that several months later, we were able to put production on the ground again, on its feet again, as we did all communication lines, all the bridges, and by the end of that first year, all those who had lost a roof over their heads were given new apartments in a large project for the country's reconstruction. Could we go through the photographs, please, one by one? This is the Sloboda factory in Cacak that was destroyed by the bombing. This is the heating plant in new Belgrade, Novi Belgrade. The carbonised corpse of one of the employees of the Belgrade, Novi Belgrade heating plant. The fuel reservoir which was ignited, once again in Belgrade, in town.

Next, please. This is the destroyed warehouse in Dim in the ³¹⁴ town of Nis.

Next, please. How that facility looks in Nis. These are the factories in Lucani which I mentioned a moment ago. Next, please. The automobile factories in Kragujevac. Next, please. Once again, this is the production line, and you can see the assembly line for the cars, with the car bodies on the assembly line.

Next, please. This is once again the automobile factory. Glasnik in Pristina, the lacquer factory. And that was an investment of over 100 million German marks alone.

Next, please. This is the main road in Pristina that we saw a moment ago. These are the textile machinery factory in Krusik in Valjevo. Next, please. Once again, the same Krusik Valjevo factories for the production of textile machinery.

This is the destroyed hall of the transport firm and a workers' canteen in Krusik Valjevo which was destroyed.

Next, please. I'm not sure I recognise this. Yes, it is the factory for the production of batteries, once again in Kraljevo. Next, please. This is the Prva Iskra Baric factory. Next, please. This is Cigota, a place called Cigota, the armature factory which was destroyed. Place where it was hit. This is the inside of the factory as it was destroyed. The batteries factory, the inside of it and how it was destroyed. Is that it? Have we come to the end? Thank you.

There is a long list of bombings for fuel reservoirs and petrol ³¹⁵ derivatives. It was a systematic destruction of everything, but the ecological damage done is much greater, incomparably greater than the damage done on these facilities and fuel reserves and so on, although they are enormous, too.

In Cigota, it's on the 4th of April at 0200 hours; in Pancevo on the 4th of April as well. These are the corpses of the workers, the employees.

In Smederevo on the 4th of April; in Pristina on the 5th of April; in Novi Sad on the 5th of April; in Mala Krusa on the 6th of April; in the village of Devet Jugovica at Kosmet on the 6th of April; in Conoplja on the 7th of April and then again on the 8th of April. A systematic in-depth bombing with enormous craters. I'll skip over that. Novi Sad, the 7th of April. Once again in Bogutovac on the 8th of April. Four days later. Once again in Smederevo on the 9th of April. In Novi Sad on the 12th of April, and repeated in Conoplja on the 12th of April; in Pancevo. Once again the oil refinery was hit. In Smederevo, too, a repeated attack. They went back to do the job properly, to destroy everything, to raze everything to the ground.

We also have a list of the sports and recreation centres and hotels. From the top of Tornik, Zlatibor and Cigota at Mount Zlatibor, and then a whole range of others where people were killed. We have photographs with bodily parts blown off the victims. We have Baciste Hotel at Mount Conoplja. The hotel compound was completely burnt. You have the buildings and everything else. The cassette [phoen] bombs. They're all shown on these photographs. ^{316 BLANK PAGE 317} And all that in the first month. It is characteristic to note that this bombing was merciless. The bombing of civilian targets was merciless. That was the basic characteristic. The more suffering for civilians, the better. The more destruction and the more the lives of people were imperiled and as many dead as possible. Let me draw your attention to the fact that bombs were used, the impact of which led to the carbonisation of human bodies. These bombs were used to target facilities in built-up areas, and they destroyed whole housing and residential settlements. Cassette [phoen] bombs were used in the fields, and they stayed there, unexploded. They waited for curious, inquisitive children who had to pay dearly for their inquisitiveness. Curiosity killed them.

It is quite obvious that the targets were civilians. Take the example of the Grdelicka bridge. In broad daylight, and on the 30th of May - you'll see this later on - they bombed the bridge at Varvarin on the Velika Morava River at noon during a religious holiday, although they saw a large number of civilians on the bridge at the time. And then they used the same construction and targeted the bridge again when they knew that the safety teams giving first aid to the victims were located in the area. Each of these individual crimes represent enormous tragedies, and it was obviously the goal and objective to terrorise and break down the whole Yugoslav nation. The goal was, in practical terms, the nation as a whole.

These facts and figures do not contain figures of killed soldiers, although we consider them to be the victims of aggression as well, because ³¹⁸ if peace is the highest value of the United Nations, then aggression and war is the greatest crime. They were there to defend their country. They could not have been a legitimate target. They must not have been a legitimate target in their own country engaged in the defence of their country, a legitimate target of aggression which was illegal, unlawful and in violation of the United Nations Charter. It was perpetrated without any -- without being okayed by the Security Council and without the States of the NATO pact being asked.

Political leaders told me of a parliamentary parties in Italy, and I received them all during the war both from the left and from the right. We are not in -- nobody asked us whether we're going to go to war with a neighbouring country. The aggression showed that the NATO pact was not an alliance but an appendage of the American administration which can use it as it deems fit and when it sees fit.

That is why these committed crimes cannot be justified by anything, because they were preconceived and planned several months in advance. The targets were chosen several months before that, and in addition to that, the unacceptable text of an alleged agreement in Rambouillet was put forth, and that meant the occupation of the entire territory of Yugoslavia. And this allowed the anti-Serb and the anti-Yugoslav propaganda to work through the most influential media, through global networks to create a pretext for the aggression that was to follow.

Today it is more than obvious that the real reason for the NATO aggression was the geostrategic spreading of NATO interests and its areas, ³¹⁹ And also to create a precedent for using force in contravention of the UN Charter and without the approval of the UN Security Council. I assume that even in this room, nobody can help hearing this. I shall continue.

JUDGE MAY: It's now quarter to two, and it's the time to adjourn. So we'll adjourn until tomorrow morning, half past nine, and you can continue then.

Half past nine.

--- Whereupon the hearing adjourned at 1.45 p.m., to be reconvened on Friday, the 15th day

of February, 2002, at 9.30 a.m.