⁴³⁴³²

Wednesday, 31 August 2005

[Open session]

[The accused entered court]

[The witness entered court]

--- Upon commencing at 9.02 a.m.

JUDGE ROBINSON: Mr. Milosevic, you are to continue with your examination-in-chief.

WITNESS: VOJISLAV SESELJ [Resumed]

[Witness answered through interpreter] Examined by Mr. Milosevic: [Continued]

THE INTERPRETER: Microphone, please.

THE ACCUSED: [Interpretation] I beg your pardon.

MR. MILOSEVIC: [Interpretation]

Q. Mesic, during his testimony, was asked, that is on page 10572 of the transcript, to ask the -- he was asked to explain the financing of the JNA. He was asked by the other side to ask what he knows about financing the JNA, what budget it came from, and who had control over this budget. First and foremost, how the JNA was financed.

He explained, inter alia: "[In English] This was from the revenue of the federation. The original revenue of the federation. Croatia and other republics were against this because they wanted to keep the original revenue within the republics."

[Interpretation] Do you know about that? Do you know what happened at the time concerning financing the JNA from the federal budget, and on the basis of what this kind of position was taken in particular ⁴³⁴³³ republics and why? What was the motive for taking such a stand?

A. The Yugoslav People's Army was always financed from the federal budget. All republics paid a certain quota, as is done in any budget. This quota depended on the population of a respective republic and the degree of economic development.

Slovenia and Croatia, on the very eve of the war, tried not to contribute to the federal budget at all, therefore to the JNA as well. However, that was unconstitutional and unlawful behaviour. The Socialist Federal Republic of Yugoslavia, according to the constitution in 1974, had very few powers of its own, but foreign policy and defence were its sole and basic powers. Also, customs duties and a few other things, but those were the two basic ones.

Q. Further on, he says -- the question is actually: "[In English] Had there been a time when Croatia's contributions to the republican budget for the purposes of the JNA ceased?"

A. As far as I remember, it stopped sometime after Tudjman came to power but I cannot tell you exactly when.

Q. This is the explanation that he gives: "Croatia made this decision at a point in time when the army was [In English] in the service of the aggressors, when it was working on creating a Greater Serbia [Realtime transcript read in error "Great Britain"], and so Croatia could no longer continue paying this army to its own detriment." [Interpretation] Now, my question to you, Mr. Seselj, is the following: This pertains to 1991. That is the next page, 10573.

JUDGE ROBINSON: Just a minute. There's a mistake in the ⁴³⁴³⁴ transcript. Instead of "Greater Serbia," we have "Great Britain."

THE WITNESS: [Interpretation] It says "Greater Serbia" in the transcript I'm reading from. Oh, this transcript from here. It is equally convincing.

MR. MILOSEVIC: [Interpretation]

Q. All right. I guess it's been corrected. It says here on this page 10573: "[In English] By the time that we are dealing with, the middle of 1991 or late in 1991, were Croatian representatives still on the board of governor --" [Interpretation] on the board of governors of the National Bank?

So he explains that mid-1991 was the time when financing the army stopped because the army was working on the creation of a Greater Serbia. Can you remember who was federal Prime Minister throughout 1991 and who held all the main federal posts in 1991?

A. The federal Prime Minister in all of 1991 was a Croat, Ante Markovic, and his government was in place sometime until June 1992. However, as far as I can remember, the Croatian contributions to the federal budget stopped already in 1990 because the regime of Franjo Tudjman started using that money for illegally arming Croatian paramilitary formations.

The first idea that Franjo Tudjman had was that the Territorial Defence of Croatia should be turned into the army of a separate Republic of Croatia. However, the Yugoslav People's Army reached a timely decision to take over all the arms depots of the Territorial Defence in all republics and in this way Tudjman's intention was thwarted. Then Tudjman ⁴³⁴³⁵ established the so-called National Guards Corps, the ZNG as it was called, and he started buying or receiving gifts of large quantities of weapons from foreign countries. Most of the weapons arrived in convoys via Hungary. Most were from the depots of the former --

JUDGE ROBINSON: [Previous translation continues] ... thank you, you answered the question.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, in that year 1990 or 1991, or generally speaking, when Mesic was the presiding member of the collective Commander-in-Chief and then Ante Markovic from Croatia as well was the federal Prime Minister, were there any signs of the JNA doing anything against Croatia?

A. No, there was no such thing. However, those two Croats in the top state leadership, Ante Markovic and Stipe Mesic, insisted the most on the Yugoslav People's Army intervening in Slovenia, and a decision was reached by the federal government that the army should take over the border posts in Croatia --

THE INTERPRETER: In Slovenia, interpreter's correction.

THE WITNESS: [Interpretation] -- and JNA units went there without any ammunition. That is when JNA soldiers were massacred in Slovenia, and then there was a real military intervention that did not take very long. Stipe Mesic and Ante Markovic wanted to fully compromise the JNA. As far as Slovenia is concerned, no one in the remaining part of Yugoslavia had any reason to prevent Slovenia from seceding, because there were no ethnic squabbles there. Slovenia, as a federal republic, took up the territory exactly where the Slovenian people lived. It is only ⁴³⁴³⁶ Slovenia itself that could have had territorial aspirations towards Croatia because part of the Slovenian people lived in Croatia and they were systematically being turned into Croats.

As for Slovenian separatism, had there been a goodwill, it was possible to reach agreement at federal level. However, Stipe Mesic and Ante Markovic did not allow that. It was in their interest to have an armed conflict in Slovenia, for the army to be compromised there, so that --

JUDGE ROBINSON: Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. Are you aware of any case when the JNA - now let's leave Slovenia aside - that the JNA anywhere at the time in -- even in Croatia, intervened at any place where it was not attacked or where it went out to separate the parties that were in conflict?

A. No.

JUDGE ROBINSON: Thank you. That's the answer. No, you're not aware.

Next question, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. I shall try to avoid these long quotations from the transcript. That seems to be too long. So I shall try to summarise the statements of various witnesses in these transcripts.

Stipe Mesic, on the 2nd of October, 2002, that is page 10639 in the transcript, he said, when referring to you personally, that the Serb minister who was in government was one of the ministers of Mr. Milosevic, ⁴³⁴³⁷ that he visited the Karlovac-Karlobag-Virovitica border together with the Chetnik vojvoda Vojislav Seselj in order to show how far the interests of Serbia went. Is that correct, Mr. Seselj?

THE INTERPRETER: Interpreters note: Could the speakers please pause between question and answer.

JUDGE ROBINSON: Mr. Seselj and Mr. Milosevic, if you look at the transcript, particularly Mr. Milosevic, the interpreters are asking you to observe a pause between question and answer. It particularly applies to Mr. Seselj who doesn't wait at all.

This is not a conversation in the living-room between Mr. Milosevic and yourself. We have interpreters, and they have the job of interpreting what you say. So be a little patient, observe the pause, so that we can have the best results from them. Yes, Mr. Seselj.

THE WITNESS: [Interpretation] Since this morning I've really been trying to speak as slowly as possible, Mr. Robinson.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj --

JUDGE ROBINSON: It's not just speaking slowly. It's observing the pause after Mr. Milosevic's question so that the interpreter will have a chance of interpreting what he says before you speak. But we also want you to speak slowly.

THE WITNESS: [Interpretation] First of all, a border was never established on the Karlobag-Ogulin-Karlovac-Virovitica line. This is part of the ideological programme of the Serb Radical Party. Secondly, I never toured that particular line with any minister or ⁴³⁴³⁸ did I tour any front line with any minister from Serbia or Yugoslavia. And thirdly, never in my life was I in Ogulin. Never in my life was I in Karlovac. Never in my life was I in Virovitica. And once in my life I passed through Karlobag when I travelled from Zadar via Gospic to Bosnia. Once in my life, sometime in 1975, if my memory serves me well. So this is totally an invention on Mesic's part.

Q. As for financing the army, Mesic explained that when they stopped financing the army, that the army took credits from the National Bank of Yugoslavia and the National Bank of Yugoslavia was under my control. Do you know how the National Bank of Yugoslavia functioned and who made up the board of governors of the National Bank of Yugoslavia in 1991?

A. The board of governors of the National Bank of Yugoslavia consisted of representatives of all federal states. It was absolutely impossible for you to exercise control over the National Bank of Yugoslavia.

The National Bank of Yugoslavia was to a large part under the control of the government of Ante Markovic. Ante Markovic, at the beginning of 1990, even carried out a monetary reform, and then he made it possible to sell foreign exchange freely from the reserves of the country. Since Slovenia and Croatia had the largest quantities of this money that was on bank accounts - not banknotes but simply money that was on bank accounts, electronic money as we might call it nowadays - most foreign exchange was bought by Slovenians and Croats from the federal foreign exchange reserves, which were -->0 billion. So the coffers were depleted very quickly. Slovenia and Croatia were getting ready to secede, ^{43439 BLANK PAGE 43440} and they were in a hurry to get as much foreign currency as possible from the federal reserves. This caused an even deeper economic crisis in Serbia, Bosnia, Montenegro, and Macedonia.

Q. On the 2nd of October, 2002, that is page 10674, he said that in Serbia there were 18 camps where Croat citizens were held and that they were fleeing from Seselj.

A. That is a total fabrication. There was not a single camp in Serbia where Croat citizens were put up.

At the beginning of the war, it was only the JNA that had Croatian prisoners of war, members of paramilitary units who were taken prisoner after fighting. For a while they would put them up at the correctional facility in Sremska Mitrovica. That is one of the prisons in Serbia that is one of the better equipped prisons, with better facilities and so on. It is far more comfortable, say, than the prison in Pozarevac. As far as I know, prisoners of war were never taken to Pozarevac. However, this went on for a very short period of time. I think that all these prisoners of war were released very soon and unilaterally at that.

Q. At the time when the JNA used part of the prison facilities for that purpose, were these facilities under the control of the Ministry of Justice of Serbia or under the control of the JNA?

A. To my knowledge, JNA control. Part of the prison was separated and put under the control of the JNA command in charge. Prisoners of war, according to our regulations, could not be sent to civilian prisons. They were not detainees, they were prisoners of war. The difference in status is a major one. ⁴³⁴⁴¹

Q. Again, on the 3rd of October, that is to say the following day, in his testimony on page 10782, he says one minister came to the Karlovac-Karlobag-Virovitica line in the company of Vojislav Seselj whose units were also in the area. There are a few questions there, but there is one basic question: Did you have any military units at all; and if so, as Mesic says, were you in the area?

A. I never had any military units. I never toured the area, as Mesic claims. And all volunteers of the Serb Radical Party were within the JNA. They were in Western Slavonia, and they were at part of the western front, in Lika approximately. They were transported there by military aircraft to the Udbina air field and then were deployed from there. It was the JNA commands in charge that deployed them.

It is not serious to testify in that way. Mr. Mesic is the president of a republic. He could have at least made an effort to try to find out from the services that he is in charge of to find out what name of that -- what the name of that minister is. He is not serious for a head of state to say a Serbian minister. Whenever I speak here I make an effort to --

JUDGE ROBINSON: Thank you.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, we are now going to deal with some other witnesses that were called here. Nikola Samardzic testified here. Do you remember who Nikola Samardzic was?

A. If I remember correctly, he was a minister in the government of Montenegro. ⁴³⁴⁴²

Q. He stated that my policy was the creation of a Greater Serbia, and he spoke about the Karlobag-Karlovac-Virovitica line, and he said that you were my candidate for the president of this kind of Serbia. Do you have any comment on this? We're talking about his testimony of the 10th of October, 2002. As for the page of the transcript containing this testimony of his, it is page 11427, 11428, and 11429.

A. I've never heard anything so stupid in all my life that I was your candidate for any office let alone the top office in the land. I didn't even want ministers from my party to join a coalition government with you in 1993 let alone that you would be counting on giving me even higher office.

Secondly, you absolutely had nothing to do with the concept of a Greater Serbia. The concept of a Greater Serbia and the western Serbian boundary along the Karlobag-Ogulin-Karlovac-Virovitica line is purely an ideological project of the Serb Radical Party. No other political party ever stood behind that project, never.

Q. [No interpretation]. Mr. --

JUDGE ROBINSON: [Previous translation continues] ... any translation. I didn't hear the translation of --

THE INTERPRETER: Can you hear now?

JUDGE ROBINSON: Yes. I'm going to ask Mr. Milosevic, then, to repeat the question.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, Milan Babic testified here as a witness, and he stated that Martic was my man and Goran Hadzic was his yes man. Do you know ⁴³⁴⁴³ anything about that from the time when you met both Martic and Hadzic? We didn't mention them, apart from going through that list of participants in the joint criminal enterprise.

A. That's absolutely untrue. The truth is that the public sentiment in Serbia was always in favour of Milan Martic, because the public thought of him as the better and the more honest man. He was not a great statesman, but he was known to live very modestly, that he was never bent on any sort of crime, that he is a very honourable and courageous person, and that explains the popularity he had among the Serbian people, the entire Serbian people.

As a statesman, Milan Babic was much more capable than Milan Martic. However, his public image was always tainted by hints of low morality.

Q. On pages 13671 to 679, Milan Babic stated that I bought weapons.

A. That, too, is nonsense. In 1991, there was a press conference where I released a propaganda balloon, so to speak, saying that volunteers of the Serb Radical Party purchased weapons through Hungary. It was an allusion to the fact that Croats were buying weapons from Hungary, and I was -- this was a tit-for-tat sort of thing. That caused a great public outcry and indignation, and I remember that even investigation was started to see if one of the ministers was involved.

The truth was very different. The truth was that most of our weapons came from the depots of the Territorial Defence. They were obsolete Thompsons, and later they were weapons of JNA issue. That's what you do in politics. You say something for propaganda ⁴³⁴⁴⁴ purposes, and that causes an effect.

JUDGE ROBINSON: Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. Milan Babic says on page 13803 of the transcript, and I want to ask you if it's correct, that the JNA was protecting only the Serbs while assaulting all other ethnic communities. Is that true what he says, that the JNA protected only Serbs and attacked everybody else?

A. For several months the JNA was completely passive, without responding at all to the attacks of Croats on JNA barracks, depots, and even JNA personnel and families of personnel on the territory of Croatia. JNA was engaged in preventing armed conflict between Territorial Defence members and Croatian paramilitary units. It stood between the warring parties and tried to put an end to hostilities.

It was only in August 1991 that JNA got involved into a real armed clash when the attacks on its units became massive and frequent and caused great casualties.

Q. Babic stated here on the 19th of November, 2002, page 13051 and 052, that I gave you orders as to what your party should do because I thought of you as one of the greatest patriots at that time, and that continued all the way to our personal conflict in 1993.

A. Well, I would like to think that you did think of me as a patriot always, even at the time when we clashed personally, but it is silly to say that you gave me orders at any stage of our relationship, whether it was good or it was strained by tension and conflict. All of Serbia knows that. ⁴³⁴⁴⁵

Q. Mr. Seselj, the entire Serbia also knows the kind of farce we are participating in with this indictment of Mr. Nice's.

MR. NICE: That's a remark --

THE INTERPRETER: Interpreter's note: Mr. Seselj has to stop answering while Mr. Milosevic is speaking.

JUDGE ROBINSON: Yes. Mr. Milosevic, the comment that you made is entirely inappropriate.

And, Mr. Seselj, you must observe the pause. The interpreters have just made another request. In fact, you start responding even before Mr. Milosevic has finished his question. That is -- that is normal in ordinary conversation in a living-room, but here we have technical matters to attend to and you must observe the pause, otherwise it's exceedingly difficult for the interpreters.

Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. On the 18th of November, 2002 - and that's on transcript page 13052 to 13054 - Milan Babic described your visit of the 2nd May, 1991. That's the occasion when he said -- when you were said to use a JNA helicopter organised by Minister Marko Negovanovic, and you were said to ask for that helicopter calling from the office of Milan Babic.

A. That's untrue, beginning with the date. On the 2nd of May, I was leading the peace march to Plitvice, although Milan Babic was initially the leader. But when he saw the soldiers with their rifles cocked, he got frightened and retreated to the back of the column. I travelled by helicopter from Knin in November 1991. ⁴³⁴⁴⁶ About the office of Milan Babic, it's true that I called Marko Negovanovic from that office, but I called him as chief of General Staff, whereupon Marko Negovanovic told me to call General Vukovic, who I think was commander of the Knin Corps at the time. General Vukovic invited me to his staff, to his headquarters. I went there. From his headquarters I also talked to Colonel Mladic, and then General Vukovic provided me with a helicopter to go to Mostar. He announced my arrival, and in Mostar another helicopter waited for me. Those were small helicopters, Gazelle type. It was impossible for me to go directly from Knin to Belgrade or from Knin to Podgorica, so I went from Knin to Mostar, from Mostar to Podgorica, and from Podgorica I took a commercial line to Belgrade.

Q. I think you gave us an exhaustive answer. Just tell me, because I didn't remember correctly, did you say that Marko Negovanovic was chief of General Staff or assistant chief?

A. I think he was actually deputy chief of General Staff. At any rate, he wasn't the minister of defence of Serbia. The defence minister at the time was Mr. Simovic.

Q. We had another witness here, Jovan Dunic [as interpreted]. He testified to an event in Vukovar. Do you know the name of Jovan Dulovic.

THE INTERPRETER: Interpreter's correction: Dulovic.

MR. MILOSEVIC: [Interpretation]

Q. Have you ever been in contact with him?

A. It's possible that I have been in contact with Jovan Dulovic once, but it was after the war. He was a correspondence of Ekspres Politika newspaper from Vukovar for the duration of the liberation struggle for ^{43447 BLANK PAGE 43448} Vukovar, and he wrote reports full of praise for the fighters of the JNA and the volunteers of the Serb Radical Party. And then sometimes -- sometime in 1995, he became a journalist of the spying agency that is the Vreme magazine in Belgrade. It has been published since end 1990, with a very small circulation, 5 to 6.000 copies, but it is continuously financed by Western intelligence services and various other Western agencies and branches. When he joined the Vreme magazine, he changed his ideological perceptions completely and started taking part in the anti-Serb propaganda political campaign.

I provided the Office of the Prosecutor, in the course of proceedings against me, two documents to announce my special Defence, as stipulated by the Rules of Evidence and Procedure. In those two documents I provided a wealth of intelligence data that I got hold of through my men in the state security service. This intelligence is highly confidential.

JUDGE ROBINSON: Mr. Seselj, I'm stopping you because I believe you have answered the question. It's for Mr. Milosevic to put another question.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, this intelligence that you provided, what does it have to do with? What is it related to, and what does it have to do with Jovan Dulovic?

A. Well, from this intelligence one can see that Jovan Dulovic was engaged in subversive and spying activities for the benefit of various Western intelligence agencies. I provided these documents to the Office of the Prosecutor and published them also in my book called The Devil's ⁴³⁴⁴⁹ Apprentice, The Criminal Roman Pope John Paul II. The Prosecutor who is in charge of my case can tell you this. It has been translated into English and the Prosecution can easily get hold of these documents. These documents completely disqualify and discredit both Jovan Dulovic and Mr. Anastasijevic.

Q. Let us deal with some of these assertions. I have a note here regarding the testimony of Anastasijevic as well. Tell me about this salto mortale by Jovan Dulovic. It happened in 1995.

A. Yes. That's when he got on the payroll of Western intelligence agencies.

Q. He testified here and he mentioned the date of the 12th of November, 1991. He was testifying about Vukovar. So on the 12th of November, 1991, according to his testimony, there was a meeting between you and Mr. Radic, a JNA officer; Mr. Bojkovski; and Stanko Vujanovic. Those are the people he mentioned. And some other officers were involved, plus this witness Jovan Dulovic, who says that he attended personally that meeting where you stated, "All of us are one army." I don't see what's so special about saying this, "All of us are one army."

JUDGE ROBINSON: Mr. Milosevic, put the question and stop the comments. What is the question?

MR. MILOSEVIC: [Interpretation]

Q. So on the 12th of November, 1995 -- 1991, correction, there was this meeting allegedly with a group of officers. Do you remember that meeting? ⁴³⁴⁵⁰

A. Jovan Dulovic is making all that up. There was no such meeting, quite simply. I toured the entire town of Vukovar up to the front lines. I went everywhere, and I met with all sorts of people. But the only real formal meeting I had with officers took place when the then Colonel, currently General, Mrksic organised a dinner for me in his commander tent. There was his ADC Colonel Panic, another group of officers, there could have been Sljivancanin, there could have been Radic, and there was no other meeting at all. However, I have a different piece of information. In the case against me as part of the public documents, Dulovic asserts that he did not attend the meeting. He says he was standing on the stairs, that the door was open, and that's how he overheard the conversation. As for the statement itself or, rather, the testimony itself, I absolutely do not trust people who claim they can remember such things 15 years later. But it's true that everywhere where I went to tour the front line -- Mr. Robinson, this is very important because I am --

JUDGE ROBINSON: I've stopped you. Let Mr. Milosevic elicit it from you.

MR. MILOSEVIC: [Interpretation]

Q. You have just explained that he overheard that standing on the stairs, and you say that this meeting was held in a tent.

A. Yes. And I claim that Jovan Dulovic did not attend that dinner. And as for my position, my general position, I have always been against paramilitary units everywhere and anywhere, and I always insisted that all fighting men be within the JNA, and that could be an explanation for my statement, "All of us are one army." "We are all one army." That's what ⁴³⁴⁵¹ I said in the media and everywhere. I was in favour of the preservation of the JNA and against any paramilitary formation.

Q. Since it was unclear here what in fact he said, I have to quote from the transcript, practically at the insistence of Mr. Robinson, because it's not clear what he said. He mentioned the date of the 12th of November. I'll skip most of his testimony, and I'll start with the passage where he mentions you. That's on page 11683. "[In English] Did there come a time when the person you've described as Vojislav Seselj arrived at that house?" "Yes."

[Interpretation] I'll skip. It was 6.00, 6.30 p.m. "[In English] He came with his entourage. They were armed." [Interpretation] So he talks about the fact that you had arrived at some house where the officers I mentioned were already gathered. Radic and others. Sljivancanin seems to have come by. Sasa Bojkovski and many other officers.

"[In English] [Previous translation continues] ... detachment attending meeting."

[Interpretation] So all those people were there when you came with armed people accompanying you. Is any of that description correct?

A. It's absolutely impossible that such a meeting took place. I don't exclude the possibility that I entered a house. I entered many houses of the Serbs living there. People invited me in. I wanted to see how people were living under wartime conditions. During my stay, for example, a mine exploded and killed a soldier ⁴³⁴⁵² who was riding either a bicycle or a motorcycle, and he resided nearby. He was a local man from Vukovar. So I went to visit his family to express my condolences.

There were many encounters, but there was no meeting apart from this dinner in the command tent of the then Colonel, now General, Mrksic. I assert that decidedly.

Secondly, I was armed. I had an automatic rifle. I wore a uniform. I was always accompanied by several soldiers, by several volunteers. I had only one person escorting me from Belgrade, Petar Panic. He was my personal escort at the time. Nobody else had arrived with me from Belgrade. But I was always surrounded by soldiers, and I visited all the front lines.

Q. So the people you were with were not your escort, they were simply people you were having conversations with.

A. I had only one person escorting me who came from Belgrade, Petar Panic. There may have been a driver as well. I can't recall precisely now. But I usually drove my own personal car wherever I went, even to the front lines.

Q. He was asked by the other side: "[In English] Can you describe what happened when Mr. Seselj entered the building?"

[Interpretation] And then he goes on to explain: "[In English] Together with the officers, with Radic and Bojkovski and Stanko Jovanovic as well as some other officers from artillery units, he went into the largest room in that house where a meeting was held." "Where were you when this meeting was being held?" ⁴³⁴⁵³ [Interpretation] Answer: "[In English] The table was right next to the door, and I was at a table right next to the door of that room. The door was slightly ajar, and one could hear what was being said inside. "Were you able to hear Mr. Seselj when he spoke during the meeting?

"Very clearly. "And were you able to identify -- the voice that you heard clearly, were you able to identify it as the voice of Mr. Seselj? "Absolutely."

[Interpretation] Then he goes on to explain in answer to the question of whether he heard what you said and whether he noted down your words, he says: "[In English] Yes.

"How did you record his words? [Interpretation] He explains that he still has your words in his notebook, as it says here, and that he can repeat them.

JUDGE ROBINSON: Time for a question, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. So this is a very lengthy explanation. He's explaining where his notebook is but he didn't bring it to Court, and he quotes what you said. And that's on page 11687.

"[In English] 'We are all one army. This war is a great test for Serbs. Those who pass the test will become winners. Deserters cannot go unpunished. Not a single Ustasha must leave Vukovar alive.'" [Interpretation] Did you say this, Mr. Seselj, what Dulovic says here? ⁴³⁴⁵⁴

A. Dulovic, while reporting from Vukovar, wrote that I insisted that soldiers, primarily volunteers, be extremely disciplined, that I was against drunkenness, and so on.

JUDGE ROBINSON: Mr. Seselj, the question was did you say what Dulovic has attributed to you, which is: "This war is a great test for Serbs. Deserters cannot go unpunished, and not a single Ustasha must leave Vukovar alive." Did you say that?

THE WITNESS: [Interpretation] The statement itself makes no sense because there was no meeting. Much of what Dulovic said corresponds to my positions and my public statements, but he couldn't have quoted my precise words. You're putting a question to me based on a fabrication whether I said this at a meeting which I say never took place.

JUDGE ROBINSON: Thank you. Mr. Milosevic, you have the answer.

JUDGE BONOMY: Well, I certainly don't have the answer, I don't think. I thought you indicated that there was a meeting and that he was listening to this meeting from a position he should not have been in. Are we now talking about a different event?

THE WITNESS: [Interpretation] No. I said there was a dinner in the command staff of Colonel Mrksic. Dulovic was not present, and Dulovic is not testifying about that dinner. He claims there was another meeting apart from this meeting where I made a statement like this, in somebody's house. And this is a fabrication. There was no other meeting. There was only the meeting in the tent of Colonel Mrksic.

JUDGE BONOMY: Is it possible that these things were said at the dinner you're referring to? ^{43455 BLANK PAGE 43456}

THE WITNESS: [Interpretation] I didn't hold political speeches at that dinner. It wouldn't have made any sense. At that dinner we discussed how the operations were progressing, what the problems were, what was going on on the ground. These were all high-ranking officers. Why should I make speeches to them saying we're all one army and so on and so forth? We had serious matters to discuss.

JUDGE BONOMY: Can I ask you the question again: Is it possible you said that at the meeting or at the dinner? Yes or no.

THE WITNESS: [Interpretation] Not at that dinner. These are very general things. I could have said that elsewhere but not at that dinner.

JUDGE ROBINSON: Well, did you ever say those words at any time?

THE WITNESS: [Interpretation] That we're all one army, that was my general political standpoint. It was also my standpoint that the Ustasha had to be defeated, that not a single Ustasha could leave alive but that they should all be caught. And if they were caught alive, they should be tried. I advocated in public that they be tried. I made statements on Serbian radio in Vukovar, calling on Croatian policemen and paramilitary men to surrender, saying that they would be guaranteed the kind of treatment that is provided for in the regulations and the treatment of prisoners of war. Those are things I said in public and on Radio Vukovar.

JUDGE ROBINSON: Thank you. Thank you. Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Very well. You have explained the motives and the background. You have also provided a document where one can establish how credible this witness is and how reliable. Let's move on, Mr. Seselj. ⁴³⁴⁵⁷ Borislav Jovic said here that the Serb Yugoslav leadership never wanted a Greater Serbia and that there were three options, and those were, first to preserve Yugoslavia through constitutional changes; second, should Yugoslavia dissolve, organise a referendum at which nations would be given the right to self-determination; and thirdly, ensuring equality for Serbs in republics outside Yugoslavia.

He testified on the 19th of November, 2003, and this is on pages 29215 to 29216 of the transcript. He mentioned those three options. I hope you remember what I quoted to you.

Is this correct?

A. Basically it's correct, because in Yugoslav constitutional legal theory and practice, there was never any mention of the right of federal units to self-determination, including secession. There was only the right of nations to self-determination. But this did not include secession, because this was considered to be a one-time right and that all the nations in the former Yugoslavia had used that right after World War II when they opted to live in Yugoslavia as a federal state of equal republics.

JUDGE BONOMY: Can I ask you, Mr. Seselj, how that fits with the views you've expressed this morning about Slovenia?

THE WITNESS: [Interpretation] I'm telling you my views. On the other hand, in a situation where the country was facing dissolution, the question arose as to whether Slovenia should be kept within Yugoslavia by force, and yet there were no unsolved ethnic issues there. To start with, the position of the majority political factors was ⁴³⁴⁵⁸ that Slovenia should not be allowed to secede either. I was the first to advocate granting that right to Slovenia.

JUDGE BONOMY: But is the short answer that you would say that you accepted the basis for Slovenia seceding, but strictly speaking, their secession did not fit with the legal regime? They ought to have followed a different course, but because of the make-up of the population, you accepted that what they did was not unreasonable?

THE WITNESS: [Interpretation] It was unlawful, there is no doubt about it. But to avoid war, in my view it was better to let Slovenia go peacefully than clash with the Slovenian people.

JUDGE BONOMY: I understand. Thank you.

MR. MILOSEVIC: [Interpretation]

Q. So you agree with what Jovic said here.

A. Basically, yes.

Q. So this was true. Was it also true what Jovic said here? It's on page 29272 of the transcript, that the political leadership, our political leadership was afraid there would be a genocide of Serbs in Croatia, as had happened previously in history.

A. That's what all Serbs were afraid of. This was a pervasive fear throughout the entire Serb people, because Tudjman openly expressed his will to have continuity with the former Independent State of Croatia, which was Hitler's satellite state. He revived this ideology. He said that this fascist creation had been the expression of the historical aspirations of the Croatian people, and after that, everything was clear to the Serbs; the Serbs could expect nothing good from Tudjman's state. ⁴³⁴⁵⁹ There was --

JUDGE ROBINSON: Mr. Milosevic, we have been through this already.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Jovic said here, and this is on page 29380 and 381, that in Cleveland in February 1990, Tudjman said that the main goal of his party was to separate Croatia from Yugoslavia. In February 1990, Tudjman was not in power yet.

Do you recall this statement made by Tudjman in Cleveland?

A. I remember Tudjman's tour in America and Canada, all of it, and this was not the only such statement he made. Wherever he spoke, this was the position he advocated. It was part of his election campaign and his platform. On the basis of this, he collected vast sums of money from the Croatian Ustasha emigres community. He also made such statements in Croatia.

Q. To complete Mr. Jovic's testimony, he said, and that's page 29273 and 4, it's a political standpoint that was pervasive at the time, that Croatia and Slovenia had been recognised too soon by Germany and this speeded up the crisis and led to war.

Is this your understanding of the events at that time?

A. I think Borisav Jovic overlooked a fact here. It was the Vatican that first recognised the independence of Croatia, followed by Germany. But it did speed up the course of events leading to war and the dissolution of Yugoslavia.

This recognition took place after the adoption of the Vance Plan, when a peaceful solution had to be sought. Something similar happened in ⁴³⁴⁶⁰ Bosnia. The Cutileiro Plan was adopted, and right after that independence was recognised and war broke out.

So those who, after the adoption of peace plans, unilaterally recognised independence in an unlawful manner because it could not be recognised if the central government did not have control over the entire territory under international law, so that independence could only have been recognised on the territory not including the Krajina. Therefore, those who did this unilaterally, first the Vatican, then Germany, then the European Community and then America, they caused new wars.

Q. On page 292738 and 9, Jovic said that I opposed the establishment of a Serb army. Can you challenge this or confirm it? And also answer the question of who in Serbia was in favour of establishing a Serb army.

A. All those in authority in Serbia were opposed to the establishing of a Serb army. They all fought for the preservation of Yugoslavia and the JNA, including you personally and your party. However, the situation was different among the opposition parties. In the opposition, it was only the Serb Radical Party that was in favour of preserving the JNA, but we also advocated the reform of the JNA, primarily the removal of communist symbols. The pro-Western political parties wanted to abolish the JNA and form a Serb army because they wanted Serb separatism, and on the other hand they wanted to create a basis for Serbia and the government in Serbia if a Serb army set up --

JUDGE ROBINSON: Thank you. Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. A minute ago when talking about Dulovic, you mentioned Dejan ⁴³⁴⁶¹ Anastasijevic, another witness here. He testified here first as K1 and later on under his own name. He said that he interviewed you several times. He said that you were my nationalist satellite and that on one occasion you said to him that in the period from 1991 to 1992 you had very close friendly relations with Jovica Stanisic and that your cooperation with him pertained to the organisation of paramilitary formations in Croatia and Bosnia. You can find that on 11480 and 481, those pages of the transcript, the evidence given by Dejan Anastasijevic. What can you say about that?

A. Dejan Anastasijevic first of all was a spy of the State Security Service of Serbia. Then Western intelligence agencies took him over. And that is not the only such example. That was the case of Goran Svilanovic and some others.

Secondly, I've already said that I first met Jovica Stanisic in November 1992. However, in 1993, when there was a fierce clash between the Serb Radical Party, the Socialist Party of Serbia -- and the Socialist Party of Serbia, I launched an all-out propaganda offensive against you personally and against the Socialist Party of Serbia and Jovica Stanisic as head of state security. I have to say here quite openly that in this propaganda offensive I did not choose my methods to tarnish your name, insult you in public, to do anything that would cause hatred and rage on your part. I had a direct reason for doing that. Your party first attacked me in a press release, that I was a criminal, that I was a madman, that I was an alcoholic. I, who perhaps just have a sip of alcohol a few times a year. ⁴³⁴⁶²

JUDGE ROBINSON: Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. What was it that you wanted to say in connection with what he said here, that you had an excellent relationship in terms of engaging paramilitaries in Bosnia and Croatia?

A. Jovica Stanisic, as head of the state security, after the head-on clash between our two parties, started arresting volunteers of the Serb Radical Party, and he started issuing press releases to the effect that they were arrested as criminals, and they would find one or two pieces of weapons on each and every one of them. The state television showed footage of some arms depots found God knows where. All these volunteers who were arrested were accused of being war criminals. That is what was said to the public. What happened was that a month later they would be released. None of them were ever prosecuted. I think that some of them were punished for misdemeanors, though. The state security service in this way arrested volunteers for no reason whatsoever, and that is why I pulled all stops as far as Jovica Stanisic was concerned. Whatever first came to mind is what I said about Jovica Stanisic in public. He was the most powerful man in the secret service. He was considered to be the most powerful person in Serbia. Many people said that he was the most powerful person after you. And I really pulled all stops. I did not choose my methods of attacking him. Now, perhaps this Hague Prosecution wrote indictments against you and Jovica Stanisic on the basis of press articles or my own statements. However, that will make it easier to challenge their indictments. So -- ^{43463 BLANK PAGE 43464}

JUDGE ROBINSON: Thank you. Next question.

MR. MILOSEVIC: [Interpretation]

Q. What Dejan Anastasijevic says, namely that he interviewed you several times, is that correct? Why do you think he is not a reliable witness?

A. As far as I can remember, we had only one conversation. You know, I cannot remember exactly what he looked like when I talked to him because I talked to a multitude of journalists. At any rate, he did interview me. That interview was published in the Vreme magazine and it's easy to find, so that's very easy to clarify.

As for Dejan Anastasijevic, I found his entire file at the state security service. I have a rarefied network. I have people everywhere. I even have people in The Hague Office of the Prosecutor, and I received valuable documents from there, too. For example, I published what Jovica Stanisic said to The Hague Office of the Prosecutor. I'm a man who knows what he's doing. I look for what I need, and I find what I need.

Q. On several occasions he spoke about you. On the 27th of September, 2002 - that is 10341 and 342 - when asked about a map of Yugoslavia where some lines were drawn, the witness explained that this line is based on a line that Seselj talked about. In Seselj's perception, those are the new borders of the Serb state, a Greater Serbia. Is that correct?

A. Well, I cannot exactly discern what the witness said quite specifically, but it is true indeed that the Serb Radical Party made a map, a geographical map of a Greater Serbia with western ethnic borders on ⁴³⁴⁶⁵ the Karlobag-Ogulin-Karlovac-Virovitica line. And the Serb Radical Party has the exclusive right of authorship over that line. It was only the Serb Radical Party that ever advocated that. No one else, either in Serbia or Republika Srpska or the Republic of Serb Krajina.

Q. That was half of the question. I'm going to quote page 10343, 4 and 5 now. It says: "Seselj had in mind a state that would include Serbs only. As for Croats, the best thing would be for them to go to Croatia. Albanians should live in Albania." The witness cannot recall whether Seselj spoke about Bosniaks. And -- or, rather, let's deal with this first.

At that time, you had in mind a state that would include Serbs only, and for the Croats it would be best to go to Croatia and Albanians to live in Albania.

A. The policy of the Serb Radical Party and of me personally was that this Serb state should include practically all Serbs, Serbs who were Orthodox, Serb Catholics, Serbs who were Muslims, and so on. I advocated the expulsion of Albanian emigres who did not acquire our citizenship and who were active from separatist positions. I could not have referred to any kind of Bosniaks because the Bosniak nation was invented much later, in 1994 and 1995, whenever. So this is the latest invention as far as these nations are concerned.

The Serb Radical Party always consistently advocated the full equality of rights of the members of all national minorities in our territory, and that is why our membership included Hungarians, Romanians, Bulgarians, and members of all other national minorities; Slovaks, et ⁴³⁴⁶⁶ cetera.

JUDGE BONOMY: When you talk of Serb Catholics in this context are you referring to people who would normally regard themselves as domiciled in Serbia or are you talking about the Serb Catholics you described earlier who nowadays regard themselves as Croatian?

THE WITNESS: [Interpretation] I'm talking about Serb Catholics who consider themselves to be Croats today. In 1900, the Catholic Congress was held in Zagreb where it was first proclaimed that all Catholics who spoke the Serbo-Croat or Croato-Serb language, as it was called at the time, were Croats.

Now, what was it that happened? First the Croats espoused the Serb language as their own --

JUDGE BONOMY: I don't require you to go into that detail. Does it follow from that answer that when you talk about Serbs who were Muslims you're talking about people who would normally regard themselves as Bosnians?

THE WITNESS: [Interpretation] As of a few years ago they've been calling themselves Bosniaks, yes. I am talking about them. Because all top intellectuals from the ranks of the so-called Croats and the so-called Muslims --

JUDGE BONOMY: Again, I don't need an explanation of the history. I'm quite happy with an indication of your view and who you're referring to when you talk about these folk. I was simply looking for clarification, and you've provided that. Thank you.

JUDGE ROBINSON: Yes, Mr. Milosevic. ⁴³⁴⁶⁷

MR. MILOSEVIC: [Interpretation]

Q. In order for this to be complete, Mr. Seselj, let us digress slightly. Do you know about the Yugoslav author Mesa Selimovic?

A. Yes. Mehmet Mesa Selimovic is a Muslim from Bosnia and one of the greatest Serb authors of all time. He said for himself, "I am a Serb, my family is Serb, my father was a Serb, we're all Serbs." In his last will and testament he said that because he knew that after his death somebody would try to claim him, saying that he belonged to an invented nation. Mehmed Mesa Selimovic, Hasan Kikic, Skender Kulenovic, Camil Sijaric, and so on and so forth. All these top intellectuals who were Muslims emphasised that they were Serbs. And also among these alleged Croats, Ivan Gundulic and all the writers from Dubrovnik. Then Ivo Vojnovic, Ivan Stojanovic, Milan Resetar, Vladimir Dvornikovic, all the way up to Ivo Andric. All of them are Catholics, but they were proud of the fact that they belonged to the Serb nation. Artificially, later on, Serb Catholics were turned into Croats. First they were forced to declare themselves as Croats, and after brainwashing they said that they were Croats en masse. And after several decades of brainwashing, now the Muslims are convinced that they are some kind of a nation in its own right, and now even that has been changed and they're called Bosniaks.

Q. Mesa Selimovic, and we know that he is one of the most prominent Serb writers, in his last will and testament, which he left in the Serb Academy of Sciences and Arts, he wrote that he was a Serb.

A. Yes, that is correct. That text was published in his book called Secanja, "Memories." ⁴³⁴⁶⁸

Q. I believe that will do as for this particular aspect.

A. Mr. Milosevic, I have to remind you of Josif Pancic. Josif Pancic is a Serb who is a Catholic and he was the first Serb -- the first person who was president of the Royal Serb Academy of Sciences and Arts, and there are many other examples to that effect. In my book The Ideology of Serb Nationalism, there is a special chapter devoted to Serb Catholics, giving a series of examples. Yet another chapter about Serb Muslims with specific examples.

Q. C037, a witness here, said in addition to what you've been saying just now, that at that time Seselj was very prominent in the press, radio and television. All his speeches were reported about. Journalists followed him everywhere. This includes state television. He was given total freedom of speech.

Could you please explain this to me. What does that mean, that you were given total freedom of speech? Would that mean that somebody was not given total freedom of speech in Serbia in the 1990s? Who was it who had total freedom of speech and who was it that did not have total freedom of speech? Please give us examples for both.

A. It is impossible for me to answer that because after half a century of communist dictatorship, your government was the first one, Mr. Milosevic, that introduced full freedom of speech and freedom of thought. Full freedom. And it is not true that I figured most prominently in the media.

After the elections in 1992, Snezana Milivojevic, together with another associate whose name I cannot remember, published a book. If I ⁴³⁴⁶⁹ remember correctly, it was called The Elections On Screen. And in that book, on the basis of empirical data, she showed that the Serb Radical Party was the least represented party in the media when compared to other political parties. Our use of the media was the most effective because we are one of the few political parties that had a feeling of conviction deep down in terms of what we were advocating, our political views. Among all the people who were deceitful, we shone brilliantly as people who believed in their own ideology. That is what made us different. And we expressed our readiness to sacrifice ourself for our ideas, as opposed to others.

Q. Mr. Seselj, you arrived in The Hague on your own when you heard that there was an indictment against you.

A. Yes, and I happened to be arrested at the airport. I wanted to come to The Hague. For ten years I offered myself to The Hague. I phoned them several times, the Office of the Prosecutor here, and --

JUDGE ROBINSON: Yes, thank you. Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. What Mr. Seselj said at the end is not included in the transcript.

JUDGE ROBINSON: He said he offered himself to The Hague.

THE INTERPRETER: Interpreters note that the microphone was off.

THE WITNESS: [Interpretation] I would have been sad, truly sad had I not come.

JUDGE ROBINSON: Yes --

THE WITNESS: [Interpretation] It is important.

JUDGE ROBINSON: We have a complete picture now, Mr. Seselj. ⁴³⁴⁷⁰ Yes, Mr. Milosevic, next question.

MR. MILOSEVIC: [Interpretation]

Q. On page 10346, the same witness, C037, says non-Serbs were not desirable in the territory of Krajina. This was first said by Seselj, and Serbs from other territories would come to Krajina.

A. First of all, that's untrue. I never said that non-Serbs were undesirable in Krajina.

I'll tell you one detail. When I was in Mirkovci during the war, there was a unit of local TO, and some Croats were in the unit.

JUDGE ROBINSON: I'm sorry to stop you. You have answered the question. The tendency to go on and on and on has to be checked. You did answer the question.

Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. The same witness says he does not remember you were involved in the incident in Plitvice. And as for the meeting in Srb, you were present but it was not agreed in advance, you just dropped by. Is that true about your presence in the Krajina, and did he present it correctly?

A. It was -- it's true I attended the rally in Srb, but I didn't speak there. There was Jovan Raskovic, Milan Babic, and other speakers.

Q. He says you were not involved in the Plitvice incident.

A. Well, that happened a month before my arrival, sometime in March. Croatian special police barged in that place, there was a clash, and as far as I remember one Croatian policeman was killed and one Serb policeman before a JNA unit arrived to calm down the tensions. ^{43471 BLANK PAGE 43472} Later on, I took part in the protest march of the Serbian people towards Plitvice, and that was on the 2nd May, if I remember correctly.

Q. On transcript page 10429, the same witness, C037, testifying on the 30th of September, 2002, says that in Balinci and in Bacin crimes were perpetrated by Seselj's radicals with the help, of course, of local extremists. That's his assertion. So the two places are Balinci and Bacin, crimes allegedly perpetrated by Seselj's radicals with the help of local extremists.

A. I've never heard of a single crime allegedly perpetrated by volunteers of the Serb Radical Party. We were very strict. Even for minor offences, theft, robbery and such, we expelled such people from the party and suggested that they be expelled from the units as well. I never heard of a single volunteer of the Serb Radical Party perpetrating a more serious crime. There was not a singe instance of that. JNA officers and commanders always held them up as an example to emulate.

Q. On page 10431, he says that in Vocin there were volunteers from the ranks of Seselj's radicals and asked who killed the members of that family on the 15th December 1991. The witness says that, according to the locals, it was done by Seselj's radicals and extremists.

A. That's not true. Our men were not involved in that. They were stationed about ten kilometres away, and they themselves were badly beaten in a village called Masicka Sagovina. A great number of volunteers was killed on that day, and an even larger number were taken prisoner. Although they were tortured as prisoners, all of them were later released. None of them were tried. ⁴³⁴⁷³ It never happened that a volunteer from the Serbian Radical Party had been charged with a war crime until recently. What happened recently was that Milan Lancuzanin, also known as Kameni, found himself among the group of men on trial in Belgrade. But I have a document provided to me by the OTP, and it's a public document, from which you can see that Kameni was not involved in the Ovcara incident, and the participants in the execution in Ovcara called him all sorts of names the next day.

THE WITNESS: [Interpretation] If I can quote -- this is a rather bad term, maybe a profanity, Mr. Robinson. Can I say it? But it's in a public document. Will you allow me?

JUDGE ROBINSON: [Previous translation continues] ...

THE WITNESS: [Interpretation] That's the name they called him --

JUDGE ROBINSON: Yes. It's time for the break anyhow. We'll come back to that after the break. We will adjourn for 20 minutes.

--- Recess taken at 10.30 a.m.

--- On resuming at 10.55 a.m.

JUDGE ROBINSON: Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, this same witness, C037, page 10434, speaks about Croat civilians who were killed in the beginning of October 1991, and he says that what was done in Balinci was done by Seselj's volunteers.

A. To tell you the truth, I don't know where Balinci is located let alone something more specific. I don't really know where Balinci is.

JUDGE ROBINSON: [Previous translation continues] ... know where Balinci is? ⁴³⁴⁷⁴

THE WITNESS: [Interpretation] Well, that's an impossible question. I don't know all the places where the JNA sent its units including volunteers of the Serbian Radical Party.

Balinci is a term that has been mentioned in reports only recently, and I don't know where it is.

JUDGE ROBINSON: Okay.

MR. MILOSEVIC: [Interpretation]

Q. Very well, Mr. Seselj. In view of the composition of your party, would you know whether your volunteers had perpetrated a crime?

A. I'm absolutely convinced that I would know if some of our volunteers were involved in some crimes. Somebody would immediately report it, the party would immediately intervene. But there was simply no such information. I told you, even for minor offences we immediately expelled people from the party; and second, we insisted that their units expel them too. I mentioned the case of this Zuca man who was found thieving in Eastern Slavonia, and he was immediately thrown out of the party. He later said that he left the Serbian Radical Party because we were cooperating with the regime. That much is true. But such people always tried to explain their actions by ideology.

JUDGE ROBINSON: Mr. Seselj, we're talking about the Serb Radical Party volunteers within the JNA, and you say that if they committed a crime as JNA members, you and your party would be informed of that?

THE WITNESS: [Interpretation] Well, it's certain that in some way we would be informed. The competent JNA command would inform us. Other volunteers who are members of our party without being members of the JNA ⁴³⁴⁷⁵ would inform us. We were convinced that our volunteers had to be the most disciplined to protect the honour of the party and its reputation. That's very important for us.

JUDGE ROBINSON: I know you are so convinced. I know you are so convinced, but what kind of institutional relationship did the JNA have with the Serb Radical Party such that you would necessarily receive that kind of information?

THE WITNESS: [Interpretation] There was no institutional link. As citizens, both collectively and individually, we cooperated with and assisted the JNA. In one case, I personally addressed a letter to Colonel Trbojevic in Western Slavonia, asking that people from the Radical Party who were engaged in rallying volunteers be placed on the payroll of the JNA because their engagement in Western Slavonia lasted for months.

JUDGE ROBINSON: Am I right in saying, then, that the only way you'd receive this kind of information would have been through informal channels?

THE WITNESS: [Interpretation] Yes. Through informal channels. But I believe that even though informal, those channels were very reliable, because our members were very conscientious in party terms, and they had great party discipline. And I'm certain that even if somebody from outside had gotten hold of such information, they would inform us immediately.

JUDGE ROBINSON: Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, this witness says that Seselj's radicals, that's on ⁴³⁴⁷⁶ page 10438, robbed and murdered Stojan Bojanic in Glavica while withdrawing. He doesn't know whether it happened on the 21st or the 22nd December. This man seems to be a Serb, judging by his name. Do you about this case?

A. No, I've never heard of it but it seems implausible to me that perpetrators are unknown. It is my deep conviction that every crime has a first and last name. Behind every crime there is an individual or a group and every crime can be elucidated from that aspect. The person who said Seselj's men, could easily have said the Japanese, or Martians, or anything else. I read in one submission by the Prosecution the term Seselj's White Eagles. There was also a lot of confusion. Even the OTP is unable to find its way through this confusion.

Q. I hope you clarified enough that White Eagles had never had anything to do with the Serbian Radical Party.

A. None whatsoever. On the contrary, we always criticised other volunteer groups if they were involved in crimes. You probably remember our sharp critique of Arkan's men, Mauzer's men, and some others, the Serbian Guard, for instance.

Whenever we would find out by crimes perpetrators -- perpetrated by others, we stigmatised it in public because we thought it was highly harmful to the Serb people as a whole because it was contrary to the customs and traditions of the Serbian people.

Q. This witness says on page 10441, in Sekulinci, Zvecevo, and Ceralije, Seselj's men were quartered in the area of Zvecevo facing Slatina, not other places. Do you know anything about that? ⁴³⁴⁷⁷

A. I know that the volunteers from the Serbian Radical Party were quartered in various places in Western Slavonia, and at any given moment there were at least 500 volunteers from the SRS there. Their superior was Colonel Trbojevic and he praised them when I toured that area. I slept up there at Zvecevo. There is some sort of mountaineers lodge. That's where I spent the night. I toured various lines, and Colonel Trbojevic never ceased to praise the discipline of the volunteers from the Serbian Radical Party. He said they were among the most disciplined. That -- their stints were a month long. Sometimes 45 days. Those were people who had jobs waiting for them, families waiting for them. So they went and served on these lines in these areas for a month, month and a half, and then they would go back home and be replaced by another shift. But I believe that at every given moment there were at least 500 volunteers from the SRS distributed among various units. There were never more than one company of volunteers from the SRS in any unit.

Q. On page 10467, he says: "People were afraid of Seselj's men. They were cruel. They did all sorts of things to the local population. They intimidated them, threatened them. Some of them were involved in looting. That's what people said to me. People complained to me that they had been robbed. The local population, both Serb and Croat, mistrusted them and feared them. Seselj came and toured his units in the area of Zvecevo in December 1991. He made inspections in Vocin and Slatina. I don't know about other places. He held speeches to soldiers who were his sympathisers, but I didn't hear them. I heard about it from the local population, people who were there." ⁴³⁴⁷⁸ So you were in Zvecevo. You toured the units that included your volunteers.

A. I toured many other units as well.

Q. All right. All right. Let us clear this up. People were afraid of Seselj's men. They were cruel. They did all sorts of things to the local population. They looted, robbed both Croats and Serbs who were afraid of them and mistrusted them. What can you say about these assertions?

A. Well, to say I made inspections is an overstatement. I just toured units. I didn't have any formal authority to inspect units. But there were certain problems that I tried to help with. For instance, there was a group of volunteers that had been given old JNA uniforms, so I begged the competent commands to give them newer uniforms that were nicer. They looked better, and that they -- they were in camouflage colours. During my tours, I spoke to a lot of civilians, including a large number of Croats. I never, never came across a complaint. Everybody received me well, spoke to me nicely. We discussed general political topics and their everyday life. Most of the complaints had to do with poor supply of food and necessities and such like. I never heard a single complaint against the conduct of the volunteers from the Serbian Radical Party in Western Slavonia.

However, when you have testimony that is third hand, fourth hand, fifth hand, that's worthless. This witness says, "People told me." Maybe old wives at the hairdresser's shop told him. That's --

JUDGE ROBINSON: Thank you, Mr. Seselj. You've made the point. ^{43479 BLANK PAGE 43480}

MR. MILOSEVIC: [Interpretation]

Q. On page 10959, the same witness says he didn't know anything about paramilitary units of Vuk Draskovic. He only knew about Seselj's men, and that's only based on what the population told him. So what kind of paramilitary units of yours is this a reference to? Did you have a paramilitary unit anywhere?

A. Nowhere. That's one thing. Another thing: The volunteers from our party in the places where they were stationed came into contact with the local population. They fraternised. And if a crime had occurred, people would know who exactly did it. These and these people committed a crime. You can't say everybody committed crimes or everybody was involved. If a crime was committed, it's not difficult to know who exactly did it by name. Such cases involving volunteers of the Serbian Radical Party are not to be found anywhere.

JUDGE ROBINSON: Is the description of these men as "Seselj's men" a fair one?

THE WITNESS: [Interpretation] Well, this term "Seselj's men" can encompass various groups. I've already given you an example from the judgement in the case against Radoslav Brdjanin. I read all the judgements that were available to me.

This judgement refers to a paramilitary unit of local Serbs in Bosnian Krajina called Seselj's men. I never heard of them in my life before reading that judgement, before -- because we never sent people to Bosnian Krajina.

So when somebody says "Seselj's men," God knows what they mean by ⁴³⁴⁸¹ it. Do they mean volunteers from the Serbian Radical Party coming from Serbia? Does he mean some local Serbs who called themselves by some local name or called themselves like that?

JUDGE ROBINSON: In what context do you consider the description to be fair and accurate?

THE WITNESS: [Interpretation] This description would be fair with respect to volunteers of the Serb Radical Party who were sent as volunteers to the front line as part of the JNA. They might be called Seselj's men because I motivated them to volunteer, and --

JUDGE ROBINSON: Yes. Thank you. Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, Nikola Samardzic on the 8th of October 2002, that's on page 11197 of the transcript, said that you led a campaign to raise the morale of soldiers around Dubrovnik, a large scale and very bad campaign. He said: "At that time he was playing his role of a Chetnik duke. He got this title from the war criminal Djuic who immigrated after World War II. This self-proclaimed Chetnik duke inspected troops wearing symbols of the Chetniks from World War I. The witness added that it was shameful that a review of a glorious, chivalrous army was carried out by someone like Seselj."

So he's speaking of Dubrovnik, your review, and the insignia, as you heard, and the qualification that you were a self-proclaimed duke.

A. The testimony of Nikola Samardzic is absolutely untrue and contains a number -- a large number of lies.

First of all, Momcilo Djuic was not a war criminal who conferred ⁴³⁴⁸² upon me the title of Chetnik duke. He lived in America, and had he been a war criminal, America would have extradited him to communist Yugoslavia as it did in the case of real criminals, such as Artukovic. He was the last one to be extradited. It never occurred to them to extradite Momcilo Djuic because he fought against the occupiers and did not commit any crimes.

Secondly, I did not carry out an inspection or review. I toured the Herzegovina war front facing Dubrovnik, and I visited several front lines there. There were never any volunteers of the Serb Radical Party at the time. There were only JNA units and reservists from Montenegro. Wherever I turned up, I was welcomed. For example, when I came to Ljubinje, several hundred soldiers gathered round me and started singing "From Niksic to Split Duke Seselj is the one whose opinion is asked about." I did not carry out any inspection but I was popular among the Serb fighters and my arrival probably did help to raise morale.

JUDGE ROBINSON: Thank you. Thank you, Mr. Seselj. Just remind me, when was the title of duke conferred upon you? You told us earlier in your evidence.

THE WITNESS: [Interpretation] On the 28th of June, 1989, at the Serb Assembly near the Libertyville monastery near Chicago in America. Duke Momcilo Djuic had declared me the new Chetnik duke in 1989 in my absence. That was two years before the war began.

JUDGE ROBINSON: Yes. Thank you.

THE WITNESS: [Interpretation] And in his statement of reasons, if you're interested, he said that I was a prominent anti-communist fighter ⁴³⁴⁸³ in the homeland.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, Witness Jovan Dulovic says on page 11736 of the transcript Cele - that is a certain person called Miroslav Vukovic - entered Marko Pavlovic's office -- Marko Popovic, that is, or Marko Popovic, there were three or four names used to describe that man -- and put a pistol to his head. Cele was Seselj's man. This was one of Seselj's units. Major Pavlovic said to the witness that he had called Radmilo Bogdanovic and Seselj and Seselj had told him that Cele was from his unit, that he was beyond control --

THE INTERPRETER: Or, rather, interpreter's apology, that Cele and his unit was beyond control.

MR. MILOSEVIC: [Interpretation]

Q. -- and had nothing to do with them. Was that a unit of yours?

A. There were no unit of ours, either mine or of the Serb Radical Party. Miroslav Vukovic Cele was a volunteer from the Serb Radical Party in Eastern Slavonia and Zvornik. In Zvornik he was a member of the JNA. Several years later, he was expelled from the Serb Radical Party but for completely different reasons. I never heard that Miroslav Vukovic Cele participated in any crimes. Miroslav Vukovic Cele, however, is today the president of the Association of Veterans from the wars from 1991 to 1995. He is the president of the War Veterans Association of Serbia. So he's still active in political life. Nobody ever said that he had perpetrated any crimes.

And as for what Dulovic says, who knows? Maybe he did have a ⁴³⁴⁸⁴ conflict with a Serb, but this man is neither a Croat nor a Muslim. It's possible that there was a conflict among Serbs somewhere.

JUDGE ROBINSON: Thank you. And remember to observe the pause, Mr. Seselj, after Mr. Milosevic's question, because I can hear the interpreter gasping for breath.

MR. MILOSEVIC: [Interpretation]

Q. There is more than one place in Jovan Dulovic's testimony where you are mentioned, and this testimony here was used to accuse me of what went on there. I will skip over some of these because they don't seem very important, and we don't have a lot of time. For example, the possibility of contacting you, the percentage of the Zvornik population that would join the Radical Party, and so on and so forth. But in answer to a question put to witness Jovan Dulovic, and that's on page 11750, did the witness personally interview Seselj when shooting a documentary film about these events, the witness answered in the affirmative.

Do you recall Jovan Dulovic, on page 11753, where a video was played and the transcript says as follows:

"Dulovic: Yesterday you said on television that Milosevic was the one who supplied your unit with weapons, that he took an active part in all this and that then he turned his back on you. "Seselj: Yes, that is a fact. In 1991 and 1992, Milosevic was the leading nationalist and patriot, and at that time we cooperated closely. When 30.000 paramilitary troops were sent to the front lines where the Serb people had to fight, he was the one who supplied weapons, ⁴³⁴⁸⁵ ammunition, clothing and food, transport, military equipment, and so on." This was played here. Can you explain what you just said and what is said in this interview? Do you remember this interview?

A. I don't recall ever saying something like this to Jovan Dulovic, but I certainly did make such statements for various media during the vehement propaganda campaign that we started against you and your government, because you were doing the same to us. As I said, we felt that all means were permissible. We wanted to upset you as much as possible, to make you angry, to get you to take ill-considered repressive measures against the Serb Radical Party because that would have been politically favourable for us. And I have to say we did manage to get you to take such measures.

Q. What measures?

A. Well, the fact that I was tried in 1994 with my collaborators and spent four months in prison, that your government and your police arrested us at Gnjilane and held us in prison for two months. So we opposed you as far as we could. And from the rejection of the Vance-Owen Plan to this showdown in 1993 where your party and secret police first moved against us, and then we waged an all-out campaign against you, and we simply did not choose our words or, rather, we chose those words we felt would upset you the most. So I cannot confirm that I said this to Jovan Dulovic, but I'm sure I said things like this to many other media. On the other hand, as you know, we were unable to speak on the state-run media, so this was a way for us to gain publicity through the opposition media. ⁴³⁴⁸⁶ As for Jovan Dulovic, I visited Iraq in 2001. I was received by my friend Saddam Hussein, the president of Iraq. On my way back, I stopped off in Damascus and the then Yugoslav ambassador in Lebanon, the brother of Jovan Dulovic, came to see me. He came especially from Beirut to Damascus to meet me, and he started complaining to me that his brother was a traitor and a foreign mercenary. I think this is very telling and shows that Jovan Dulovic is not reliable as a witness. Jovan Dulovic could have found any number of statements of mine in other media and used them, but they cannot be used in court proceedings.

MR. NICE: There must be some limit to the --

JUDGE ROBINSON: Thank you.

MR. NICE: -- the liberty the Court is going to allow this witness. I'm not going to stand up and object at all, if I can avoid it, but really we are seeing an extraordinary form of evidence given this morning and I would invite the Chamber to restrain the witness as far as it feels it should.

JUDGE ROBINSON: What precisely is the point, Mr. Nice?

MR. NICE: Well, the last answer where we see -- if we look at the question. The question, if we can actually find it, is what measures were taken. He then elaborates upon the measures he took, or that he says he took, and then it goes on into a long explanation about his visit to Iraq and comments on the reliability of witnesses coming in that way.

JUDGE ROBINSON: It seems to me that Mr. Milosevic is using this witness to comment on testimony given by Prosecution witnesses, and that goes to their credibility. It's for us to assess. ^{43487 BLANK PAGE 43488}

MR. NICE: Well, commenting is one thing. Giving evidence about -- giving evidence that may sustain comments by others is one thing, but commenting, being allowed simply to comment is another. Typically, witnesses aren't allowed simply to comment on the alleged credibility or veracity of witnesses. They have to give evidence. It's a matter for the Court.

JUDGE ROBINSON: But what the witness is doing is giving evidence on the evidence that was given by Prosecution witnesses.

MR. NICE: Some of the time.

JUDGE BONOMY: If a witness is accused -- sorry, if a witness here is accused by another witness of saying something which the witness here thinks is a lie, why can't he say that?

MR. NICE: He can say it's untrue. He can say it's untrue, of course he can. And he can also give factual reasons if factual reasons exist for supporting that, but we're getting very expansive answers.

JUDGE BONOMY: Well, I think the comments you've made have merit in relation to the answer we've just been listening to, but speaking for myself, I think that the evidence this morning to a large extent has been very focused.

MR. NICE: As Your Honours please.

JUDGE ROBINSON: Mr. Milosevic, yes.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, to put aside the question of whether you said this to Dulovic or not, it says here that you said that in 1991 and 1992 the two of us cooperated closely and that I was supplying you with weapons, food, ⁴³⁴⁸⁹ and so on and so forth. Do you remember having said this?

A. I'm sure I did say that more than once, speaking to different media, but this was part of the propaganda war in which your party was declaring me to be a criminal, a psychopath, an alcoholic, and so on and so forth, but this does not correspond to the facts. One has to bear in mind the characteristics of Serbian political life. For example, the previous regime said that I had participated in the murder of Djindjic. Later on, the Prime Minister said that they didn't mean it seriously. Then the government accused me of stealing 36 million Deutschmarks. We have to see all this in context.

JUDGE ROBINSON: Yes. Thank you. I think you answered the question.

JUDGE BONOMY: Over what period of time do you think we cannot rely on your public statements as accurate?

THE WITNESS: [Interpretation] Every public statement has to be seen in the historical context in which it was made. As to whether they were false or true, in theory there is a very important standpoint. A lie is not something that is said in public and does not correspond to the facts if everybody knows it's not true.

For example, the public was amused by the way I was accusing you of things that you hadn't done and how you're upset about this. However, here I'm testifying under oath about the facts.

Our first conversation was in May 1991 and the first time we met was in April 1992. These are the only facts, and these can be proved. As for the rest, this is just Serbian political folklore. And I am not the ⁴³⁴⁹⁰ only example of this. All the other participants in political life are as well.

The Democratic Party would forge a document with a signature of mine. They would photocopy my signature from another document, and they would insert another text.

You know, in Serbian political life a lot of things happened, and all this has to be borne in mind when judging public statements made by in that period.

JUDGE BONOMY: It also has to be borne in mind when judging statements made here, that people in other contexts quite deliberately lie.

THE WITNESS: [Interpretation] Yes, but I am now speaking in public under oath and that's the difference. There's a difference between what one says when testifying before a court and what one can say in the heated political atmosphere when one is exchanging blows with one's opponents. And of course it's for you to evaluate the credibility of my testimony. I will not go into that. And the credibility of all the other testimonies here.

I am fully aware of the circumstances of my testimony here and its historical import. History will study what I said here, not what I may have said in a heated debate, a heated political atmosphere where one day I'm opposed to someone and the next day we can cooperate again. However, I am fully conscious of the historical importance of my testimony here, whatever the outcome may be in terms of the Court's decision.

JUDGE ROBINSON: Yes, Mr. Milosevic. ⁴³⁴⁹¹

MR. MILOSEVIC: [Interpretation]

Q. Dulovic, on page 11847, says that he knows for sure on the basis of his own investigations that members of Seselj's party volunteered to the local committees of the Serb Radical Party that made up lists, sent them to the Ministry of the Interior in order to be checked, and then the Ministry of the Interior sent lists further on or, rather, back to the local committees that then called the volunteers who had been approved. Now, my question is the following: Dulovic himself says that your volunteers signed up voluntarily. Did you send their names to the police for checks and did the police then give you approval as to who you would call to your local committees?

A. No. At first we had some volunteers who had not done their military service, their regular military service. When we understood that problem, when it was pointed out to us - I cannot remember all the details now - then we insisted that only those who had completed their regular military service could volunteer, those who had had some kind of military training before that, because it did happen that sometimes people applied without any military training beforehand and then they would get killed because of this total lack of military experience. So these checks simply never were carried out. Our municipal committees had the task of making sure that the persons concerned were not drug addicts. Drug addicts were definitely banned, then alcoholics, too, and notorious criminals. We avoided those three categories; drug addicts, alcoholics, and notorious criminals.

Once the lists were made, then these volunteers were called to ⁴³⁴⁹² Belgrade, to the headquarters of the party, and from the headquarters of the party they were sent on buses to the barracks in Bubanj Potok and that is where they were put under the command of the relevant military authorities, and then the command sent them on to where they thought they would be used best.

JUDGE BONOMY: Help me to understand this. What you're saying is among your membership were drug addicts, alcoholics, and notorious criminals, but while they could be members of the party they couldn't serve --

THE WITNESS: [Interpretation] No.

JUDGE BONOMY: -- as volunteers. Well, could you explain how I've misunderstood that.

THE WITNESS: [Interpretation] No. You know, there is free membership in the Serb Radical Party. Anybody can become a member. Whoever wishes to do so, whoever is 18 years of age can do so. There are no bans, and also no checks are carried out previously to see what kind of a person the member is. It's a free party. Anybody can join. However, when personnel policies are pursued, then the criteria become more strict. In this case, it was made sure that among the volunteers there should be no drug addicts, alcoholics, or notorious criminals. It could happen that on a particular day a person could join the Serb Radical Party and say, "I wish to sign up as one of your volunteers." There were such cases. Then also some people who got in contact with our volunteers at the front line would join the Serb Radical Party there. I already mentioned -- ⁴³⁴⁹³

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, I have the impression that it's very difficult for the transcript to keep up with you.

JUDGE BONOMY: Just a second. You talked about "our municipal committees." Are these party committees or are these committees of the Ministry of the Interior?

THE WITNESS: [Interpretation] There are no committees of the Ministry of the Interior. These are committees of the Serb Radical Party that exist in all municipalities and also at lower levels of local communes.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, you did not answer part of my question that has to do with the Ministry of the Interior. Did you send information about your volunteers to the Ministry of the Interior so that they could assess who can be a volunteer and who cannot?

A. Never. And you can never find a document to that effect that we sent them such lists. It is absolutely impossible for such a document to exist. I think that you have received a very direct answer now.

THE INTERPRETER: Could the speakers please pause. Could Mr. Milosevic stop before putting a question.

JUDGE ROBINSON: Again the interpreters are asking for a pause between question and answer.

It is particularly relevant, Mr. Seselj. You speak immediately. In fact, you speak before Mr. Milosevic has completed his question. Just a second. ⁴³⁴⁹⁴

[Trial Chamber confers]

JUDGE ROBINSON: Mr. Seselj, I was just consulting with my colleagues since they have more knowledge of these technical matters than I do. You have to observe the pause since you're listening in your own language, because if you are listening in the other language, then you can hear the interpretation, wait until it's finished, wait until the interpretation of the question is finished and then you start to speak. But since you're listening on a Serbian channel, then you must observe the pause. That's the only way. Otherwise, the interpreters will be asking me every five minutes to tell you to observe the pause. Mr. Milosevic is a veteran at this so he does a little better, but he was delinquent a short time ago.

So let's proceed.

MR. MILOSEVIC: [Interpretation]

Q. On page 11848, when I said that the Serb Radical Party had never had any paramilitary formations, the witness answered that that was not true. I quoted you then, namely that you never had any paramilitary formations. He said that that was not correct.

A few pages later on the transcript, in order to prove that there were such paramilitary formations, he mentions Seselj's unit the Yellow Wasps led by Major Dusan or Vojin Vuckovic. We already talked about that. So I claim that you did not have paramilitary formations. He says that is not correct, and then he refers to the Yellow Wasps. Is it necessary to give an additional explanation or do you believe that you have explained this fully? ^{43495 BLANK PAGE 43496}

A. As for the Yellow Wasps, we had nothing to do with them. When members of the paramilitary formation called the Yellow Wasps were arrested and put in prison in Bijeljina, the Serb Radical Party issued an official statement, press release, supporting the arrest. That is an undeniable fact.

Vojin Vuckovic, nicknamed Zuca, himself in his statement which was submitted to me as part of the exculpatory material testifies that at that time he had nothing to do with the Serb Radical Party. At the beginning of the war he was a member. In Western Slavonia he was a volunteer, but then, as he says, he left the party because we had cooperated with the regime. Actually, he was thrown out because of crime.

Q. All right. I hope we have clarified that. Dulovic, on page 11874, says that when he was in Zvornik there was a clash between the Territorial Defence and a strong military -- paramilitary formation, and the man who led this paramilitary formation said that he was one of Seselj's men, and it was the same Cele that you mentioned a short while ago.

He talks about a paramilitary formation headed by this man that was in a conflict with the Territorial Defence. So this was an inter-Serb conflict. He's not talking about a conflict with any other ethnic group here. He says that there was a paramilitary formation there headed by that person.

A. I categorically claim that Miroslav Vukovic Cele was a volunteer in Zvornik within the JNA and that he had come to Zvornik as such. Now, whether he personally clashed there with some local Serbs or not is ⁴³⁴⁹⁷ something that I don't know about. This is the first time I hear of this. And I cannot go into that. However, he left Zvornik when the JNA units withdrew.

Q. So he was within the JNA?

A. Yes.

Q. Not at the head of your paramilitary formation?

A. There was no paramilitary formation of mine.

Q. Witness C060 testified on the 21st of October, 2002. This is on transcript page 12004, saw in Vocin in October and November 1991 Seselj with Vukelic, Sasic, Bojcic, and others.

A. He probably saw me. Thousands of people saw me there. Veljko Vukelic at the time was Prime Minister of Western Slavonia. Ilija Sasic was minister of foreign affairs. He was the person who I came with by helicopter to Western Slavonia. We took a helicopter to Banja Luka and then from Banja Luka we went to Western Slavonia by car. Those are the facts. Thousands of people saw me there; Serbs, Croats, all of those who were there. I visited many places, I talked to many people, shook hands with many people.

Q. Did you learn then of any crimes or any incidents that had occurred in that territory? I wish to remind you that in several of these statements there is mention of some local population or local extremists. Different terms were used in these statements that I've quoted to you. Have you heard anything about such things?

A. To my knowledge, at that time there weren't any such crimes. Some crimes had happened at the time of the fall of Western Slavonia. As for ⁴³⁴⁹⁸ the type of crimes and who had committed them, the best explanation for that could be given by General Aleksandar Vasiljevic, the then head of the then security service of the JNA who happened to be in Western Slavonia at the time of its fall. I was not there at the time of the fall of Western Slavonia. I was there almost a month before Western Slavonia fell.

Q. Witness Slobodan Lazarevic, who testified on the 30th of October, 2002, says that very early on, in the area of Knin, White Eagles appears, Seselj's volunteers, and Captain Dragan's volunteers. Did that coincide with what happened in Knin at the time? You were there for a while on several occasions, as you said yourself.

A. I have never heard of the White Eagles being in Knin. There weren't any volunteers of the Serb Radical Party in Knin. The volunteers of the Serb Radical Party were at the Lika theatre of war, because the territory there was very big and with a very low density of the population. In Knin, there were enough local Serb soldiers. Captain Dragan had a training centre in Golubic, I think. That is near Knin, but I never visited that centre. I always kept my distance from Captain Dragan, considering him to be an ordinary criminal and a cheater.

Q. Witness Petar Kriste testified on the 27th of January, 2003. The page is 14925. He says that the rebellion in the Croatian territory was the result of activities of secret services and agents like Seselj and others who had come from Serbia for the most part. So what happened in Croatia was the result of activities of agents from Serbia, including you. ⁴³⁴⁹⁹

A. That is an absolute fabrication. The Krajina Serbs themselves and collectively felt jeopardised by Tudjman's regime. That is why they stood up.

I first came to Knin when the roadblocks had already been put in place for quite awhile. I came towards the end of August or beginning of September 1990. As far as I can remember the roadblocks had already been put up everywhere. No agents from Serbia could make the Krajina Serbs rebel, take up arms, had they not really been threatened there.

Q. Witness Aleksandar Vasiljevic, on the 6th of February, 2003, that is transcript page 15812, recalls that Seselj publicly, in a BBC TV programme called The Death Of Yugoslavia, so you publicly in that BBC TV programme, according to what Vasiljevic says, said that Jovica Stanisic had hired you to get some volunteers and that you took weapons from the JNA in order to arm them.

A. First of all, it is a lie that I said that I was hired by Jovica Stanisic. I never could have said anything like that.

Q. It would have been insulting.

A. Of course. But that I pulled all stops when attacking Jovica Stanisic and made statements that I was sure would upset him the most is correct.

At one point in time, when I heard that Jovica Stanisic was ill, I had pangs of a guilty conscience even. I was sort of wondering whether these attacks of mine had contributed to the psychosomatic basis of his illness. However, I did not feel that for a long period of time. I attacked Jovica Stanisic as head of the secret police using all ⁴³⁵⁰⁰ conceivable means, because he started a political conflict with the Serb Radical Party. He started recruiting members of my party. We expelled Ljubisa Petkovic, vice-president of our party, because he was suspected of being recruited by the secret service. Also, there is video footage of seven of our MPs in the federal parliament who were given money to betray the party in order to tip the balance of power in the parliament. This was done by Jovica Stanisic. And on the other hand this was recorded --

JUDGE ROBINSON: Thank you.

JUDGE BONOMY: When you say that you used all conceivable means, did that include making inaccurate statements?

THE WITNESS: [Interpretation] Yes.

JUDGE BONOMY: Thank you.

THE WITNESS: [Interpretation] Bombastic statements.

JUDGE BONOMY: Well, the two are quite different in my vocabulary. Perhaps not in yours.

JUDGE ROBINSON: Mr. Milosevic.

THE WITNESS: [Interpretation] I would like to draw your attention to a particular fact, Mr. Bonomy. A prosecutor is sitting here, the one who is in charge of the proceedings against me. In her official motion to the Trial Chamber, she called me a scandalmonger, and I'm proud of that title. There is no greater scandalmonger in Serbian political life than me over the past 15 years. When I needed this kind of scandal out of political interests, I was the one who could do that the most skilfully. I am so proud of that title of scandalmonger that this lady sitting there bestowed upon me. I'm prouder than -- of that than of my doctorate. ⁴³⁵⁰¹

JUDGE ROBINSON: Very well. There you have it. Mr. Milosevic.

JUDGE KWON: Is it possible, Mr. Seselj, that you had said to the BBC people that you had been engaged by Jovica Stanisic?

THE WITNESS: [Interpretation] It's not impossible. I used that programme, too, to attack Jovica Stanisic, and here is why: In the preceding period, all the Western media and Western politicians were attacking Mr. Milosevic as the Balkans butcher, and they used many other terms. After the support given to Vance-Owen's Peace Plan all the way up to the Dayton Accords, Western politicians started praising Mr. Milosevic. After the Dayton Accords, the Americans publicly stated that he was the main guarantor of peace in the Balkans. And in the same period, I started to pull out those accusations against Mr. Milosevic and his associates that had been previously used by the West. So in that period, I didn't agree with him and I started repeating the same accusations that were presented by the West at the time when they were calling him the Balkans butcher and termed him uncooperative. When he became cooperative with them, then I started seeking quarrel with him, seeking scandal, and creating comedy sometimes.

JUDGE BONOMY: Can I ask you then specifically why you would say that Stanisic had hired you to get some volunteers and that you took weapons from the JNA in order to arm them?

THE WITNESS: [Interpretation] In order to provoke Stanisic to do something rash against me and the Serb Radical Party. I wanted to provoke him. I wanted that from the depth of my heart, and I was using every term ⁴³⁵⁰² and accusation that I could think of short of cursing his mother. He was chief of the secret police, a very powerful man, and he was working systematically to destroy the Serbian Radical Party. I don't have to tell you about the arsenal that is at the disposal of the secret police, how they use fabrications, lies, et cetera.

MR. MILOSEVIC: [Interpretation]

Q. Let me point out to you one of the sessions of Aleksandar Vasiljevic on the 12th of February, six days into his testimony, on page 15934, when he says very decidedly: "Miodrag Lancuzanin was a commander of the Leva Supoderica unit that took part in the liquidations in Ovcara. This unit was called Seselj's unit. Practically, those were his radicals."

So everything is lumped together. Leva Supoderica, Ovcara, the detachments, so you can conclude that this detachment of Seselj's perpetrated the execution in Ovcara.

Tell me, what is the truth about this Leva Supoderica unit, and what is the truth about Miodrag Lancuzanin, its commander, and whether there is any link between the detachment and Lancuzanin with the execution in Ovcara.

A. This is an obvious example of false testimony by Aleksandar Vasiljevic. This Miodrag Lancuzanin - I'm not sure about his first name, maybe it's Milan - he was otherwise known as Kameni. He was the commander of the Leva Supoderica unit. Originally it was the defence detachment of Vukovar and he was a native of Vukovar and captain first class in reserve. When the Guards Brigade came to the area of Vukovar, then that detachment ^{43503 BLANK PAGE 43504} was resubordinated to the commander of the 1st Guards Brigade, and that commander decided that the volunteers from the Serbian Radical Party should be admitted into the detachment and become part of the 1st Guards Brigade.

Q. Please stop for a moment. Let us clarify this very, very carefully.

So there was a detachment of the Territorial Defence of Vukovar and its commander was a reserve officer, Lancuzanin.

A. Yes.

Q. Your volunteers were included into that detachment as they would be included in any other JNA unit.

A. Well, that's not a complete definition. It was only when that detachment became part of the 1st Guards Brigade was the order issued that volunteers of the Serbian Radical Party be admitted into that detachment. Before that, there were no volunteers of ours in that detachment and Kameni was not a member of our party. Kameni joined our party during the war when our volunteers started arriving to place themselves under his command.

Q. Did I understand you correctly now? Your volunteers came to the JNA?

A. Yes.

Q. When this existing detachment, the authenticate Vukovar Territorial Defence detachment, became part of this JNA unit, the 1st Guards Brigade, then your volunteers were included in that unit as they were included in various other units? ⁴³⁵⁰⁵

A. Yes.

Q. I think that is clear enough. Now, tell me, this detachment and this particular person, this captain first class as you say, Lancuzanin, do they have anything to do with the events in Ovcara?

A. When I heard about the crime in Ovcara, which was several months after the fact, I called Kameni to come to Belgrade, and I asked him to tell me whether he had participated in that. He swore on all that he could swear on that he had nothing to do with that crime, and I was persuaded he was telling the truth.

When I came here, as part of the exculpatory material delivered to me by the OTP, and I mentioned this a moment ago, a profanity is used, and I didn't hear from Mr. Robinson whether he would allow me to quote it. That's something --

JUDGE ROBINSON: If Mr. Milosevic feels it is important to his case, then you may use it.

MR. MILOSEVIC: [Interpretation]

Q. I don't know whether it's necessary. The point is, I suppose, the fact that you tried to explain a moment ago, namely that he was called all sorts of names because he wasn't with them at the time.

THE WITNESS: [Interpretation] When Kameni got a whiff of something suspicious being in the offing, he got into his car and left. He didn't want to be part of it at any cost. After it happened, the people who took part in the execution called Kameni all sorts of names because he didn't participate. And documents testifying to this were delivered to me by the OTP. I hadn't known about them before. ⁴³⁵⁰⁶

Q. That clarifies it sufficiently. Did anyone from that detachment, as far as you know, take part in the crime at Ovcara or not?

A. To the best of my knowledge, nobody from that detachment took part. That's what Kameni told me.

Q. Did any other member of the Serb Radical Party from that area, even if they were a native of that area, take part?

A. From what I know, one of the accused Stanko Vujanovic joined the Serbian Radical Party later, subsequently. Only in 1993. It was Rade Leskovac who introduced him as a member, then president of the Serbian Radical Party for the Republic of Serbian Krajina. He nominated him at the first party elections, majority elections, and Stanko Vujanovic became one of the majority MPs. I don't know whether he participated in the executions or not. We have to hear about that from the judgement of the Special Court for War Crimes in Belgrade. That judgement is pending and expected soon. But at the time of the liberation of Vukovar, he was not a member of the Serbian Radical Party. He became one only in 1993. That is an indisputable fact. Generally speaking, he's a native of Vukovar.

Q. I hope this is not a major digression, but how do you explain that nobody knew about that event, even you who had a large number of volunteers on the ground? How come that nobody knew about it for several months after the fact?

A. Well, that's something you have to ask of General Aleksandar Vasiljevic, because he was in Western Slavonia at the time. He was in the area of Vukovar, and when the execution happened, from what I know, the ⁴³⁵⁰⁷ commander from the Guards Brigade, then Colonel, now General, Mrksic was not in Vukovar at all from what I know. General Vasiljevic was, and he should be asked why he hadn't filed criminal charges or a criminal report as soon as he found out, even if he didn't participate in organising that crime. And why he stole 1 million Deutschmarks from the Vukovar party. He never -- he never submitted that money through proper channels to the bank.

Q. There was another witness here, Dragan Vasiljkovic, better known as Captain Dragan, on the 19th February, 2003. Page 6 -- or 16487. It says that Seselj had sent a bus carrying with self-styled Chetniks -- carrying self-styled Chetniks, people who called themselves Chetniks. Captain Dragan stopped the bus because he considered that to be his own responsibility, whereas the bus was headed for Korenica. He sent 15 per cent of the people from the bus back to Belgrade and recruited the rest into his own unit.

Do you remember such an event, such a problem with Dragan Vasiljkovic and those Chetniks that were sent to Krajina?

A. Dragan Vasiljkovic is a false captain who had been brought there by somebody to run that centre in Golubic. I don't see how Korenica could possibly be his zone of responsibility. He may have been there. It's just that the volunteers of the Serbian Radical Party didn't go there by bus. They went there by plane. And they would land in JNA planes to the Udbina air field. It's possible that some volunteers were interviewed by him, and he may have rejected some of them. I don't know about that. But he never had any problem with me on that score. ⁴³⁵⁰⁸ The first time he had a problem with me was in November 1991, when he came to Knin again, because he had come once before and was turned away by Martic. He was in their way, and the officers complained that he didn't know his job and he was trying to teach them. It was the media who spread this story about him as an able officer.

So when he came to Knin to organise that putsch, I met him at the first front line, forward defence line in Benkovac, and that meeting was recorded on camera. I think it was precisely Miroslav Mlinar, whom I mentioned before as the man who had been badly beaten by Croats so that he barely survived before the conflict broke out. So he was the man who recorded my public duel with Dragan Vasiljkovic. I attacked him publicly, saying that he was a criminal. And later when he established that fund to assist the war veterans and their families and the families of those who had fallen in the war, I said that -- and they -- and I said that he stole money from that fund.

Q. I really want to see that -- how the interpreters translated that particular bit when you said that he was trying -- that he was trying to dispense wisdom to the officers. They simply said tried to teach them their job.

A. Well, I don't know English, but I suggest that the records be reviewed after this trial and maybe the interpreters will find better solutions when they have more time after this trial is over. They might find better solutions than what they did on the spot.

Q. So my next question -- on page 16490, Dragan Vasiljkovic says that he doesn't accept that any unit could act independently, and that goes for ⁴³⁵⁰⁹ Seselj's units too.

A. In that I agree with that witness. Nobody there could act independently. Everybody was part of the JNA in that western part of Serbian Krajina.

Q. On page 16513, the witness says Vojislav Seselj, waving a gun, threatened the students of the law school of the university in Belgrade. "The students came to see me, asking for protection, carrying weapons themselves." The witness was worried. He disarmed the children, and he told them to go to the Ministry of the Interior and complain, and if they are not given any protection, he would protect them themselves. He said he had asked Radmilo Bogdanovic to strip Seselj of immunity because of this incident with the students.

Which part, if any, of this is true? Was there an incident at the law school? Was it in the street?

A. Basically, this is false testimony by Dragan Vasiljkovic. There were no students. They were rabble, rabble who attacked me as I was coming out of the building of the Assembly as an MP.

Q. So it was rabble, not students of the law school?

A. There may have been law students among the rabble. They threw stones at me and bottles of water, and when my life was really threatened, when the rabble had come really close, I took the gun out of my pocket, I pointed it in the air and threatened them, and the rabble pulled back immediately. They balked.

In that group, in that rabble there were criminals as well, like Vojislav Bozilovic and Snezana Rajcic, a student and assistant Dean of the ⁴³⁵¹⁰ law school, who were arrested several weeks later for the murder of a shop assistants -- shop assistant in the jewellery called Majdanpek near the Terazije square. That's the kind of students we are talking about.

Q. They were later arrested, you say.

A. And they were convicted. I think this Bozilovic got 15 years' imprisonment for this robbery and murder.

Q. Witness C048, on the 28th of April, 2003, said that Seselj gathered and trained people in Bubanj Potok. Did you gather and train men in Bubanj Potok?

A. At that time when volunteers of the Serb Radical Party were being sent, I was never in Bubanj Potok. When I was serving my regular military service in Belgrade in 1980, on two occasions I was in Bubanj Potok. Once as a young soldier I was taken there to -- for target practice, and another time I as a squad leader took young soldiers there for target practice. That was in 1980.

My collaborators in the party visited Bubanj Potok, perhaps, but I personally never did because there was no need. This was a technical job for volunteers to be taken from the party headquarters to Bubanj Potok. So why should I go there personally? I usually held speeches to these volunteers in front of the headquarters of the Serb Radical Party or somewhere else in the centre of Belgrade. I spoke to them of chivalry on the battlefield, that they should be courageous and that they should be disciplined, and that they should treat prisoners of war, civilians, and the wounded humanely, as true chivalrous knights do. That was the essence of the speeches I made, and many journalists attended these send-offs and ^{43511 BLANK PAGE 43512} they can testify to all this.

Why should I go to Bubanj Potok? I never went to the General Staff at the time either. Why should I? Other people from my party did.

JUDGE ROBINSON: Thank you, Mr. Seselj.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, in these proceedings witness Renaud de la Brosse on several occasions mentioned you in connection with these charges being brought against me. On the 20th of May, 2003, on transcript page 20776, he said Seselj drew up a list for the elimination of some journalists from Germany which he read out on television. When he mentions this list, what is this about?

A. I have not heard any greater nonsense at this Hague Tribunal. I did make statements that I had SS-20 rockets at my disposal and that I would target the American military base Aviano in Italy. This caused panic in Italy. All the media wrote about it. And by this statement I delayed the bombing of Republika Srpska by at least six months. That's how effective this bombastic statement of mine was. But I never made such a statement about German journalists nor did I read out such a list on television. I did know some German journalists. I occasionally gave them interviews. For example, a certain Havlovic, a German who was a correspondent of a German television station. I knew Renata Flot, who was a correspondent of Spiegel.

JUDGE ROBINSON: Mr. Seselj, you might have missed your calling. You should be a PR consultant.

THE WITNESS: [Interpretation] When I leave this prison in some 40 ⁴³⁵¹³ to 50 years, if you offer me such a job I will be happy to accept, Mr. Robinson.

JUDGE ROBINSON: Well, 5th Avenue in New York might be interested. Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, the same witness, Renaud de la Brosse, on transcript page 2805 of the same day said, "Seselj influenced public opinion by speaking of Croatian crimes from World War II." In what context did you speak about Croatian crimes from World War II, and was your intention in mentioning these crimes to influence public opinion in a negative way?

A. First of all, these crimes were truly horrendous, and proportionally greater than Hitler's crimes, because the Croats in World War II committed more crimes and more horrendous crimes than the Germans did when viewed in proportion. This is a historical fact. Secondly, the Serb public was well-informed about these crimes. Thirdly, I did often mention these crimes and the fact that most of the perpetrators had remained unpunished because, with the help of the Vatican, they managed to flee to South America. And the Croatian Ustasha leader Pavelic managed to reach South America with the help of the Vatican. This remains deep in the memory of the Serb people who are afraid that such crimes might be repeated.

As a politician, I was constantly trying to influence public opinion.

Q. I didn't question the fact that public statements made by politicians have the purpose of influencing public opinion. My question ⁴³⁵¹⁴ was did you do this with the intention of causing negative consequences?

A. No. I wanted to cause positive consequences, for the Serb people not to allow such terrible crimes to be perpetrated against them again, to be exposed to genocide again. And Tudjman was openly advocating this, announcing this in his speeches.

Q. On page 2835, this same witness says, "Seselj publicly made threats against the Muslims." Did you in public in your various political speeches threaten the Muslims?

A. No. That's not true. I was constantly trying to win over the Muslims and to avoid a conflict in Bosnia. You can look at the contents of my speech at the large rally in Banja Luka sometime in November 1991, which I held on my return from Western Slavonia. The large Boric Hall [phoen] was full to overflowing.

JUDGE ROBINSON: Thank you. We will adjourn for 20 minutes.

--- Recess taken at 12.18 p.m.

--- On resuming at 12.45 p.m.

JUDGE ROBINSON: Mr. Milosevic, the interpreters have asked me to bring to your attention the fact that when you read from the transcript which you are quoting to the witness, you are reading much too fast for them. You have been reading the transcript evidence of witness -- of Prosecution witnesses, but you tend to read too fast for them to follow.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, there was a witness here, C047. He testified on the 3rd of June, 2003, and the pages of the transcript are 21584 to 588. He states that he met Seselj in 1990 in Mali Stapar, a restaurant owned by ⁴³⁵¹⁵ Aleksandar Nikolic. There, Seselj said there would be war and that he was advocating a monarchy and that an army should be organised to fight and topple communism in Yugoslavia and Serbia. The Croats were exerting pressure on the Serbs in Croatia, and his army was already organising in Western Backa, headed by Jovo Ostojic. Jovo Ostojic organised and trained men for the war in Croatia.

A. These are nebulous statements. This has nothing to do with reality. First of all, I never advocated a monarchy. I have always been a republican. I think only an idiot in the Serbia of today could advocate a monarchy and that no one in Serbia is in favour of a monarchy. That's one thing.

Secondly, I never wanted to topple the communist regime using weapons. And the army, I always advocated the toppling of the communist regime by peaceful means. In 1990, Jovo Ostojic could not have been a member of the Serb Radical Party because it didn't exist at the time. All that existed was the Serb Renewal Movement or the Serb Chetnik Movement. I don't recall any meeting in that cafe.

It's not impossible that I happened to be in Stapar, but this does not correspond to the truth. It's impossible that I could have said something like this.

Jovo Ostojic joined the Serb Radical Party only in 1992. As far as I know, before that he had been a member of the Serb Democratic Party.

Q. On page 21594, this same witness C047 says that the Serb Chetnik Movement was organising to provide assistance to Slavonia, Baranja, and Krajina. Is this correct? ⁴³⁵¹⁶

A. We wanted to provide assistance. This was in 1990. I have already told you that I travelled to Knin, that Milan Babic was seeking volunteers, that I tried to gather volunteers, that your police arrested me for that reason, that I was sentenced to 15 days in prison for a misdemeanour. On two occasions in that year I was sentenced to 20 and 25 days in prison respectively because of demonstrations in front of the federal Assembly in support of the Krajina Serbs. In the year 1990, I took up my candidacy for president of the republic from prison. I appeared on TV only once and gained a hundred thousand votes, but in that year there was no possibility of providing concrete assistance.

Q. Very well. Thank you. This same witness - and these are pages 21601 and 602 - says: "Seselj held a rally in Subotica in 1990 at which he said -" that is at a rally in Subotica in 1990 - "that he would use a rusty fork to gouge out the eyes of non-Serbs, Croats and Hungarians in Subotica who were not loyal to the local authorities." He said that the Croats should be expelled to Croatia and that the Serbs should be returned to their homes. He said the same about the Hungarians. He spoke of the borders of a Greater Serbia from Karlovac to Karlobag and Virovitica. So in 1990 you are gouging out eyes with a rusty spoon at a rally in Subotica.

A. This is an absolute lie. There was no rally in Subotica in that year. What the Serb Radical Party did was in November 1991, it held its first rally in Subotica then, and that meeting was attended by about 5.000 people. Those 5.000 people can testify that I never said anything like ⁴³⁵¹⁷ that. Absolutely not.

The Prosecution is relying on witness Vesna Kljaic, who says that just before that rally I danced a round dance, and I have never danced that dance in my life. I'm not a musical man. I have no sense of rhythm and I never danced that dance. So we are facing nonsense. In June 1991, in --

JUDGE ROBINSON: Mr. Seselj, I think you have answered the question.

JUDGE KWON: I think -- I know you're coming to 1991, but just for the record, the very witness clarified later the year in which you held the rally in Subotica is in 1991, not 1990.

THE WITNESS: [Interpretation] But I am denying that I said anything like that at the rally. I want to let you know that this witness of yours is testifying falsely based on a statement I made in a show called Minimaks Ilic, a comedy show hosted by Milovan Ilic Minimaks, a famous Serb comedian, and I took part in June 1991. When asked directly by him in a facetious tone, "Are you Chetniks still cutting throats?" I responded, "Oh, yes. Only we've changed our methods of slaughter. We no longer use knives, we use rusty shoehorns so that one cannot tell whether the victim was killed by slaughter or died of tetanus." This was black humour. It may not be everybody's cup of tea. I like it. But this was never said at a rally.

JUDGE KWON: It's now for Mr. Milosevic to ask some questions.

MR. MILOSEVIC: [Interpretation]

Q. This comedy show is well known in Serbia, Mr. Seselj, and you have ⁴³⁵¹⁸ explained again now what this was about. So not only did you not hold a rally, but you never said anything like that at any rally, is that so?

A. Yes. Minimaks died a few months ago, and to pay homage to him the Politika TV station in Belgrade broadcast that show again and the Serb public was reminded of its contents. This was two or three months ago.

Q. This Witness 047 says that in Subotica he saw Seselj, Ostojic, and Kertes. Weapons were being distributed; rifles, automatic rifles, and so on. This was done by Seselj, Ostojic, and JNA officers. This is on page 21607 and 608.

A. This is a lie. Jovo Ostojic might have attended a meeting in Subotica. I never met Kertes in Subotica, and there was never any distribution of weapons in Subotica. This witness is lying absolutely.

Q. The same witness, C047, on the same day - the transcript is 21641 - says Seselj held a rally in Subotica and Novi Zednik in May 1992 at which he gave the example of Hrtkovci as to what should be done and how the Croats and the Hungarians were to be forced to leave of their own accord. If they failed to do so, other violent measures should be used.

A. This is an absolute fabrication. I never mentioned Hungarians in any negative context whatsoever. In May 1992, I did have a rally in Hrtkovci on the 6th of May, and at that rally, which was part of the election campaign for the forthcoming federal elections, I advocated the so-called retortion principle. As Tudjman's regime had expelled several hundreds of thousands of Serbs from Croatia, at this election rally I publicly advocated that, according to the principle of reciprocity, Serbia should return this because of the feeling of desperation because of these ^{43519 BLANK PAGE 43520} hundreds of thousands of expelled Serbs, I advocated an exchange of property. I asked that the expelled Serbs look for Croats with whom they could exchange property in order to mitigate this refugee crisis. At this rally, I am alleged to have read out a list of Croats to be expelled. That's a lie. I didn't read out any lists. An activist of the Serb Radical Party --

JUDGE ROBINSON: Thank you.

THE WITNESS: [Interpretation] Very well. I'll stop if you're not interested in hearing any more.

MR. MILOSEVIC: [Interpretation]

Q. You advocated retortion at an election rally.

A. Yes.

Q. Did you ever take any practical measures to carry out this in practice?

A. No. No practical measures. We just promised that if we came to power, but we didn't come to power. What we said then was said out of anger and out of despair at a given moment.

Q. The same witness, C047, said --

JUDGE KWON: Just a second, Mr. Milosevic. In previous answer you said at the end of that part: "At this rally I'm alleged to have read out a list of Croats to be expelled. That's a lie. I didn't read out any list." Then you said "An activist of the Serb Radical Party --" and you stopped. What were you trying to say at that time?

THE WITNESS: [Interpretation] Mr. Kwon, I wasn't the one who ⁴³⁵²¹ stopped. Mr. Robinson interrupted me. But see how overwhelming my respect is that I always abide by what he says. I wish to answer that question, though.

An activist of the Serb Radical Party read out the names of Croats from Hrtkovci who had gone to Croatia and joined the ZNG of Franjo Tudjman in order to wage war against the Serbs there. We have video footage of that rally. And in this same book that I showed a short while ago, The Criminal Pope John Paul II; The Devil's Apprentice, I gave a recording of that rally. We also have video footage of that. I am preparing for my own trial to use that. That is to say, to show it in Court.

JUDGE ROBINSON: You can spare us the exaggeration in language, Mr. Seselj. I don't want any prolongation.

THE WITNESS: [Interpretation] I want -- I wish you could tell me what was so bombastic so that I would avoid doing it in the future, Mr. Robinson.

JUDGE ROBINSON: The reference to the Pope. That's what I characterise as a --

THE WITNESS: [Interpretation] Well, that's a title of my book. What can I do about it?

JUDGE ROBINSON: I don't wish to prolong this. Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, this witness, on transcript page 21720, talked about the promotion of officers on the 9th of December, 1991, signed by Katic, commander of the volunteers, sent by Seselj for a particular part of ⁴³⁵²² Vukovar. What kind of promotion of officers is this signed by your commander of volunteers? Do you know anything about that?

A. No. Slobodan Katic, as far as I can remember, at a given point in time was the deputy of Milan Lancuzanin Kameni in the Leva Supoderica Detachment. I know him very well. He's a member of the Serb Radical Party and a volunteer.

Now, formally there couldn't have been any promotion. It is possible that somewhere someone promoted an officer of his own free will as an arbitrary act, but this was not relevant to the military command organs or was it part of one's service book.

Q. On transcript page 21741, this same witness, C047, says Seselj was in opposition but he secretly collaborated with the authorities. Tell us now, how was it that you secretly collaborated with the authorities?

A. That is quite impossible. Whenever I cooperated with the authorities, I did that openly and publicly. When we supported the minority government in 1993, we did it publicly and openly. And we explained to people why we did not want to join that government. Later, when we went into the coalition, we did that openly. When we were in a conflict, that was open too. In periods of conflicts, there were no contacts between us; and when we cooperated, then there were contacts. I already mentioned those numerous meetings and talks we had.

Q. All right. At any rate, what the witness claims, that you secretly collaborated with the authorities while you were in opposition, is incorrect.

A. It is incorrect. ⁴³⁵²³

Q. This witness says on page 21965 that, "Seselj got a great amount of money when Djuic appointed him vojvoda to fight against communism." Did you really get a very large amount of money from Djuic or anybody when Djuic appointed you vojvoda to fight against communism?

A. That is a fabrication. I earned some money while selling my books when visiting the Serb emigration, and also I lectured in these different Serb organisations that were registered as humanitarian organisations according to the laws there. I never got any amount of money from Djuic. Once he did send some money, in May 1991, that is to say $500. He sent them through a Serb Orthodox priest from America. That money was given out to some volunteers who took part in the fighting in Borovo Selo and who were poor otherwise. I now remember that Miladin Todosijevic got a certain amount. Some was received by Oliver Denis Baret and a few others, but that was the only financial contribution of Momcilo Djuic from the moment when our party came into existence all the way up to his death. We never received any other money from him.

When American congressman Jim Moody was in Belgrade and when he personally requested a special meeting with me, trying to persuade me to have a showdown with your government, and I retorted in very strong words by attacking the ambassador in Belgrade, Zimmerman, because of his anti-Serb policy. He was very angry about this and then Djuic stopped all contact with me. After that, we had only a few contacts but they were really forced.

MR. NICE: The transcript, like the translation, reads 500 dollars. It may be that that was an error. I think it may be 5.000. ⁴³⁵²⁴ It's worth checking.

THE INTERPRETER: Interpreter's correction: The witness said 5.000, interpreter's correction.

THE WITNESS: [Interpretation] This is what a priest brought in May 1991. I think that in the Serb Radical Party we have the name of that priest recorded. I cannot remember right now. He is either from Chicago or Milwaukee, I cannot remember.

JUDGE ROBINSON: Let us move on. Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, this witness says that he thinks that Seselj wrote - and the transcript page is 21995 - part of the programme of the Serb Radical Party in 1991 where it is said that 360.000 Albanians have to be expelled straight away.

A. It's very simple to find that programme and to see what it says. That programme was published in our newspaper, in the newspaper called Velika Srbija, Greater Serbia, it was published in my books, and it says that Albanian emigres should be expelled, those who do not have our citizenship. And the estimate was that from World War II onwards there were 360.000 of them who illegally entered from Albania and engaged in separatist activity. So this pertains to Albanian emigres only, people who did not have our citizenship.

The programme of the Serb Radical Party is something that we worked on collectively, and it is a matter of course that I played the main role in that.

Q. Well, that's not the point here, whether you wrote the programme ⁴³⁵²⁵ of your party.

A. Well, that's only natural. It's a bit tendentious, as if that witness knew exactly which part I wrote. I had the main say in all of this and I took part in the writing of the entire programme.

Q. This same witness says, on transcript page 21997, that on the 2nd of February, 1994, Seselj and Babic had a joint press conference at which they stated that the two strongest parties in the Krajina have to cooperate in promoting a joint objective of the priority national interests of Republika Srpska and the Serb Krajina. Seselj stated then that these two territories should become part of a single state. That was the agreement between Babic and Seselj. After that, the Serb Radical Party became part of the Krajina government.

So this is the 2nd of February, 1994, Mr. Seselj.

A. That statement is partly true and partly untrue. What is incorrect is that after that we joined the government of the Republic of Serb Krajina. We remained an opposition political party. At the beginning of 1994, we went into a coalition with the party of Milan Babic. On that occasion, Milan Babic came to Belgrade. We made public our coalition in the Tanjug press centre in Belgrade. We had a press conference. We published the entire content of that press conference, and it can be found in my books.

At that time, we presented the entire programme of our government, and my personal wish was that the Republic of Srpska and the Republic of Serb Krajina would unite in a single state which would be called Western Serbia. Milan Babic was not inclined to accept that idea at the time. As ⁴³⁵²⁶ far as I can remember, that was not our joint position at the time, it was only my position. We Radicals at that time published a newspaper, Western Serbia, in Banja Luka. Our party in Republika Srpska published it. We thought that this was one of the desirable variants of protecting Serb national interests. However, soon after that Milan Babic betrayed our agreement on a coalition. He entered the government of Borislav Mikelic and from then on we became political foes. Bitter ones at that. We were far angrier with Milan Babic for having trampled upon our agreement than Borislav Mikelic, with whom we disagreed in the first place.

Q. This witness, C047, says on transcript page 21604 that a Catholic church was attacked in Subotica. Do you know anything about that?

A. I know nothing about that attack. For the most part there weren't any such attacks in Serbia. In a few cases this could have occurred as an individual incident, but the Serb Radical Party never had anything to do with any attacks on places of worship. We were never against the Catholic faith. We appreciate those who profess the Catholic faith just like we respect those who are Orthodox and those who are Muslim. We are against the Vatican because of its politics, not because of theology. After all, if you look at the difference between the Orthodox and the Catholics, you will see that these differences are insignificant. For us ordinary believers, these differences are insignificant. Our problem is the politics of the Vatican, not their religious principles. We have the highest respect for those of the Catholic faith, of the Islamic faith, for as long as they are honest and honourable persons and --

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MR. MILOSEVIC: [Interpretation]

Q. A witness testified here under the code name C017. So this is a ⁴³⁵²⁹ different witness, and he mentioned you several times. Let us just go through a few things now. If these allegations are correct. He says on page 22016 of the transcript that he saw Seselj's men in Buna. Buna is a small town near Mostar. I imagine that is the one he's talking about. He testified on the 10th of June, 2003. Were your people there?

A. I don't know whether they got to Buna at all. Volunteers of the Serb Radical Party were within the JNA at the Mostar front under the command of Momcilo Perisic in 1991. That was before the actual war broke out in Bosnia-Herzegovina. This is the time when the Croatian paramilitary formations had taken Western Herzegovina and confronted themselves with the JNA at the Neretva River. That is when volunteers of the Serb Radical Party were sent from Serbia within the JNA to the Mostar front line and --

JUDGE ROBINSON: You have answered that question. You have answered that question.

MR. MILOSEVIC: [Interpretation]

Q. This witness says that at the camp in Buna he saw the headquarters of the Serb Chetnik Movement, that is to say Seselj's men and the White Eagles belonging to Jovic.

A. This is a total fabrication. First of all, there were no headquarters --

JUDGE BONOMY: The question is pointless in view of the answer you've already given, which is that you have idea whether they got to Buna.

JUDGE ROBINSON: Next question, Mr. Milosevic. ⁴³⁵³⁰

THE WITNESS: [Interpretation] But the other thing hasn't got anything to do with Buna. With your permission, I would like to answer.

JUDGE BONOMY: The question that was put was, "The witness says that at the camp in Buna he saw the headquarters of the Chetnik Movement." It's very simple. It plainly has to do with Buna.

JUDGE ROBINSON: Yes. Next question, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. He mentioned on page 22023 that a certain Svabo was commander of Seselj's men. Is that correct?

A. It's impossible that there was a headquarters of the Serbian Chetnik Movement.

JUDGE ROBINSON: No. The question was whether there was a certain Svabo who was a commander of Seselj's men, of your men. Is that correct? We're not talking about the headquarters now.

JUDGE KWON: Ms. Uertz-Retzlaff, I remember some part of this witness's testimony was done in private session. So could you attend to that matter, whether it is all right to mention those parts in public session.

MS. UERTZ-RETZLAFF: Yes. I am aware of that situation. Thank you.

THE WITNESS: [Interpretation] There was a volunteer with the nickname of Svabo. Whether he was engaged in the Mostar theatre of war I cannot tell you now, but I know a very prominent capable volunteer, a courageous one nicknamed Svabo, he lives in Zemun in Belgrade. I can't remember his real name right now. I can find out by tomorrow if that's ⁴³⁵³¹ important. I can call people from my party so they can tell me.

MR. MILOSEVIC: [Interpretation]

Q. It's not particularly important. I just wanted to establish whether he was a commander of some sort and whether there was headquarters of the Serbian Chetnik Movement.

A. There were no headquarters of the Serbian Chetnik Movement and I never heard about White Eagles appearing in that area, not in the Mostar theatre of war. As far as I know, there were no White Eagles there. There were only volunteers of the Serbian Radical Party distributed across the units of the JNA.

Q. I think that would suffice. This Witness C17 says on page 22030, "All Seselj's men had a 27-day training at the camp in Golubic, and they were also in Borovo Selo."

This Golubic camp is in the area of Knin. He says: "All Seselj's Chetniks passed through this training course that lasted 27 days."

A. That camp was run by Captain Dragan. I do not rule out the possibility that certain volunteers of the Serb Radical Party were sent for training there. I don't believe all of them went there. It's impossible. But it's possible that certain individual commands of the JNA had sent some volunteers there for training.

As for Borovo Selo, I explained that in detail on my first or second day here. That was in the end of April or early May 1991, before the JNA openly went into armed conflict with Croatia.

Q. Let's clear up one thing. No matter where your volunteers went for training, that was always organised by the JNA at the time? ⁴³⁵³²

A. Well, they could not apply for training as private citizens. If there was any training, that must have been advanced training compared to what they had learnt during their regular military service. If it concerned handling weapons or retraining for a different speciality, like somebody was a signalsman and supposed to serve as a -- as a gunner now, then they needed additional training. But I cannot tell you exactly because I had never visited that camp in Golubic and I don't know who was sent there.

Q. The same witness says on pages 22036 and 044, he mentions some names and nicknames. Do nicknames Kiza and Vranjanac mean anything to you? Do these people belong to the Serbian Radical Party?

A. Well, they can't mean anything to me because everybody called Zoran has a -- the nickname of Kiza. Even Zoran Djindjic was called Kiza. Vranjanac means somebody who was born in the town of Vranje, so it means nothing.

Q. I will not bother you with the assertions that we've heard here. This witness says during the main offensive of the Muslims in Trnovo in 1995, there was Slavko Aleksic of the Serbian Chetniks. Were there any Chetnik units in 1995 in the area of Sarajevo or was it the army of Republika Srpska? Just briefly.

A. Slavko Aleksic was the commander of one unit of the army of Republika Srpska at the Jewish cemetery in Sarajevo. That was the site of the most frequent and fiercest battles with Muslims. Everybody from that area knows it.

Slavko Aleksic is not a volunteer from the Serbian Radical Party ⁴³⁵³³ who had been sent from Serbia. He is a native of Herzegovina. He lived in Sarajevo, and that's how he joined the Serbian Radical Party. And as soon as the war started, he joined the Serbian army. He became very prominent as a fighting man, and I bestowed upon him the title of Chetnik duke for his merits.

When Biljana Plavsic became a renegade and joined the Western forces, he sided with Biljana Plavsic and I cut off all relations with him. Otherwise, he was a very good fighting man and he was particularly prominent in the battles of Trnovo. He's very famous and very well respected in that area. When you mention his name in Trnovo, everybody will tell you he's courageous and deserves a lot of credit for military success.

Q. Page 22112, this same witness says: "Among Chetniks volunteers, there were many criminals from Sarajevo, more precisely from the Grbavica area." Is that correct or not?

A. That's absolutely untrue. There were no criminals among our volunteers. If a criminal did crop up, we would eliminate him immediately. We took great care and made sure that none were included in our ranks. All our volunteers were part of JNA units.

Q. Would you clarify one thing more precisely, because we are dealing with the testimony of an expert witness for the other side. Reynaud Theunens an officer who testified on the 26th of January, 2004, at transcript pages 31478, and I would really like to have this cleaned up finally. He's talking about the links between the JNA and the Territorial Defence and the volunteers in Vukovar, which has been explained to some ⁴³⁵³⁴ extent already, and he says that Leva Supoderica unit was involved and the commander of Seselj's unit is on the payroll. Was he confused here? Was Seselj's unit part of the JNA or was it a local Territorial Defence unit that became part of the JNA later?

A. Well, I would be only happy if all the units that took part in that war in 1991 were called Seselj's units, but we already established that that unit was part of the 1st Guards Brigade, and of course they were on the payroll of that brigade. There's no doubt about it. I believe the Office of the Prosecutor has in its possession the order whereby that unit was brought under the wing of the 1st Guards Brigade.

Q. The same witness says on page 31482: "Seselj's men are considered as volunteers but in some publications they are referred to as paramilitaries." He's only explaining the references he finds in different documents. Your definition is volunteers within the JNA.

A. Yes. And he obviously comes across these references in documents. However, our political opponents insist on calling them paramilitary units, which is absolutely untrue.

Q. That's what he says here. Some publications called them paramilitaries. But you've just explained there were no cases when volunteers formed paramilitary units.

A. Correct.

Q. On page 31488, he says: "Seselj and his men were within the command structure of the JNA, and they were subordinated to the lowest level."

A. I don't know what he means by that, "subordinated to the lowest ^{43535 BLANK PAGE 43536} level." Does he mean to discredit us or what? They were within the structure of the JNA, and they were never grouped in greater numbers than one company. I hope he was not meaning to offend us. I didn't have my own school to produce military officers. They were all patriots who wished to fight for their country, and in a moment of crisis we sent them to the JNA, and they were not grouped together in greater numbers than one company, not to disturb the structure of the JNA.

MR. NICE: The answer is something of a problem caused by the accused not preparing his materials properly. We've been trying to track down private sessions or otherwise for witnesses. Perhaps this ought to be dealt with in private session itself, I think.

JUDGE ROBINSON: Yes. Private session.

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[Open session]

JUDGE ROBINSON: Yes. Mr. Milosevic, yes. ⁴³⁵³⁹

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj, maybe these several assertions of Mr. Theunens could help confirm your assertions concerning the status of your volunteers, namely on page transcript 31489, Theunens refers to Mrksic's order - Mrksic was then the commander of the Guards Brigade - about the resubordination of the unit in Vukovar, and that applies to Seselj's volunteers too.

On page 31524, Theunens says that one of the JNA commanders in his report said that he had problems with the engagement of certain units, meaning by that Seselj's volunteers and the Territorial Defence, and he says Seselj's volunteers participated in operations in Vukovar under JNA command. So he refers to this document.

Then on page 31692, Theunens, their military expert, says that he had seen the war journal of the Guards Brigade referring to Seselj's volunteers.

This is related in a way to what you said, namely that your volunteers were within the JNA.

A. Yes. Our volunteers were always part of the JNA. I keep repeating that most emphatically.

Q. Witness D1804, who testified on the 10th of February, 2004, page 31832, says that when the conflict began, volunteers such as Seselj's men, but he speaks in general about volunteers, participated in operations under JNA command.

To the best of your knowledge, was that general practice, namely that volunteers could only go as part of the JNA, apart from those who ⁴³⁵⁴⁰ wanted nothing to do with the JNA, such as the Serb Guard?

JUDGE ROBINSON: [Previous translation continues]... this business of reading out the transcript, going on and on and on. If you have a specific question, just raise it. And we don't want repetition.

THE ACCUSED: [Interpretation] This is about Witness B. This was used by Mr. Nice to denote witnesses testifying about Bosnia. So this is not about Croatia. He says on page 31832: "When the conflicts broke out, volunteers such as Seselj's men participated in operations under the command of the JNA."

MR. MILOSEVIC: [Interpretation]

Q. My question, Mr. Seselj, was as follows: Was it so according to your knowledge?

A. Yes. When the armed conflict broke out in Bosnia, volunteers of the Serb Radical Party within JNA units participated in those conflicts. I mentioned the example of Zvornik. Before that, it was the Mostar theatre and several other locations. There is precise documentation about this in the General Staff of the JNA as to where they were sent and where they participated. It's no secret. I am proud of the participation of volunteers from the Serb Radical Party.

JUDGE ROBINSON: Yes, next question. Next question.

MR. MILOSEVIC: [Interpretation]

Q. The next question concerns paragraph 34 of the Croatian indictment. We have not yet mentioned this paragraph, although it will seem very familiar to you because it's the same text running through all the paragraphs more or less. So look at paragraph 34 and tell me when ⁴³⁵⁴¹ you've found it.

A. I have found it.

Q. It says here -- let me just -- "From on or about the 1st of August, 1991, until June 1992 --"

JUDGE ROBINSON: Mr. Milosevic, just ask the question. Just reflect the substance of it. There's no need to read out the content.

MR. MILOSEVIC: [Interpretation]

Q. Very well. It says here that I acted with participants known and unknown of the joint criminal enterprise and that I planned, instigated, ordered, committed, or otherwise aided and abetted and so on the planning, preparation, or execution of the persecutions of the Croat and other non-Serb civilian population.

As you also are accused of this, tell me, did you in any way plan, instigate, order, commit, or otherwise aid and abet the persecution of Croat and other non-Serb civilians as mentioned in this paragraph, and according to what you know, did I in any way plan, instigate, order, and so on and so forth, what it says here in this paragraph 34?

A. No. Neither I nor you nor anyone else on the Serb side planned, instigated, ordered or aided and abetted or committed the persecution of the Croat and other non-Serb civilian population. This was not done systematically. It was not done in an organised manner. There were incidents where this was done, but all these incidents can be listed and the perpetrators can be identified.

Q. Can you, with respect to anyone on the list of alleged participants in the so-called joint criminal enterprise, can you identify ⁴³⁵⁴² anyone in that list who may have planned, instigated, ordered, committed or otherwise aided and abetted this?

A. You know that I have a negative opinion of many of them.

Q. I know that.

A. But as a serious witness I cannot say so-and-so did that but I did not see it. I was not an eyewitness. If any of them did anything like that, I attacked them publicly at the time, but I was not an eyewitness to what Aleksandar Vasiljevic was doing apart from what I learned for certain that he had done in Vukovar, Western Slavonia, and so on and so forth. I was not an eyewitness to what Arkan did.

JUDGE ROBINSON: Yes. Thank you. You have answered the question.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Seselj --

MR. NICE: Your Honours, I don't know if you're about to bring the hearing to a conclusion. If so, can I just confirm the position in respect of the matter raised in private session. It was as I -- perhaps we better deal with it in private session.

JUDGE ROBINSON: Yes, private session. Yes.

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[Open session]

JUDGE ROBINSON: Yes. We'll adjourn until tomorrow at 9.00 a.m.

--- Whereupon the hearing adjourned at 1.47 p.m., to be reconvened on Thursday, the 1st day

of September, 2005, at 9.00 a.m.