> 21694

Wednesday, 4 June 2003

[Open session]

[The accused entered court]

[The witness entered court]

--- Upon commencing at 9.07 a.m.

JUDGE MAY: Yes, Ms. Uertz-Retzlaff.

MS. UERTZ-RETZLAFF: Thank you, Your Honour.

WITNESS: WITNESS C-[Resumed]

[Witness answered through interpreter] Examined by Ms. Uertz-Retzlaff: [Continued]

Q. Witness, yesterday you mentioned the stay of the voluntary unit in Bubanj Potok and you also mentioned that you received equipment there. What kind of equipment was it?

A. Military uniform and military training. So it's boots, trousers, blouse, T-shirt, jacket. We got two caps and belts. So complete uniforms to wear, as well as footwear and also a wartime rucksack for ammunition, for equipment. That was it.

Q. And when did you leave the military base and where did you go?

A. The day after we arrived in Bubanj Potok we were escorted by the police and we took military buses to Bajina Basta.

MS. UERTZ-RETZLAFF: Your Honour, for your orientation, Bajina Basta is on this map, tab 27, of the Exhibit binder 326. And you can see on the bottom Bajina Basta, Skelani, and Perucko, the Serbian part on the one bank of the River Drina and Skelani in the -- on the Bosnian side. 21695

Q. In Bajina Basta, where did you stay?

A. When we arrived in Bajina Basta, we got off the buses in front of the fire brigade building.

Q. Who received you there?

A. We were met by two men. One introduced himself as Uco, and the other one as Milan Lukic.

Q. Milan Lukic, was he a Serb from Serbia or Bosnia, or wasn't he a Serb at all?

A. As far as I managed to figure out from talking to him, he was a Serb from Bosnia, but he said that he was in charge of our unit.

Q. What was he wearing?

A. Milan Lukic wore civilian clothes.

Q. What did he look like?

A. He was about 175 centimetres to 180 centimetres tall, a rather big man with a prominent jaw. He was heavily built.

Q. You said that he was in charge of your unit. What exactly was his function?

A. I had had an incident with one of my volunteers. So the next day I talked to Lukic --

Q. Let's stop here, and we need to go into private session because it's for your -- keeping your identity.

[Private session]

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[Open session]

THE REGISTRAR: We're in open session.

MS. UERTZ-RETZLAFF:

Q. Rajo Bozovic, what was he wearing?

A. He had a complete uniform, a belt and a red beret, and I think he had an American rifle.

Q. What did he look like?

A. He's about 180 centimetres tall. He's blond, rather thin, I should say.

Q. Was -- what ethnicity did he have? Could you make that out?

A. Yes. Rajo Bozovic is a Montenegrin, so we talked about that too.

Q. Did you receive weapons in Bajina Basta?

A. Yes.

Q. From where? Who gave it to you?

A. Within the fire brigade building where we were staying, there was a room. It was like a storage room, a basement, and that is where Milan Lukic and Uco brought us, and there were many weapons there, military weapons.

Q. Did you receive a task the following day to go to Skelani in Bosnia?

A. Yes. After we were issued with weapons for all our men, and then when we also got ammunition, RAPs, with 150 bullets each, Milan Lukic took 21698 us across the bridge to Skelani. That is the first town in Bosnia when one crosses the Drina from Serbia into Bosnia.

Q. How did you get there? Were you transported or did you walk?

A. No. It's quite nearby, so we walked on foot, two by two. We came to the bridge, and the military police was there and they had an APC, but they did not stop us. They were actually waiting for us.

Q. When you say "the military police," do you mean the military police from Bosnia or from Serbia?

A. Serbia.

Q. While crossing into Bosnia, did you see also other forces crossing over the bridge?

A. Yes. As we were moving towards the school in Skelani, I stood there with Rajo Bozovic. At that moment a column was coming to Skelani from Serbia consisting of four or five trucks with special units of the Army of Yugoslavia.

Q. Could you -- how could you see that it was special units and what special units?

A. First of all, I saw it. I saw the license plates on the trucks. I saw them, these specials I mean. I was in Nis and I know their uniform and I know the way which they dress. I know what they look like.

Q. You mentioned Nis. What -- what special unit? Do you know which name they had?

A. The Special Parachute Units.

Q. Did you also see Red Berets crossing into Bosnia?

A. Yes. Part of them had already arrived. When I met up with 21699 Rajo Bozovic, about 20 or 30 of them had already arrived. I didn't wait for the rest to come in too.

Q. Who received the volunteer unit in Skelani?

A. I went to the command immediately. In front of the command - and the command was just a prefabricated building - and lieutenant colonel or colonel was waiting for me there. Kuljanin I think was his name. And there was also a captain; I don't know his name. So Milan Lukic was there too.

Q. And this Colonel or Lieutenant Colonel Kuljanin, was he -- from which army was he a colonel?

A. That's the Army of Republika Srpska. And as far as I managed to learn from talking to him, he was an active-duty officer in the war.

Q. When -- when you were received in Skelani, were you -- were the volunteers requested to do anything with their Serbian ID cards?

A. When the unit was put up at the school - that's where we slept - I was told by the command to collect all the IDs, that people should not walk around with Serbian IDs.

Q. Why was that?

A. Well, I was told that if somebody got killed, the Muslims could see that this was the army from Serbia.

Q. Was that a common practice or was that the first time that you ever was confronted with such a request?

A. It was practiced most of the time.

Q. And who was over the command in Skelani? Could you figure that out? 21700

A. Well, during these preparations, it was Kuljanin, and Milan Lukic was a type of coordinator. That was my understanding.

MS. UERTZ-RETZLAFF: Your Honour, we need to go into private session briefly.

[Private session]

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[Open session]

THE REGISTRAR: We're in open session.

MS. UERTZ-RETZLAFF:

Q. These tanks, were they -- had they anything to do with your mission?

A. Yes. His instructions were that I should take a Motorola, and I did that later. I left one of my soldiers by the tanks so that I could have contact with him. And my duty was to cross the dam. And once this action started, I should tell them who were on the hill where the Muslim strongholds were and where most of the gunfire was coming from. And then the tanks managed to neutralise these houses, these positions from where the gunfire would come.

Q. Were you at that time -- the volunteer unit, was it subordinated to Colonel Kuljanin, or from whom did you get your orders?

A. Yes, absolutely. As soon as we arrived in Skelani, the unit was 21702 under the command of Republika Srpska.

Q. Did you know the -- you have explained your task. Did you know what the other units were doing at the same time and where?

A. Well, from the command, from Kuljanin, I got a topography map. On the back side there were all the directions in which all the units would move. And my conclusion was that there would be movement towards Srebrenica, the Red Berets, the special units of the Army of Yugoslavia. Whereas, I was supposed to draw the attention of the Muslims to myself.

MS. UERTZ-RETZLAFF: I would like to put to the witness now tab -- a map. It's tab 29 in the Exhibit binder 326 with all the maps.

Q. Witness, is that --

MS. UERTZ-RETZLAFF: And actually, the witness has the coloured map.

Q. Is that the original map that you just have in front of you?

A. Yes. This is the original topography map, Visegrad 2.

Q. And there is -- there are lines drawn in this map. Who drew the lines and what do they mean?

A. During my reconnaissance, I marked the positions of the Muslims, their bunkers, the direction of movement of my own unit, the putting of the Muslims in the school in Osetnica. And if you can see it in the lower part of the map, that's where the position of the White Eagles and the Red Berets is. This was the special units of the Army of Yugoslavia.

MS. UERTZ-RETZLAFF: Your Honour, I was just informed that you don't have the back side -- a copy of the back side of this map. So I would like the witness to put it on the ELMO. 21703

[Prosecution counsel confer]

MS. UERTZ-RETZLAFF: I'm just informed you have it, but it is not complete. There would be some more on the map.

Q. This -- if you please -- yes. Can you -- as we see now this little drawing, could you explain it? Because it is in the -- in the Serbian language, and I'm not able to read it. Could you -- could you please explain what this little sketch means.

A. This is what I got from them. This is what they marked in the command. It was probably Dragan Bitic, probably this commander -- this captain. Then there are crosses here, and this says Subotica. So that's my unit.

Then up here there is a two-headed eagle. So these are the White Eagles. The unit of the Army of Republika Srpska is marked up here. Then this small cross here shows my target, Osetnica, that is, and the other units. I cannot really decipher the rest. And also there is this telephone number here.

MS. UERTZ-RETZLAFF: That should be sufficient. Thank you.

Q. Having seen the area and the possible defence positions of the Muslims, did your unit request additional weapons? And if so, did you get them?

A. Yes, I did ask for tromblons, full grenades, snipers, and something called a Levak 2 for hand grenades, for propelling hand grenades, and ammunition as well.

Q. And who provided this?

A. Milan Lukic said that if any -- if we needed anything, there 21704 wouldn't be any problems. Whatever we needed, we would get. And that's how it was. And I also got two heavy machine-guns, the 84 type.

Q. Returning to Skelani, did you make any observation in the school involving Muslim detainees?

A. Yes. The day after I arrived in Skelani, the Army of Republika Srpska brought in 15 civilians of Muslim ethnicity to the school, to a room in the school.

Q. Yes. And what?

A. I was there and men were around. They were cursing the Muslims and threatened they would hand them over to the Chetniks if they didn't listen to them then they told them to strip and they gave them some old JNA uniforms as well as the M-48 rifles, old ones.

Q. Yes. Continue.

A. As I say, the whole time they were cursing and swearing at them. When they took them off in the army truck, none of them ever returned. And I heard comments about that from the soldiers of Republika Srpska. Allegedly the rifles weren't operational, and yet they were being sent to the frontline.

Q. Did the -- the unit, this Chetnik unit, did they actually engage in the combat activities they were assigned to by Colonel Kuljanin?

A. Yes. The operation lasted for four or five hours. The Muslims set up active resistance. There's a stream down there, a brook, and I didn't allow my unit to cross it because I saw --

Q. Witness, we would not need the details of the combat activities. It is enough to just briefly address it. I think I rather ask the 21705 questions, the very few that we would actually need. Did you get assistance from the tanks that you had mentioned before from Serbia?

A. Yes.

Q. Did you burn down the villages, as you were told to do?

A. No.

Q. Why not?

A. Before we set off, I ordered the unit, they were not to touch the civilians, the old people, and children, anybody not carrying weapons. And afterwards, I saw that it was just the civilians that were left behind, the women and children, so that I issued orders for us to return to base.

Q. Did you get another task in Skelani?

A. Yes. As soon as we returned to Skelani, we received orders to go to a place called Jezero. I didn't know where that was exactly.

Q. And what were you supposed to do there?

A. Well, part of the unit went off and I was told that there was active fighting between the Army of Republika Srpska and the special units on one side and the Red Berets and the Muslims and that we were going to help out as reinforcements.

Q. We do not need to go into the details of this activity, because it would -- the details are not needed. But let's briefly go into private session.

[Private session]

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[Open session]

THE REGISTRAR: We're in open session.

MS. UERTZ-RETZLAFF:

Q. When the volunteer unit left, did they take their weapons, or did they leave their weapons?

A. Yes, absolutely correct. We left everything. The military police was on the bridge of the -- of Republika Srpska, and they searched us.

Q. What was usually the procedure when the volunteer units had taken part in combat? Would they leave their weapons or would they take them home?

A. Well, mostly they would leave them behind at the headquarters to which they belonged. But you could take the weapons as well if you had a 21710 licence, a permit.

MS. UERTZ-RETZLAFF: Your Honour, I just see that we need to go back into closed session -- private session, because we need to discuss a personal matter for the witness.

[Private session]

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[Open session]

THE REGISTRAR: We're in open session.

MS. UERTZ-RETZLAFF:

Q. What did you see at the house of Arkan?

A. Well, where I was, I saw some leather suites, an enormous television set, computers. It was the reception area. It was all secured. There were people under arms guarding the place inside and outside. There were vehicles belonging to the Tigers, the Guards, and they had the Tiger emblem on them.

Q. How were you taken to Erdut?

A. With their vehicle.

Q. Did you have to cross checkpoints? And what happened on checkpoints?

A. Of course there were. The checkpoint was in Bogojeva [phoen] at the bridge there, but they didn't stop us. They just raised their arms in salute, and we were able to enter.

Q. Who maintained the checkpoint? Police or army or what?

A. Police.

Q. Serbian or RSK?

A. On one side it was the police of Serbia, and of course on the 21714 other crossing it was the police of Republika Srpska.

Q. In Erdut, where did you stay for the first couple of nights?

A. In a tent.

Q. Were other people also in the tent? And about how many, if you can say?

A. Well, there were about five or six of us, new arrivals. And there were also the prisoners there. That's how we called them. There were about 20 of them.

Q. These prisoners, as you call them, who were they?

A. As far as I was able to see, they were Serbs, people who had been withdrawing from Western Slavonia, trying to escape from the war zone.

Q. How did they get there? Do you know?

A. Yes. There were several ways, one of which was that when crossing into Serbia, they would be captured. And the other way was that the police, Arkan's police - I know specifically for Subotica, there's a flea market there - and they stormed the place and captured the people, as they did in the various catering establishments.

Q. When would this happen, these kind of raids for people? Was it just after Western Slavonia had fallen, or did that happen frequently?

A. Well, yes, after the fall of Western Slavonia and frequently too, in 1995, which means constantly.

Q. Did the Subotica police get engaged in that activity of Arkan, or did they cooperate, or did they stop him?

A. There were situations when we were together; that is to say, the police and them stormed the places. They would look at the people's IDs. 21715 People would be arrested, returned, and so on.

Q. These prisoners, as you say, how were they treated in Arkan's base?

A. Well, they usually had military uniforms, JNA ones. Instead of rifles, they had leather -- they had wooden sort of batons. On their backs they had to carry sand. So they were physically mistreated all day. They were kicked. They had to run around. They were physically abused. They had to do push-ups. They were shut up with dogs, and they were, of course, beaten with batons.

MS. UERTZ-RETZLAFF: Can we briefly go into closed session, Your Honour?

[Private session]

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THE REGISTRAR: We're in open session.

MS. UERTZ-RETZLAFF:

Q. How many men were -- how many soldiers were in the camp or Arkan's were in the camp, a rough estimate at that time?

A. Well, over there, there was a battalion. There were the Guards, the police. About four to five hundred men, I should say.

Q. The members of the unit you were in, were they -- what kind of people were they? 21717

A. I talked to those people. Of course, I didn't dare say that I was [redacted]. But they were criminals, killers. And that was what they said. They had been released from prison or escaped from prison, part of them in Erdut. Most of them were like that, anyway.

Q. Did you -- while you were there, and can you say how many -- how long was that time period all together, approximately?

A. About two months.

Q. During that time, did you participate in any combat activities?

A. Not directly, no.

Q. What did you do during that time?

A. We had training every day, exercises, the whole unit.

Q. Did you have night trainings? And if so, what did you do during the night?

A. Yes, we did have some night trainings. We would go to the positions around Osijek, and we demonstrated our force and might there, provocations, that kind of thing.

Q. While doing that, did you ever come across a Serbian police unit?

A. Yes.

Q. What kind of police unit was it?

A. They were units of the state security of Serbia.

Q. The discipline in the Arkan centre, can you describe it briefly?

A. Well, maximum discipline, highly disciplined. No alcohol, you had to follow orders, hygiene, top-level hygiene. It was terrific.

Q. Did you see Arkan himself?

A. Yes. 21718

MS. UERTZ-RETZLAFF: Private session, please, Your Honour.

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[Open session]

THE REGISTRAR: Now we're in open session.

MS. UERTZ-RETZLAFF: Thank you. I would like to put to the witness tab 20. And it is also on Sanction. It relates now to Vukovar. And it is a request of the Chetnik commander of Vukovar, Mr. Katic of 9th 21720 of December, 1991 for the promotion of officers.

Q. And if you look at the stamp and the format -- the form of this document, would you say it's a -- a authentic document?

A. Yes. This was signed by Slobodan Katic, captain of all volunteers in Vukovar. Seselj sent him there to be the commander of all the Chetniks from Serbia in this part of Vukovar. And the stamp is that of the municipal staff of the Territorial Defence of Vukovar.

Q. When -- you have already mentioned this person Kameni Lancuzanin from the Leva Supoderica. Do you know whether he was actually promoted? And if so, to what?

A. Yes, Milan Lancuzanin, Kameni, acquired the title of a Chetnik Vojvoda or duke.

Q. And you also see here the names of Miroljub Vujovic, commander of the TO, and Stanko Vujanovic, chief of TO in Vukovar. Were they also members of the Serbian Chetnik Movement, or why are they on this list?

A. No, they were not members of the Serbian Chetnik Movement. But the Chetniks in that area belonged to them. They were under their command.

Q. Related to --

MS. UERTZ-RETZLAFF: Thank you. That's enough for this document.

Q. But related to this document, I would -- I have a question in relation to an exhibit that was used with a different witness here. And it's Exhibit 387, tab 31. It's a decision in relation to an assault operation in Vukovar on the 29th of October, 1991.

Q. And witness, I do not want you to comment on this document. 21721 I -- because that's not to you. But I would have to ask you a few questions. And just if you look at the first page, under the headline -- the first page, please, under the headline 2, "Units tasks," we find under number 1, the detachment Leva Supoderica, followed by the words "detachment Petrova Gora." Is that detachment Petrova Gora also a Serbian Chetnik unit?

A. Yes.

Q. Then followed by, "Volunteers Company, Novi Sad." Would you know whether this is related to the Chetnik Movement?

A. In my opinion, they are volunteers attached to the army.

Q. And when you now turn the next page and you come to point 3 where units are mentioned. And in the middle there is a reference to the 1st Volunteer Company, Smederevska Palanka. Would that be a Serbian volunteer unit or something else?

A. Yes, it is probably a Chetnik unit.

Q. And how would you make this distinction? Why do you think that?

A. After the fall of Vukovar, I was there, and I saw quite a number of people from that area and I spoke to them.

Q. Now, that's enough. This is all I wanted to ask you about. And I would like to put to you a photo now.

MS. UERTZ-RETZLAFF: It's tab 24. The quality of the photo is quite bad here on this, as we can see it here now.

Q. Were you shown this photo during your preparation of your testimony? And could you say who that is?

A. Yes. 21722

Q. Did you --

A. I think this is the Chetnik Vojvoda Aleksic from Bosnia.

Q. And how do you know him?

A. I heard of him, and I've seen several of his photographs. And there's even a calendar with his image. The picture is not clear. There were quite a number of Chetniks wearing beards like this. But I think it is him.

MS. UERTZ-RETZLAFF: And now for the conclusion of this testimony, I would like to go into private session, because I need to put a document to the witness. And it's tab 25.

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[Open session]

THE REGISTRAR: We're in open session.

JUDGE MAY: Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] Mr. May, in my assessment, we went into private sessions repeatedly, not to discover the identity of the witness. I shall do my best not to require private sessions, and I will not mention the name of the witness. But I will mention the events. And I want to make these things quite clear, because this is one of the examples of the opposite side having documents from which it can infer -- reach the conclusion that these are untruths, yet it is insisting on this type of witness. And I will prove that.

Cross-examined by Mr. Milosevic:

Q. [Interpretation] Mr. C-047, Croatia-047, as is stated in your statement and during your testimony yesterday, you joined the Serbian Chetnik Movement, the Serbian Radical Party, because you favoured the 21726 monarchy, you wanted to overthrow the Communists, or as you put it here on page 4, you wanted to get rid of the Communists and Milosevic. Is that right?

A. Correct.

Q. You even said yesterday that that unit that you formed wanted to overthrow the Socialists, to topple the Communists, to fight against me, et cetera; is that right?

A. Quite right. There were several such units.

Q. Very fine. So you tried to win over army officers. You recruited members of the Army of Yugoslavia or the JNA, policemen. All this with the view to overthrowing me. And you even said that there were many officers and policemen who joined this Chetnik Movement of yours. Is that right?

A. Right.

Q. And then that movement fell apart, as you said, yesterday, in 1995, when the information reached the state security and you feared arrest?

A. That is not right. I said in 1993.

Q. In 1993, when the state security acquired information about you and you feared arrest; is that right?

A. Yes, that's right.

Q. Fine. So you organised this movement to overthrow me. You tried to win over policemen and army officers. And then you fell apart when information about you got into the hands of the police and you feared arrest. And furthermore, you claim - and that brings me to my next 21727 question - that you actually collaborated in Subotica with the Socialist Party of Serbia. In all these facts and activities which I have briefly described and which you just answered about.

A. That's not right.

Q. Did you collaborate with the Socialist Party of Serbia? Didn't you say that? And that the SPS also wanted chase out the Croats, Hungarians, et cetera, from those areas. Isn't that what you said?

A. No. I said that the leaders of the Serbian Radical Party did that. I didn't mention the Serbian Chetnik Movement. And secondly, to answer your question, as regards the police and JNA officers or Yugoslav army officers, don't believe that they all wanted you. Many intelligent people were reasonable and knew what Communism meant.

Q. I won't go into those assessments that you consider yourself to be qualified to comment on. I think that you don't even know today what you're talking about. But we'll come to that.

JUDGE MAY: He can make his comment. You're usually asking the witnesses about political matters. Usually you're very keen to do that. So you can ask him.

But one thing C-047 -- C-047 -- Just a moment.

One thing, C-047, remember before you answer any questions, just make sure that the microphone of the accused is turned off. Secondly, if there are any matters which you think could in any way lead to the revelation of your identity and you want to answer in 21728 private session, would you ask and then we can go into private session and you can answer in private session.

Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] Very well.

MR. MILOSEVIC: [Interpretation]

Q. You are specifying by saying that the Socialists and the Socialist Party in Subotica did not collaborate with the Serbian Chetnik Movement but rather with the Serbian Radical Party. Is that what you're saying?

A. Yes.

Q. And you said that the Serbian Radical Party had acted in an organised fashion to expel members of other ethnic communities from those areas; is that right?

A. The Serbian Chetnik Movement is something else. It is not political.

Q. I'm asking you about the Serbian Radical Party. You said that the Serbian Radical Party organised these things and that it cooperated with the SPS.

A. Yes.

Q. Since for many years you were living and working in Subotica, do you know how many Croats and Hungarians were members of the Socialist Party of Serbia in Subotica? Several hundred Croats and Hungarians were members of the SPS in Subotica.

Do you know that?

A. I don't know that.

Q. Very well. If you're not familiar with the membership of the 21729 Socialist Party of Serbia in Subotica, you surely are aware of the membership of the Chetnik Movement. Do you know, for instance, that the president of the Municipal Committee in Subotica from 1990 until 1995 was Ana Prcic, a Bunjevac, a money of the Bunjevac community?

A. Yes, I do know that.

Q. And do you know that the president of the committee for the entire area of Northern Backa and also a member of the main board of the SPS, from 1993 until 1996 was Tibor Molnar, a Hungarian, and after him, Mihalj Vermes another Hungarian. So leading figures in the Socialist Party of Serbia for the whole district of Northern Backa. He was also a parliament member in the Chamber of Citizens. Do you know those people? They are well-known figures.

A. I think that that is not important at all. There were Hungarians and Croats in the Chetnik Movement as well.

Q. I am not asking you to say what is important or not. I'm just asking you whether you know that or not.

A. No, I don't know that. I didn't keep abreast of politics.

Q. Very well. And do you know that president of the municipal board in Subotica for many years, including today, is Branko Popovac, also a Bunjevac -- a member of the Bunjevac community?

A. I don't know that he was a Bunjevac.

Q. Do you know Margit Saovic, a Hungarian, who was even a federal minister and who is truly a Hungarian? Surely you know her.

A. Mr. Milosevic, you are talking of a couple of individuals out of 150.000 inhabitants. 21730

Q. I am saying that you're telling untruths regarding any kind of cooperation between the Socialist Party of Serbia in which there were several hundred Hungarians and Croats in Subotica and that the main figures in the leadership of the party was Ana Prcic, a Bunjevac, Tibor Molnar, Mihalj Vermes, and others. And you're trying to sell the story here that these leaderships cooperated in expelling Hungarians and Croats? Is that what you're trying to tell us?

A. I said that Dusan Stipanovic, Dusko, did cooperate with the leaders of the Serbian Radical Party on a daily basis.

Q. That is not true. That is unbelievable. Stipanovic is not a Serbian surname. He's not a Serb.

And secondly, he was secretary of the municipal board, whose boss was this lady that I mentioned.

JUDGE MAY: Listen, Mr. Milosevic, there's no point arguing with witnesses. You've been told this many times. But it's a good illustration. You've heard what the witness said. That's his evidence. There's no point your then arguing with him. We waste a lot of time that way. Let's move on.

THE ACCUSED: [Interpretation] Very well, Mr. May. Such an absurdity needs to be heard for the public to hear it and the people in Subotica to hear about it, that the Socialist Party of Serbia cooperated with the Serbian Chetnik Movement and the Radicals.

MR. MILOSEVIC: [Interpretation]

Q. Do you know that the Radical Party throughout that period was the fiercest opposition to the Socialist Party of Serbia? 21731

A. Yes, publicly.

Q. And secretly, they were cooperating, were they?

A. Yes, correct.

Q. Oh, I see. Oh, you're really well informed. You think it's possible on the political stage to clash most fiercely and then clandestinely to be cooperating? So that's what you're telling me? But please let us remove all mystery about one particular point.

THE ACCUSED: [Interpretation] At the very beginning, as, Mr. May, the lady opposite sought to attach significance to this witness. Tab 1, please. Please let us not go into private session, because I don't intend to read any names. The identity cannot be revealed.

JUDGE MAY: We will go into private session to discuss this exhibit.

[Private session]

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--- Recess taken at 10.40 a.m.

--- On resuming at 11.04 a.m.

[Open session]

JUDGE MAY: Yes, we're in private session; is that right?

THE REGISTRAR: We're in open session, Your Honour.

JUDGE MAY: Yes, we're in open session.

JUDGE MAY: Now, there's a matter which Mr. Nice has to raise.

MR. NICE: I'm grateful. It's to do with the ordering of witnesses this week. B-024 has to come back and complete his evidence. It's thought that will take a normal working day. The Chamber, the accused, and the amici have been provided with written explanation for his need to be dealt with as swiftly as possible. And we would therefore, although we regret having to do this, ask that the evidence of this witness wrap round B-024, to use that phrase we've developed, if that becomes necessary, because this witness doesn't conclude today. There's an additional problem in respect of B-1098, for whom two further pieces of material were provided to the parties yesterday -- or in respect of whom two further pieces of material were provided for the parties yesterday. He's being kept back to travel home on Friday, and it would be very desirable to complete his evidence, if at all possible, tomorrow. 21740 The amici tell me they would want, in light of their review of the material, five minutes with the witness. I understand that the accused would like a little longer, 15 or 20 minutes, thereabouts. So it may be half an hour or a little more would be required for that witness. I would ask that it shouldn't be necessary for the material itself to be viewed in court. It can all be counted as pre-viewed outside court. And so we would be looking for perhaps half an hour or a little more for that witness in order that he could go back on Friday. I have inquired, I hope not impertinently, as to whether there's any prospect of sitting perhaps a little longer tomorrow than the normal hours or even invading the afternoon, were the accused able to do that and were others able to accommodate us. Otherwise, we're going to have two witnesses who, through no fault of their own, but as a result of various historical events will have been very substantially detained and inconvenienced.

JUDGE MAY: Very well. We'll consider this. And what you're asking is B-024, B-1098 be interposed effectively, which may require this witness to come back next week, I'm afraid.

MR. NICE: Yes, that's less inconvenient than the other courses.

[Trial Chamber confers]

JUDGE MAY: We'll agree then.

MR. NICE: Thank you very much.

JUDGE MAY: And we'll see about tomorrow afternoon. I don't know about that.

[Trial Chamber and registrar confer] 21741

JUDGE MAY: Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] Mr. May, wouldn't it be more sensible to finish this B-024 tomorrow if necessary and today to have this brief continuation of the previous witness, and then you only have one person who has to come back yet again, and that is the one who is sitting here right now. Then you wouldn't have anybody else. If you resolve this problem of 1098 today, then tomorrow you have B-024 all day.

JUDGE MAY: We've been asked to put him in tomorrow, B-024. So we'll do as much as we can with C-047 today, and we'll review the position at the end of the day. We'll see if there's any possibility of doing some more work tomorrow afternoon. But all that we'll consider. So let's proceed.

THE ACCUSED: [Interpretation] Yes. But if we work longer tomorrow afternoon, then I lose time, the time I have with my associates, which is rather short anyway. Because I am given time between 3.00 and 15 to 5.00 with them and I barely make it by 3.00. Sometimes I'm even late for that. All right. I can proceed. I hope we are in open session.

THE REGISTRAR: We're in open session.

THE ACCUSED: [Interpretation] All right.

MR. MILOSEVIC: [Interpretation]

Q. You explained that actually publicly the Serb Radical Party was in opposition but secretly there was some kind of cooperation. Is that your assertion?

A. Yes.

Q. All right. Does that mean that publicly Seselj was in prison and 21742 secretly he was at home at that time?

A. Not that.

Q. Oh, all right. Let's go on, then. You say that you worked where you worked. Let's not raise that issue again, where you worked. That you had problems with your superiors, that you had problems over there with your superiors too. Is it true that you had problems due to alcohol?

A. No.

Q. As far as I managed to understand things, precisely from the document that Ms. Uertz-Retzlaff showed just now towards the end - I'm not going to mention any names. I won't mention anything - but, inter alia, it says there, since it has to do with a very negative assessment of your behaviour in respect of measures that were taken vis-a-vis you and your party, the Serb Radical Party, it says, "Personally took part in the establishment of unknown paramilitary formations." And then this alleged activity included persons from these areas that were prone to the use of alcohol and crime, and then this same person - they mention your name, of course - "under the influence of alcohol put on a camouflage uniform, walked around town during the pre-election campaign, disturbed the citizenry in the apartment of a lady called so and so."

JUDGE MAY: Private session. Private session.

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[Open session]

MR. MILOSEVIC: [Interpretation]

Q. You say that in the autumn of 1981 the first unrest occurred in Kosovo, the first armed conflict between the Kosovo Albanian terrorists 21750 and the police. Do you remember why these conflicts broke out?

A. I know that the federal special unit under the command of Franc Kos went to Kosovo, from the 13th of May base.

Q. All right. You say that conflicts broke out between -- now I'm going to read this from your statement: "Between the Kosovo Albanian terrorists and the police"; is that right?

A. Yes.

Q. Well, yesterday, when you talked about this in Kosovo, you said that there was repression there against the Albanians. Whereas, here you say quite nicely that there was a conflict between the Kosovo Albanian terrorists and the police.

A. This is not my opinion. What has been written here was what I was told.

Q. Oh, you know nothing what happened?

A. Oh, I know very well.

Q. So what did happen in Kosovo in 1981?

A. Of course the Albanians were seeking their rights. They wanted their own republic. They wanted to have their own government. They wanted to have their own authorities, the police. And that was not permitted.

Q. But they had all of that within the province.

A. Hardly.

Q. Oh, you don't even know that either.

A. I do know. They hardly had any of that.

Q. All right. They didn't have a republic, of course. Well, they 21751 certainly didn't have a republic.

All right. You mention, referring to Kosovo, the fact that you had contacts with members of the military counter-intelligence service. And you mentioned Colonel Petrovic, whose nickname was Pizon. So could you explain to me what this means. Why is this important? Why did they contact --

A. I got to know the members of KOS in 1991 first. [redacted]

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MS. UERTZ-RETZLAFF: Your Honours, we are now again addressing the witness's position and whom he met in this position, in his profession.

JUDGE MAY: We'll go into closed session -- private session, I mean.

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[Open session]

THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. You spoke about the visits of Vojislav Seselj, the president of the Serbian Radical Party, to your region in the autumn of 1990. That's right, isn't it?

A. Not 1990. It was in 1991. I apologise, but which meeting are you referring to?

Q. I'm talking about the first visit that you talked about yourself during your testimony.

A. So when I got to know Seselj? Is that what you mean?

Q. Well, take a look at page 3 of your own statement, where you say "During the autumn of 1990." That's right after the title, the first paragraph. It says: "During the autumn of 1990." Is that right?

A. Yes.

Q. Or was that during the autumn of 1990?

A. Yes, you're quite right. Yes, it was.

Q. And I assume that this is not a matter for private session, but then with respect to these events and the presence of Seselj during 1990 you expressed the desire to be a member of the Radical Party, did you not?

A. Yes.

Q. And that is in fact the sentence when you say: "At that time, I was ready to fight for anybody, to -- for us to be able to rid ourselves of the communists and Milosevic." Is that right?

A. Yes. 21755

Q. So let's just establish this. This was the autumn of 1990, wasn't it?

A. Yes.

Q. All right. Fine. And this is why I wanted to establish that particular fact, because you're not telling the truth there either. Do you know, since you say that you're testifying about it, do you know that the organisation, according to the information that my associates checked out very rigorously, both on the spot and in the party itself - the activities of the party is of course public and registered - so the organisation of the local board in Subotica was formed in mid-May 1991, in fact. And you're talking about the autumn of 1990.

A. Correct. I informed -- I met Seselj in 1990. The two individuals I also mention from Subotica had already established independently of the Serbian Radical Party and the registry of the registration of the party itself took place in May 1991.

Q. In the autumn of 1990, the Serbian Radical Party did not even exist.

A. That's not what it's called.

Q. Let me make this clear. The Serbian Radical Party did not even exist them.

A. It wasn't called that way. It wasn't called anything because it didn't exist. Didn't Ms. Uertz-Retzlaff yesterday - I don't want to have to search through the various tabs - she gave you the establishment of the founding assembly in Kragujevac when it was established first and when the name of the Serbian Radical Party was first heard of, in February 1991. 21756 That's when that took place. So in the autumn of 1990, you couldn't have talked to anyone, let alone Vojislav Seselj, about the Serbian Radical Party.

A. I said that the Serbian Radical Party was not called the Serbian Radical Party at that time. It was a different movement led by Seselj.

Q. I'm going to read out something else to you. You're talking about the Serbian Radical Party, but let's move on. I claim that this meeting or, rather, his arrival is something you invented. Because Seselj in the autumn of 1990 himself was in prison and he was not in Subotica.

A. May I ask the Trial Chamber to go into private session for a few moments, please?

JUDGE MAY: Yes.

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[Open session]

MR. MILOSEVIC: [Interpretation]

Q. You mentioned certain events in the village of Jankovci, Vukovar municipality. You say that Serb rebels attacked the police station and allegedly a person whose name for your own safety and identity I cannot mention, to remain in open session, said that they were preparing an attack on Borovo Selo and that he allegedly told you what the plan of attack for Borovo Selo was.

A. Are you referring to second paragraph on page 5? The attack by a group of Serb civilians did take place at the police station in Jankovci. And the person mentioned here is now in Subotica. And this other person - I wouldn't like to mention his name - had already organised Chetnik units and organised Chetnik units and trained them and crossed via Plavna to Borovo Selo. This was in 1991, in May.

Q. You say that this person who was obviously a member of the Serbian 21768 BLANK PAGE 21769 Chetnik Movement, wasn't he, said that they were preparing an attack on Borovo Selo?

A. On Croatia. On Croats. I mentioned Borovo Selo.

Q. "And this same person told me about the preparation -- that they were preparing the attack on Borovo Selo." That is what it says.

A. Yes.

Q. First of all, is it true that you made up -- that you contacted this person prior to the events in Borovo Selo? Do you know exactly when that event occurred in Borovo Selo?

A. In May, as far as I remember, in 1991. I don't know the exact date.

Q. It was on the 2nd of May, even before that person joined the party, became a member of the party. On the 2nd of May, and any one of you could have joined the party after the 15th of May, 1991 because it was only then that you had established the party in Subotica.

A. The party existed, but it was registered in May.

Q. Very well. If you know what happened in Borovo Selo and Jankovci, when you say that the Serb rebels attacked the police.

A. I know they attacked the police station in Jankovci, the persons mentioned here.

Q. Tell me, please: So you link this to the Serbian Radical Party, an event which occurred before the Serbian Radical Party was formed.

A. No, I'm not linking that, the Serbian Radical Party to this.

Q. What do you mean you are not connecting it? When you say that this man whom you describe as a prominent representative of that same 21770 political party told you that they were preparing an attack on Borovo Selo.

A. We're not talking about the same person. There was one person for Jankovci and another person for Borovo Selo.

Q. Do you know that on the 2nd of May there was quite a large group of members of the Croatian police who raided Borovo Selo and started shooting at the houses in the centre of Borovo Selo as soon as they arrived? Do you know that?

A. I don't know anything. I heard about it, yes.

Q. So you received information that Serbs were attacking -- were preparing an attack on Borovo Selo, whereas the situation was quite the reverse and you don't know anything about it.

A. Yes, I do. But --

Q. And do you remember that on that day, on the 2nd of May, HDZ took control of the Vukovar radio station by force and appointed a new director, Zdravko Seremet, a member of the municipal board?

JUDGE MAY: C-047, you didn't finish the earlier answer. Do you want to go into private session or do you want to finish the answer? What's being put to you was that you received information that the Serbs were attacking or preparing to attack Borovo Selo, whereas the situation was quite the reverse. And you don't know, it's put to you, you don't know anything about it. Do you want to clarify your answer as to that? And if so, do you want to do it in private session?

THE WITNESS: [Interpretation] Yes. Yes.

JUDGE MAY: Very well. Private session. 21771

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THE REGISTRAR: Okay. We're now in open session.

MR. MILOSEVIC: [Interpretation]

Q. My question related to a part of your statement in which you explained that a certain official of that movement of yours explained to you that they were preparing an attack on Borovo Selo. Do you know -- and then I asked you as to what actually happened over there, so I have another question in that connection. Do you know that during the incursion of the Croatian police into Borovo Selo a local inhabitant was killed and in the clinic they held as hostages women and children and clinic personnel?

A. Mr. Milosevic, I don't see what that has to do with my statement. I am saying what this person told me.

Q. But you are saying that the Serbs were planning an attack on Borovo Selo, which is a notorious lie.

A. The Serbs from Serbia.

Q. Were planning an attack on Borovo Selo. That is a notorious lie. 21773 Because they didn't attack Borovo Selo. But what happened was quite the opposite.

Do you know that by the intervention of the JNA units the battle there was halted and they saved these Croatian policemen and made it possible for them to leave the village? Because they came into the village, raided it, started shooting at the village, they took women and children and medical staff at hostages, a JNA unit arrived, blocked them, and escorted the Croatian policemen out safely without firing a single shot? Do you know that?

A. Yes. They were there with APCs.

Q. And the command of the 1st Military District issued a public announcement then, that members of the JNA during the tragic events in Borovo Selo did not use firearms at all, did not fire a single bullet, but through the engagement of JNA units an armed conflict was prevented as well as any further bloodshed. Do you remember that?

A. But the bloodshed was not stopped, unfortunately. It continued.

Q. And do you know that in those days restaurant owned by Serbs were blown up, Sarajka, owned by Djordje Pejicic, Krajisnik, that is the name of the facility, Tufo, et cetera? Do you remember all those events from that -- those times?

A. I'm not aware of each and every incident that took place over there.

Q. But then you referred to the Zagreb Vjesnik. Do you remember Josip Boljkovac, one of the closest associates of Franjo Tudjman?

A. Yes. 21774

Q. And did you perhaps have occasion to see a statement of his, and I'm quoting him, "It is true that four of them, members of the MUP of Croatia, entered Borovo Selo to remove the Serbian flag? Who needed this?" He says. He himself condemns it and --

JUDGE MAY: What's the point of all this? It's a very small part of the witness's evidence. And now you're asking him about what some member -- I forget who it is. A close associate of Franjo Tudjman said about it it's not relevant to his evidence. Let's get on with things.

THE ACCUSED: [Interpretation] Well, it is relevant, Mr. May, because this man, who is a politician, and who was Minister of the Interior as well, and I don't know what else there at that time - I cannot remember everything - he was one of the closest associates of Tudjman. He is certainly competent to say this, and this is what he said in his interview to --

JUDGE MAY: You can call him as a witness if you want to, but you're not examining this witness any more about what he may have said. Call him as a witness if you want. Now, let's move on.

THE ACCUSED: [Interpretation] Mr. May, I am trying to put to this witness claims that were made by the opposite side and --

JUDGE MAY: It doesn't matter, as far as his evidence is concerned. Now, this was a tiny part of it. Now, why don't we move on to something more substantial?

THE ACCUSED: [Interpretation] Mr. May, do you really - do you really - think that this witness, in view of his position --

JUDGE MAY: Stop arguing and just continue with your 21775 cross-examination. Now, on a more substantial point.

MR. MILOSEVIC: [Interpretation]

Q. All right. Mr. C-047, do you know that in Borovo Selo there was not a single volunteer from Subotica?

A. Mr. Milosevic, until now I did not mention a single volunteer from Subotica having been in Borovo Selo.

Q. And is it correct that this man who you did mention, who allegedly told you about the attack on Borovo Selo, was not in Borovo Selo either?

A. He was.

Q. Oh, you claim he was there, when that conflict was taking place; right?

A. Yes.

Q. Very well. You say that some volunteers, that this man you mention had gathered together, were being trained at a private property. I am not going to mention the name of this particular locality. But you don't even know how many volunteers he managed to gather together and where this was taking place. How do you know that?

A. I know because I heard about it in this restaurant where we were.

Q. Oh, you heard it in a restaurant.

A. Yes. I said that I was not there myself.

Q. All right. All right. And this man who you say said to you that Seselj ordered you to prepare the volunteer detachments.

A. I don't know what you mean. In which situation?

Q. Well, the situation that you're referring to on page 4 in paragraph 6. That's what I mean. I don't find this logical, that Seselj 21776 would issue orders as the leader of a party that did not even exist yet. So read page 4, paragraph 6, what you're saying there.

A. Mr. Milosevic, the Serb Chetnik Movement has been in existence since 1945, but it was illegal then. This was a situation for it to gather together within military formations.

Q. You really do not know a thing, and this is practically shown by each and every answer you give. But let me mention some names to you now of persons you had allegedly talked to.

THE ACCUSED: [Interpretation] So let's not argue, Mr. May, as to whether this is open session or private session. I'm asking you in advance: Can I mention the names of police officials, police officials who were --

JUDGE MAY: We'll deal with that after the adjournment. We'll start in private session, to be on the safe side, and then we'll consider what to do.

Twenty minutes, please.

--- Recess taken at 12.15 p.m.

--- On resuming at 12.41 p.m.

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THE REGISTRAR: We're in open session.

JUDGE MAY: Yes.

THE ACCUSED: [Interpretation] I assume that this is not for private session, I mean whatever has to do with volunteers. This is what the witness spoke about in open session.

MR. MILOSEVIC: [Interpretation]

Q. Well, I wish to draw your attention to part of your statement. Let me tell you quite openly. I want us to establish here that what you are talking about the assembly of volunteers is pure invention on your part. Look at page 6, paragraph 2. The niece of Stjepan Mesic, the current president of Croatia, was one of your volunteers. That's what it says here. Her name was Lidija Mesic. Is that what you said?

A. Yes.

Q. Tell me, please: Do you know at all then that -- that Erceg is the last name of Stjepan Mesic's niece, not Mesic?

A. That's how she introduced herself, and she said that he was the niece of Stjepan Mesic, that her house had been torched there. And I think she lived in Mali Idjos. I don't know her other last name.

Q. Do you know that she came to Subotica from Lika as a refugee sometime in 1992, 1993 with Istvan Hajages, a volunteer? Again, you can see by his name that he was not a Serb either. 21778

A. Yes, that's right. He was a Hungarian. It was not in 1992 or 1993. They were in Subotica in 1991. You have the newspapers and you have a photograph of theirs there.

Q. Very well. So she's a refugee, and she had already come as a member of the Serb Radical Party because she had joined the Serb Radical Party in Lika. She lives in the village of Njegos in the village of Backa Topola. So she had nothing to do with you whatsoever, and you claim that she was your volunteer. How could she have been your volunteer?

A. Please, Your Honours, could the photograph be shown from 1991, when the Serb Chetnik Movement was proclaimed. There is her photograph, my photograph, the leader of the Serb Radical Party, and Istvan as well.

JUDGE MAY: If anyone has got the photograph.

MS. UERTZ-RETZLAFF: Your Honour, this is actually the item that we did not address, so we have it. It's tab 21 in the exhibits that we had proposed in the beginning.

JUDGE MAY: Can it go onto the Sanction?

MS. UERTZ-RETZLAFF: The photograph is only on the -- on the Serbian version.

JUDGE MAY: Very well. Well, let the witness have the photograph. Yes.

Yes. Is that the photograph you had in mind, Witness?

THE WITNESS: [Interpretation] Yes.

JUDGE MAY: Yes. Now, do you want to say something about that? If you do want to say something about it, do you want to say it in private session or not? 21779

THE WITNESS: [Interpretation] Well, it would be best to deal with it in private session.

JUDGE MAY: Yes. We'll go into private session.

MS. UERTZ-RETZLAFF: And Your Honour, you have now the photograph on Sanction.

JUDGE MAY: Thank you.

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THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. Do you refer to some speech made by Seselj, and he says, "We are 21784 going to kill all of them. We are going to expel them." This is what you say, that at a rally in Subotica he said that he would gouge the eyes of Croats with rusty spoons.

A. Yes.

Q. According to the information I have - so please either confirm it or deny it - a rally was held on the 13th of September, 1991 in Subotica, a rally of the Serb Radical Party. Is that right?

A. Yes.

Q. And this is what he said at that rally.

A. Yes.

Q. According to the information I have, this rally was attended about 5.000 persons. Is that right?

A. I don't know the figure.

Q. Well, approximately.

A. I don't know.

Q. How many people were there?

A. There were many people.

Q. According to the information I received, everybody who attended that rally can confirm that he never said any such thing, expel, kill, all these things that you refer to here, gouge Croats' eyes with forks and knives, rusty forks and spoons.

A. He said that anybody who does not respect Serb authority, that is to say, Croats and Hungarians, should leave Subotica and that area. He said that he would use rusty forks and spoons.

Q. This was at a rally attended by 5.000 people? 21785

A. That's my recollection.

Q. I assume that somebody else who attended that rally would have to remember that too. Wouldn't that seem logical to you?

A. Well, they would have to remember that, especially Hungarians and Croats.

Q. According to the records that I have gathered here, this reference to rusty spoons was made only by way of black humour on an entertainment TV show hosted by Minimax [phoen] in 1991 on television?

A. Did he use the word train cars?

Q. Well, until the present day, he says he is going to eat up this Naletilic. He says he plays chess with him but then he doesn't really want to devour him because he's too skinny. But do you want to say that therefore he hates Croats?

A. I'm not trying to say anything. I'm just telling you what I remember him having said there.

Q. Did you ever attend a meeting with him?

A. Yes.

Q. Well, do you know that the people that you mention claim that that is just not true?

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THE WITNESS: [Interpretation] Is this in private session? 21786

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JUDGE MAY: We'll go into private session.

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[Open session]

MR. MILOSEVIC: [Interpretation]

Q. Mr. C-047, you continue to say that the Serb society of St. Sava in Subotica, the Subotica branch of the Sisters of Serbia Society, a charity organisation which cooperated with the Serbian Orthodox Church and the Bunjevacka political organisation, which was linked to the Serbian 21787 Radical Party. That they collected clothing and other items which they sent on to the battlefield, cigarettes, medicine, socks, clothing, plum brandy and so on. You say that on page 5, paragraph 7; is that right?

A. Yes.

Q. Do you know that that the Bunjevac circle, Bunjevacko Kolo, was a cultural arts society which could have nothing akin to the radical party. It was the Bunjevacko Sokacka party that could have been written down here.

A. I don't know what you consider to be a mistake in the translation.

Q. It seems to be that the whole of your statement is a translation error. Do you know that this Bunjevacko Kolo was established in the 1970s, way back in the 1970s. And at this particular time that you're testifying about, 1991, 1992, it was renamed the Croatian Cultural and Arts Society?

A. Well, I put myself right. It was the Bunjevacko Sokacka Stranka or Party.

Q. Well, in 1991 or 1992 it took the name of the Croatian Cultural and Arts society.

A. Well, I know about the Bunjevacko Kolo. But as I said, it was the Bunjevacko Sokacka party.

Q. Well, at the time when allegedly, according to your explanations, there was a lenient attitude on the part of the authorities in confronting the different national communities and that this should be the Croatian Cultural and Arts Society precisely in 1991 and 1992, and it exists today, and it is led by these Croats. 21788

A. Mr. Milosevic, I said the Bunjevacko Sokacko party, not the Bunjevacko Kolo, which is something different again.

Q. Well, anyway, you say this on page 6, paragraph 3. You say that you were led to believe the lies disseminated by Serbian propaganda that Croatian Ustashas were killing civilians and children, to that effect. What I'm asking you now is this - and this is a public, an open session, so I hope we don't have to go into private session - are you claiming --

THE ACCUSED: [Interpretation] Are we in open session, Mr. May?

THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. I'm asking you'll with respect to this assertion, and in fact that you believed the propaganda saying that the Ustashas killed women and children, do you claim that these were untruths, that the crimes reported had been committed against Serbs at that time were not true?

A. I'm not saying that. The propaganda that came over your radio and television did incite people to arms and bloodshed.

Q. Well, can you quote a single programme or broadcast which you refer to as my television programme inciting the people to rebellion and bloodshed?

A. What did you say? I didn't quite understand you.

Q. Can you quote me an example from any television programme of the kind that you mention about inciting people to bloodshed? Because you say you believed the propaganda put out that civilians and children were being killed there. So my question to you was: Do you claim that all that was untrue, that in fact the Serbs were not under threat, and jeopardised them 21789 that it wasn't the civilians who were killed and people killed in general?

A. There were crimes, that is true, caused by you through your policies and the aggression against Croatia.

Q. All right. I've already seen on Television Zagreb televised that they quote you. And that's just one single sentence that they do quote to the effect that the Serb forces launched the aggression against Croatia. Do you truly consider yourself to be competent in assessing whether Serb forces did perpetrate an aggression against Croatia or whether matters were quite different?

A. I say -- I'm saying what I saw. And you will know that best, because you were in Karadjordjevo with Tudjman.

Q. All right.

THE ACCUSED: [Interpretation] Mr. May, Mrs. Uertz-Retzlaff she showed an exhibit and presented an exhibit and Mr. Kwon asked a question pertaining to it, because he received it just like myself. And he asked what the exhibit was about and what had happened to it. And the answer was that it wasn't too important, from the aspects and positions of this false indictment and false witnesses. Of course it is not important, if you look at it that way.

JUDGE MAY: [Microphone not activated]

THE INTERPRETER: Microphone, please, Your Honour.

JUDGE MAY: I'm sorry. The epithets you can leave out. We've heard them a great many times before. Now, what is it you're trying to refer to?

Just a moment. Just a moment. Ms. Uertz-Retzlaff. 21790

MS. UERTZ-RETZLAFF: Yes, Your Honour. It's Exhibit 387, tab 13. And I dropped it for time reasons.

JUDGE MAY: If you want to ask a question about, you can, Mr. Milosevic.

JUDGE KWON: Which was returned.

JUDGE MAY: Yes. We don't have our copies any more.

THE ACCUSED: [Interpretation] Very well.

MR. MILOSEVIC: [Interpretation]

Q. The title of this document are directives as to the use of the armed forces in the forthcoming period to prepare combat activities and operations. And the date is the 10th of December, 1991. "Directive on the use of the armed forces for the preparations and performance of combat operations in the forthcoming period." That is to say, after the events that we're discussing. It is signed by the federal secretary for National Defence, army General Veljko Kadijevic. And the page is 01061439. And I'm just going to quote a few portions in point 3, paragraph 3, for example. He says that the Yugoslav People's Army, together with the Territorial Defence in addition to initial weaknesses still managed to maintain its integrity and Yugoslav character.

And then he goes on to say that "This had a significant influence on deblocking our forces in the Republic of Croatia." So my question is --

JUDGE MAY: Where are we? First page.

THE ACCUSED: [Interpretation] Paragraph 3, "The Yugoslav People's Army and TO." 21791

JUDGE MAY: Yes.

THE ACCUSED: [Interpretation] He talks about the Yugoslav People's Army and Territorial Defence. "Despite certain initial weaknesses, managed to retain its integrity and Yugoslav character, and this has contributed substantially to the relieving of our besieged forces in the Republic of Croatia."

MR. MILOSEVIC: [Interpretation]

Q. So Mr. C-047, do you know that the forces of the JNA, which had been there for 50 years, were actually blocked in the Republic of Croatia and had to withdraw, they had to leave. They were there protecting the population under jeopardy, they were there to protect mutual conflicts from breaking out? Are you aware of that?

A. That is what the army was supposed to do. But the army didn't exist. It had already disintegrated in Slovenia.

Q. Well, I mentioned Borovo Selo, where through the intervention of the army the conflict was stopped and the army managed to save the group of Croatian policemen who were in Borovo Selo. Do you remember that?

A. Yes. And could you tell me what that army was composed of? The ethnic composition of the army?

Q. Now I'm not here to answer your questions. You are here to answer mine but this is information that can be checked out easily, these facts and figures. Now, what I'm asking you is this: Did the army perpetrate an aggression against Croatia or was it blocked and attacked in Croatia?

A. I don't want to enter into military matters as to what happened, when, and how. The army was on the territory of Croatia and we know why 21792 an armed conflict broke out. The Croatian civilians and in Bosnia the Muslims did not have any tanks or planes or cannons, as far as I know, to the best of my knowledge.

Q. All right. Well, you know very little. But that is not the subject of your testimony anyway. That is self-evident, quite obvious. And then it goes on to say, "Considerable influence on deblocking our forces in Croatia and accepting the initiatives of the Presidency to involve the international peace forces in Yugoslavia." This is what it says. And then I would like to move on to page 3 of that same document, which was distributed here by the opposite side. So it wasn't me who brought the document in to the courtroom.

It is point 6, or paragraph 6. It is an order by the federal secretary, dated December 1991. And paragraph 6 reads as follows: "In all zones of combat operations, place under the command of the most senior JNA officers all the units of the JNA and TO as well as volunteer units, which agree to be subordinate to that command and wear JNA and TO insignia. Consider all other armed formations paramilitaries, disarm them and remove them from the BD zone."

Well, you've heard this. So how can you claim something you said yesterday, that is, that individual volunteers who went to join up, to join the JNA, and that they wore the insignia you showed us yesterday, the insignia of the Serbian Chetnik Movement and so on?

A. Let me tell you first of all, Mr. Milosevic, this was written down on paper but it is absolutely not true. The Serbian Volunteer Guard, let me tell you, with other insignia, the White Eagles, the Serbian Chetnik 21793 Movement, the Wolves of Bosnia and so on, they all had different insignia and patches. And the second point is it is not true that they disarmed and sent back the paramilitaries. We were under the command and did report to the commands in the area we were located as a Chetnik unit. However, we did not take down our insignias. We wore them. And you armed us, the Army of Yugoslavia, I mean.

Q. The Army of Yugoslavia armed you from you members of the Serbian Chetnik Movement? Is that what you're saying?

A. Yes, correct.

Q. Well, we'll come to that in due course. But as far as I understood you yesterday, you explained to us that in Subotica you would obtain your weapons from the commander and his name, I think, was Colonel Jankovic; is that right?

A. It wasn't Colonel Jankovic. It was Jovanovic.

Q. Fine, Jovanovic, then. And then - and you can see this in the transcript - what you said was this: You said you were armed there; is that right?

A. I said who was under Colonel Jovanovic. I was in his presence when he asked to be sent weapons for Lika and he got them.

Q. You said that the volunteers were armed by Colonel Jovanovic, garrison commander in Subotica. And then Mrs. Uertz-Retzlaff asked you what happened when you arrived at the front, at the battlefield. Did you report to anybody? And you said yes, you did report to the military command there. Now -- and she asked you, "Why did you report?" And your answer was, "In order to be issued weapons, equipment, and accommodation." 21794 So Mr. C-047, in the same breath and in the space of several minutes of examination and cross-examination you first of all explained that you were armed by Colonel Jovanovic in Subotica and then in the same breath you say that once you had arrived you reported to the military command to receive weapons, et cetera, as a volunteer. Which of those two assertions is correct, Mr. C-047? Because you said both, and there is no printing error. What is true?

A. I said something quite different. I said who was with me. I said that we were in Colonel Jovanovic's apartment in Subotica, that he was provided with a list of the requests, and I saw uniforms and snipers, and they were taken from the 1st Barracks in Subotica. And the second point is that Dusko Stipanovic also took snipers from the barracks when he went to the battlefield.

Q. All right. And do you know that there was a decision by the federal organs as to how volunteers were to be taken in, received? You say something about that, and you say that they had to have the psychological and physical properties they required, that they had to be normal people, no criminals among them, and so on.

A. I don't know what you are talking about. Not volunteers.

Q. Well, do you know that there was a decision to take in volunteers according to set procedure and be deployed to the units and only in that way would they be considered to be full-fledged members of the armed forces?

A. Of course they had to be healthy. They had to have done their military service. That was the basic requirement. 21795

Q. Did you have in your hands or before your eyes this decision by the Presidency of Yugoslavia as to the procedure? It was made public in the papers.

A. I know about that, but that referred to the volunteers in the Army of Yugoslavia.

Q. Very well, then. So we've read what it says in the order of General Kadijevic, "All other armed formations should be considered paramilitary ones, should be disarmed, and excluded from combat operations."

And then the next paragraph, it says: "With all measures prevent plunder, genocide, and retaliatory behaviour. Establish the necessary control by engaging the military police and other units designated for that purpose as well as criminal judicial organs." And then paragraph 7 says: "Contacts with the leaders of various parties should be made only in accordance with the regulations in force and with the prior consent of and in consultation with the higher command. In addition, undertake steps and avoid all compromising meetings with persons and representatives of anti-army propaganda." Is this the way in which the JNA related to the events that you are testifying about?

A. I'm not aware at all that they acted in that way. Not a single volunteer unit, as far as I know, was turned back. They all wore their own insignia. As for looting and genocide, there was looting as there is in any war. The military police tried to prevent it. Nobody prevented Arkan. I don't know that any Chetnik from my unit or any area engaged in 21796 BLANK PAGE 21797 looting or genocide. I'm not aware of it.

Q. You say that they were not prevented. But towards the end of the examination-in-chief today, you said that you were in Skelani, that you left weapons there, that you were searched by the military police, that they searched everyone coming from Bosnia in order to seize their weapons. Isn't that what you said?

A. No, I didn't. I ordered the withdrawal of my unit. My unit was supposed to remain in the area of combat operations. I ordered the withdrawal. First of all, they wouldn't let us go. And afterwards, they let us go. There was a machine-gun pointed at us because we were leaving Skelani.

Q. Did anyone shoot at you?

A. No. Fortunately not.

Q. Could it be quite the opposite? Didn't they chase you away from there?

A. No, they didn't at all.

Q. Were you volunteers?

A. Yes, we were.

Q. And you went there on a voluntary basis?

A. Yes.

Q. And you returned on a voluntary basis.

A. Yes, but it was difficult to go back.

Q. But did you go back?

A. Yes, we did go back.

Q. Well, then what have the authorities and the JNA to do with that? 21798 You went there as volunteers. You returned as volunteers. They seized your weapons.

A. It's not true that they seized our weapons. They didn't seize our weapons.

Q. Well, they searched you to find any weapons.

A. They didn't seize anything.

Q. You returned with your weapons?

A. No, we returned the weapons at the school. People left their ammunition and grenades and what they had. That's what I said.

Q. But that is what I'm talking about, the facts. So you went there as a volunteer unit. You stayed there. You left your weapons. And then you returned without any weapons.

A. Yes, Mr. Milosevic. Could we go into private session to explain these things?

Q. We're wasting time. These are facts that have been covered.

JUDGE MAY: Let the witness explain things that he wants to. He should be given a chance.

Private session.

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[Open session]

THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. You provided some kind of diagram of the structure of the Serbian Radical Party and the Serbian Chetnik Movement. It is on page 6, paragraph 5. And you say, talking about Vojvodina, that everything was centralised as the level of the province of Vojvodina?

A. Everything was coming from Belgrade.

Q. I saw this table of yours.

JUDGE MAY: Tab 4. The witness can have it in front of him.

JUDGE KWON: Is it tab 4 or tab 7?

MS. UERTZ-RETZLAFF: The SRS party chart is tab 4, and the Chetnik 21801 Movement chart is tab 7.

JUDGE MAY: Let the witness have both.

JUDGE KWON: Taking advantage of some respite. I have to note the previous tab was tab 3, not 13 from the Exhibit 387.

MS. UERTZ-RETZLAFF: That's true, Your Honour.

JUDGE KWON: Yes.

MR. MILOSEVIC: [Interpretation]

Q. Let me ask you just one question with reference to tab 4, as you're explaining what was centralised. Looking from the bottom, you have one box in which it says -- from the top, "Vojislav Seselj, president." Then to the left and right, "The main board, responsible for Serbia, Republika Srpska, the Republic of Serbian Krajina, and others in Belgrade." And then "the Fatherland Administration." I don't know what the difference is between the main board and the fatherland board. But you as a member of the party probably know.

And then the next box is: "The presidency of the Serbian Radical Party in Vojvodina." Is that right?

A. Yes. The presidency of the Serbian Radical Party in Vojvodina.

A. Yes.

Q. And you say here Maja Gojkovic, president of the presidency of the Serbian Radical Party for Vojvodina.

A. Yes.

Q. Do you know that in that Serbian Radical Party of yours, as you claim, there were no provincial levels? Because that is contrary to the political programme of your party, which advocated the abolition of 21802 provinces. There are no provincial levels in the Serbian Radical Party. There is a provincial level in the Socialist Party of Serbia but not in the -- do you know that as a party?

A. Mr. Milosevic, that is not the point. Point of the Serbian Radical Party or the chain of command, if I can call it that, in the area in which I lived. That is what it is.

Q. Oh, I see. You're talking about the chain of command. Then it would appear that Maja Gojkovic was your commander, a lady, an attorney from Novi Sad. She was commander of the Serbian Chetnik Movement in Vojvodina? Is that what you're saying?

A. I didn't say that -- mean that literally, but chain of management, chain of control.

Q. You don't like whichever way I put the question to you. You drew this chart, which doesn't correspond to the truth, because there's no provincial level. You say the chain of command and the head of the Serbian Chetnik Movement for you was Maja Gojkovic.

A. It says for Vojvodina, Mr. Milosevic.

JUDGE MAY: Yes.

MS. UERTZ-RETZLAFF: Your Honour, just we are looking at the structure of the SRS party. We are not looking at the Chetnik Movement. So I think that --

JUDGE MAY: Yes. Your question is on the wrong premise, she says. Start with the Radical Party, then go on to the Chetnik Movement, if that's the point.

THE ACCUSED: [Interpretation] I have in mind the answers given by 21803 the witness. So allow me, therefore, to put some order into those answers. Because he says that is the chain of management of the Serbian Radical Party. Then he talks about the chain of command.

JUDGE MAY: It may well be that he was misled by the questions and not taking one thing at a time. Just let's ask him about it. Start, if you would, with 4, tab 4, the structure of the SRS, which is what you were originally asked about, the Radical Party. How would you describe the relationship between your own -- or the municipal board and the -- say, the president of the Vojvodina party? Now, how would you describe that?

THE WITNESS: [Interpretation] In Subotica, there was a municipal board and Subotica was the centre for several municipalities of the Serbian Radical Party, a political party, and for Northern Backa the president was Bozidar Vujic, and Ljubomir Rajic was president of the municipal board. The centre of this political party for Vojvodina - I'm talking about Vojvodina - was in Novi Sad, and Maja Gojkovic was president of the Serbian Party.

As a coordinator for Vojvodina, for a while, Jovan Glamocanin held that position, and of course I also mentioned the president of the Serbian Radical Party, Vojislav Seselj in Belgrade. That was the chain I wanted to show, the political chain.

MR. MILOSEVIC: [Interpretation]

Q. So that is not in dispute, the square that you have now -- the box that you have now explained, Maja Gojkovic, it says here, "Presidency of the Serbian Radical Party of Vojvodina. You wrote that, didn't you? 21804 That's what you think. You can think what you like. But the presidency of the Serbian Radical Party of Vojvodina does not exist, nor did it ever exist.

A. Mr. Milosevic, I don't know then where I went to in Novi Sad. I went to Maja Gojkovic's office.

Q. You could have visited her in her office or in her home, but there's no presidency of the Serbian Radical Party of Vojvodina, according to their programme.

JUDGE MAY: It's pointless arguing about it. He says there was. If you have other information, you can put it in front of us. And if it's of any great importance, we can make a decision about it.

THE ACCUSED: [Interpretation] Very well. It is important, Mr. May, as a very small point, and that is what is important is that this witness is giving us one untruth after another. That is all that is important, nothing else.

JUDGE MAY: That is what you assert. It will be a matter for us to judge.

Now, let us go on.

THE ACCUSED: [Interpretation] Mr. May, pursuant to that logic, you can rule that today is Monday. There's no doubt about that.

MR. MILOSEVIC: [Interpretation]

Q. Mr. C-047, you say - and you have it here on your chart - Maja Gojkovic was the deputy of Vojislav Seselj. Is that what you say?

A. One of the officials in Belgrade, and she was for Vojvodina.

Q. Very well. The position of deputy was introduced at the congress 21805 in May 1996, and the deputy Tomislav Nikolic and not Maja Gojkovic. She was never Seselj's deputy. You're talking about your own party.

A. Yes.

Q. So I assume it would be logical for you to know things about your own party. But you're revealing an unbelievable lack of knowledge about a party of which you say you were a member.

A. I'm telling the truth. Now, whether she was the deputy and whether the presidency in Belgrade consisted of 10 or 15 members, Maja Gojkovic was one of them and she was in Novi Sad and she was in charge of Vojvodina and in charge of the municipal and inter-municipal boards of the party.

Q. There's no doubt that this lady was an official of the Serbian Radical Party, that she lives in Novi Sad, that she's an attorney at law, et cetera. But what I called in question was your whole chart and your allegations regarding the existence of institutions which do not exist. Have you read the programme of the party that was in force ever since 1991 to this day?

A. Yes, I have, Mr. Milosevic. What -- you said there was no centralisation. I am asking you now. You said there was no centralisation.

Q. That is something quite different. I am not entering into whether I agree or disagree with it. These are not my value judgements or yours, for that matter. They don't recognise provinces. They do not have organisations at provincial level. They don't have a provincial presidency. It is contrary to their programme to have this sort of 21806 structure as you drew it.

A. I am claiming that they do have them.

Q. You are even claiming that Vujic and Radic were kums or -- I wanted that to be checked out?

A. And that too is incorrect. I know both very well. Mr. Radic is an employee of the state security. Let me tell you that too. Ljubomir.

Q. According to the information I have received, it is true that there is a Radic who's a kum to Vujic but he's not Ljubomir Radic from the DB but Gojko Radic, which has nothing in common with this person. And a best man at a wedding can with checked out in the marriage certificate. It is registered in the registrar of married couples. It's not difficult to check out. To say things just like that, as you believe will be convincing, there's no point in that.

A. Let me tell you: Mr. Radic and his kum were employees of the state security in Serbia.

Q. Very well. We can move on as far as that is concerned. I tried to put a question to you about it, but obviously your information is different.

You talk about cards of volunteers from the Serbian Chetnik Movement?

A. I never used the word "iskaznica".

Q. That is what it says on page 8, paragraphs 2 and 3.

A. The people translating this probably used their own language.

Q. It wasn't translated from English into Serbian, but I assume from Serbian into English. 21807

A. Is that important? As if you didn't know what an "iskaznica" is?

Q. As you gave such a statement, I wanted to check out what is stated in your statement. And as everything has proven to be incorrect, among other things this too that there were no "iskaznica" or membership cards?

JUDGE MAY: That's not a proper question and another comment by you. It's inappropriate.

THE ACCUSED: [Interpretation] All right. It's an inappropriate question, then, Mr. May to ask.

MR. MILOSEVIC: [Interpretation]

Q. Do you know that no way of IDs by way of "iskaznica" existed?

A. "Iskaznica" is what existed in Croatia. Whereas here there were membership cards for acceding to the membership, "pristupnica".

Q. On the basis of the information I have - and please be so kind as to confirm this or deny it - so there are no such papers. Volunteers would give their personal IDs, their military IDs, and a written statement to the effect that they were not ill physically or mentally.

A. I don't know about these illnesses, but the personal IDs, that's true. And also the military IDs, the military booklets, that's true.

Q. But they did not say whether they were physically or mentally ill or whether they were drug addicts or something like that.

A. Actually, Mr. Milosevic, I'm not a doctor.

Q. According to what you've been saying, should there be some files of volunteers in Subotica in the archives of the Serb Radical Party?

A. There should be files. I don't have anything. Had I had this and had this been found on me, the members of your state security service 21808 would have killed me a long time ago.

Q. Who was killed on the basis of what you know? Who was killed by the members of the state security service of Serbia? It's a different thing what you said about arrests. I mean, yes, arrests they would have carried out. But what about killings?

A. Mr. Milosevic, I don't really want to discuss that. It is known in Serbia what happened and who was engaged in killings.

Q. Who knows? I imagine this is something that is known.

A. I hope that this is known.

Q. Tell me, since you are linking up the MUP, are you trying to say that in the Ministry of the Interior there was some kind of a command structure of the Serb Chetnik Movement? You have this on page 7 in paragraph 3. You talk about that.

A. Yes.

Q. Can you see this?

A. Yes.

Q. Please, what kind of an invention is this fabrication? Look what it says. This is nothing that reveals who you are. You say, "Chain of command of the Serb Radical Party in the SUP was the following." And at the top there is DB Belgrade, which is to say the state security commands the Serb Radical Party; right? Does the state security command the Serb Radical Party?

A. There was cooperation.

Q. Wait a minute. What does that mean?

A. You are sticking to this word "command." I'm talking about the 21809 linkage between the leaders. The SUP, Mr. Milosevic, the top people of the SUP.

Q. All right. Please, take a look at this. I mean, I really have to read this for the public. You say: "Chain of command of the Serb Radical Party in the SUP is the following," and then it says, "DB Belgrade on the top." And then "the intercommunal SUP of the northern Backa district. And below it says Milan Jerinkic, secretary of the SUP, Northern Backa district, member of the Serb Radical Party. And then Radovan Knezevic, head of the Northern Backa SUP district, sympathiser of the Serb Radical Party. And then Mirko Zinanic, chief of SUP in fact town of Subotica, member of the Serb Radical Party. And then Nikola Ivosevic, chief operations in the Northern Backa direct, member of the Serb Radical Party. And finally -- and finally, now, let me not go into that, lest we reveal any identities. What is this, please?

A. You find this ridiculous, Mr. Milosevic, but these people are members of the Serb Radical Party or sympathisers of the Serb Radical Party. They were top people in the Northern Backa District and they were members of the Serb Radical Party.

Q. Mr. C-047, I told you that these people whose names I mentioned were not members of the Serb Radical Party. But even if things were the way you put them, even if they were sympathisers, I mean someone can be a sympathiser of the Red Star Soccer Club and somebody else of the Partisan Soccer Club?

JUDGE MAY: Wait a minute. You will conduct this in an orderly way. Are you suggesting that the witness is wrong when he says that these 21810 BLANK PAGE 21811 people were members of the Serb Radical Party? Is this the point of all of this?

THE ACCUSED: [Interpretation] There are two points, Mr. May: One is that this is a lie; the second point is that even if it were not, what kind of chain of command is this of the Serb Radical Party and the SUP? Because you say that the DB, the state security, is on the top.

JUDGE MAY: Let the witness -- the witness can now deal with this. You've already told us that -- what the witness -- what the accused says is wrong and in fact these people were members of the Serb Radical Party. So there's no need to repeat that. But the other point is this: You are being asked about what sort of a chain of command was it with the Serb Radical Party and the SUP. Was the DB on the top? Now, you can answer it, and if you want you can answer it in this -- if you prefer, you can answer in a private session.

THE WITNESS: [Interpretation] It would be better to go into private session.

JUDGE MAY: Yes. We'll go into private session.

[Private session]

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[Open session]

THE REGISTRAR: We're now in open session.

THE ACCUSED: [Interpretation] Does that mean that we are going to adjourn for the day, that we are not going to put any more questions today? Or should I just complete this topic that I've been dealing with now?

JUDGE MAY: No. We've got to finish, because there's another hearing coming into this courtroom.

Witness C-047, that concludes your evidence for the moment. We 21813 will try and reach you tomorrow, to try and finish it. The accused has an hour and a quarter left for cross-examination. We will try and, as I say, fit that in tomorrow if we can. But meanwhile, we will go on with B-024, and then B-1098.

We'll adjourn now until 9.00 tomorrow morning.

--- Whereupon the hearing adjourned at 1.47 p.m., to be reconvened on Thursday,

the 5th day of June, 2003, at 9.00 a.m.