³²⁰

Friday, 15 February 2002

[Defence Opening Statement]

[Open session]

[The accused entered court]

--- Upon commencing at 9.30 a.m.

JUDGE MAY: Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] I think that I have presented ample arguments against the false allegation of the Prosecution that for the Serb refugees from Republika Srpska and Krajina, that we had settled them in Kosovo and Metohija and changed the composition of the population there. I have data showing that there was a total of 5.000 refugees in Kosovo from Republika Srpska and the Serbian Krajina. In relation to the total number of refugees in Yugoslavia, that up until the war and after Dayton reduced from 1 million to 700.000, so in relation to this number of 700.000, 5.000 is less than 1 per cent. Or to be quite precise, it is 0.7 per cent. And if we bear in mind that the territory of Kosovo counts for 10 per cent of the territory of the country, then it is quite clear that proportionately in this territory, this part of the territory of the country, the number of refugees was fewest, which is only logical because nobody wanted to go there and nobody forced the refugees to go to a particular place. And if this figure were to be compared to the total population, then even the share of 0.7 per cent would become much smaller, in fact, negligible. So the entire idea of the change of the population structure falls, as does the idea on alleged deportations that I have already referred to, but I will come back ³²¹ to that, too, later.

I can tell you that not even the terrorists expected such harsh allegations. And the day before yesterday, when the Prosecution ended its opening statement in regard to Kosovo there were celebration over there. And in doing so, I'd like to tell you that you're only encouraging terrorism that is still going on over there, but I'll come back to that too.

Let me continue now. The movement of Albanians from Kosovo was of strategic importance for the Clinton Administration to win the support of the media and public opinion, confirmation and justification for what they were doing. The airstrikes were so fierce that at that time even in Kosovo, even wild boars from the mountain of Cicavica swam over the Cicavica River, something that never happened before. As for the population, I wish to underline that under the threat of bombs, more than 100.000 Serbs also fled to Kosovo. And this is an official figure of the International Committee for the Red Cross in Geneva. And if you had wanted to view the totality in a serious manner, you should not have omitted this because these are figures of the body responsible for refugees, and they are probably the most relevant data that you should have relied on.

Anyway, you can look up the figures regarding Serb refugees in Macedonia and you will see how things stand. And surely you have access to those data as well.

Therefore, simultaneously with the fierce bombing, the KLA terrorists forced all Albanians that did not leave Kosovo upon their ³²² orders and the requests of NATO and under pressure of leaflets and horrific round-the-clock bombing. So they referred to all these Albanians who did not leave Kosovo as traitors because they betrayed the wartime concept which should have created the illusion of an exodus of the population before what you are referring to as the Serb forces. Simply the allegations of Albright, according to -- of Serb deportations needed to gain confirmation. And there were hundreds of cameras waiting at the borders to examine the witnesses of alleged Serb misdeeds and to perform that part of the media war.

This same thesis is one of the main tasks that need to be accomplished by this false indictment, to persuade the world that Serb forces performed deportation, which is a notorious lie. However, even towards the end of the second month of the war, all those combined crimes, the bombing and destructive ones, the media and terrorist campaigns still failed to produce satisfactory results.

So it was decided that new and bloody and murderous messages should be sent to the Albanians that they had to leave, and that is why on the 13th of May, 1999, exactly one month to the day since the previous massacre and destruction of the Albanian column of -- column of Albanian refugees about which the public was informed yesterday, another mass crime was committed.

For one of those crimes - I cannot tell you with precision, but we will find out later whether it was the 13th of May or the 14th of April - for one of those crimes of the bombing of Albanian refugees, we intercepted a talk between the pilot and the command centre and broadcast ³²³ it on our television. The pilot says that it is not a military column, that he can see tractors, peasants, civilians, and the response from the command is, "Carry out your orders," and he struck at the column. And so on the 13th of May, 1999, on the main road from Prizren to Suva Reka, at a crossroads near the village of Korisa, which is Prizren municipality, NATO forces bombed a column of between 500 and 600 Albanian refugees who were returning to their homes in the village of Korisa. So after two months of war they are still returning home, though you were claiming that the Serb forces are forcing them out. And because they are returning home, they were being bombed by the NATO Air Force. In that massacre, dozens of persons were killed, and according to initial reports, some 50 were killed and many more succumbed to their wounds later. But this is a highly eloquent, though drastic example of the suffering of people to complete the pattern that the aggressor had set as an assignment and an explanation for the crimes it committed in Yugoslavia.

Will you please show the photographs of this crime committed against Albanian refugees, on the 13th of May, 1999. Will you please show photograph by photograph and not two at the same time, because you can't see them well.

Carbonised bodies, the remains of the victims. Overturned tractors.

This is a semi-carbonised body next to a destroyed tractor. The remains of carbonised bodies of the victims. These are remains of carbonised bodies of three persons in a ³²⁴ tractor-trailer, and there's hardly anything left of them to be seen. Carbonised remains beneath the tractor.

You see the child that was killed, one of ten babies killed in the column of refugees.

Another child from the refugee column killed. Another killed child from the refugee column.

One of 26 children that were killed when the column of refugees was bombed. One of 26.

Again, carbonised bodies of the victims from the column. Carbonised bodies on the tractor-trailer.

A semi-carbonised body. The same images of carbonised corpses.

A male victim killed during the raid on the column. The body of a baby killed in the column.

A young boy. A child, again.

A woman. This is just the ground.

This is one of the children. It was not possible to send a more horrific message -- the Prosecutor is probably bored; I see him yawning. A more horrific message could not have been sent to the Albanians who were returning to their villages, that that is prohibited. Who returns will be shot at. He has to pay his disobedience with his life. He has to abandon Kosovo. He has to justify the previous premise that all are fleeing from the Serb ³²⁵ forces. And the Serb forces were trying to save them; they assisted them, they transported them to the hospital, even to the most elite medical institutions, even to Belgrade and not to Pristina and other towns in Kosovo.

I should now like to draw your attention to the fact that, in that fury of failure and fiasco of the attack on Yugoslavia, and the persistence with which its policy was being implemented, a special characteristic of the bombing was that of inhabited areas. In the south of Serbia there is a small, poor town of Surdulica. Very hard-working people live there. They are known for their diligence and goodness.

On the 27th of April, 1999, this small town of Surdulica, in which there is absolutely no facility which might justify it, though there is nothing that can justify the targeting of any facility in an illegal aggression whereby the charter of the United Nations had been violated and which was not allowed by the Security Council, whereby all the norms of international law and the statute of NATO were infringed upon, cannot be justified. But this is a unique crime. Please look and see how a small town in the south of Serbia was totally destroyed. We know from history of individual towns. We know of the village in Czechoslovakia, the only one destroyed by the Nazis during the Second World War, and it remains a symbol of crime. These new ones, this time so many villages were destroyed that each one of them could be a symbol of crime, even for those Nazi days, only many times over in this case. These are the remains of Surdulica, what is left of the town after ³²⁶ the airstrikes. For instance, this is the destroyed house from which ten bodies were uncovered.

This is the immediate vicinity of where the rocket struck. These are views of the less damaged buildings which were, as you can see, totally destroyed only they were not razed to the ground. And by the degree of destruction it is quite visible that no one inside could have survived.

These are also destroyed houses in Surdulica. Virtually one can only see the ground on which they stood. They have been razed to the ground.

The same thing. Here the streets and house numbers are indicated, which is not relevant at this point in time for what I am saying, because I'm talking about the town as a whole. You see what the remains look like, as if there was nothing there anyway.

And this is a part of the bodies of the victims who were pulled out of the rubble on that first day, because the documents date to that period.

On the 28th of April, another horrific, savage attack on Prizren and Jablanica, also in Kosovo and Metohija. May we now see those pictures, please. Perhaps these photographs are the best commentary. They require no comment, in fact.

The old part of the town of Prizren where some 50 houses were destroyed belonging mostly to the Romany people, the Romany ethnic group. Four were killed and 20 other persons seriously injured. That was on the 28th of April, 1999. ³²⁷ This is another detail. It is another spot where Zuljfiri Drenis died, and Zuljfiri Djula, Becir, Kasandra Zuljfiri, and Maksum Zuljfiri. This is what it says on the caption. That took place on the 28th of April, 1999.

Prizren had a mixed population, Serbian, Turkish, and Albanian. In Prizren, people lived a normal life in harmony. And when I visited Prizren on one occasion, everybody told me that, the presidents of the political parties, all the sides, the priests and the imams and the fathers, all of them. And that was precisely the impediment, that kind of life in Yugoslavia.

This is one the corpses being taken out from the rubble. Here you can see some feet. They belong to a three-year-old child, a little girl. Some more destroyed houses in Prizren. Again the same thing. Once again Prizren, and some Muslim houses again. This is a bombed village, the village of Jablanica, on the 1st of May. And some 20 houses completely destroyed, more than 50 houses in ruins, people killed.

Here these are the houses of the Murati family that were completely destroyed, and the inhabitants died, too, on the 1st of May, 1999. Once again the body of Ahmet Murati being taken out from under the rubble, who was killed in Prizren.

This is a damaged mosque. It was damaged on the 1st of May, 1999, in that same bombing operation.

The Kula settlement in Prizren that was bombed. And there seven people were killed and 15 others seriously wounded, most of them ³²⁸ Albanians. About 50 houses were destroyed. And that was on the 1st of May, 1999.

This is where the rocket hit, and so on and so forth. This is the total destruction of the houses belonging to the Berisha household. They were Albanians. They were all killed practically, four of them on the spot, and seven were very seriously injured.

Here you can see members of the police, the army, and Civil Defence taking out the casualties from the Berisha household. Once again, these people are saving an injured woman from the Berisha house, Meta, in Prizren on the 1st of May, 1999.

This is a child that was killed and pulled out from under the ruins, also on the 1st of May, 1999, in the Kula settlement of Prizren. On the 30th of April, a house was targeted in the centre of Belgrade. It was a residential building, undoubtedly so. It could not have resembled any kind of administrative or official building. And on the 1st of May, once again, the villages of Bitanovac and Sacevo [phoen] near Kraljevo. I'm not going to show you these photographs one by one. I will provide a set of photographs to save time, but in this set of photographs you will be able to see the bombing of Sremska Mitrovica and the corpse of a young woman. On the 2nd of May, the bombing of Valjevo. Here you are.

These are the destroyed houses in the village of Bitanovac near Kraljevo. This is a whole household destroyed. Zace, near Kraljevo. A whole residential block destroyed in Valjevo on the 2nd of May. ³²⁹ Once again, a residential building destroyed, with a number of apartments, also in Valjevo on that same day.

This is a residential building in Belgrade in a residential area, but I don't think I need comment when you see that a whole homestead was picked as a target in a small village, as if somebody was training or playing a game and trying to see who he would hit, who he would kill. On the 5th of May, at 1430 hours, which is just about the end of the working day in our country, when people go home from work, a densely populated area of Novi Sad was bombed. It was called the Detelinara, and that was a large neighbourhood, district. The projectiles fell right next to a primary school and in between residential apartment blocks and completely destroyed the apartments and homes in all these residential blocks in that particular street. You will be able to see photographs of that, photographs of Novi Sad. And Novi Sad suffered enormous damages. All the bridges in Novi Sad were destroyed. The Danube was cut off. There was no -- there were no water supplies. Residential areas were targeted in Novi Sad and so on.

On the 7th of May, between 0255 to 0425 on two occasions, that is to say, during the night, in the middle of the night when people and children are fast asleep, the residential part of the town of Nis and then the industrial district of Nis were targeted. And the greatest destruction took place in the village of Medosevac in which tens of houses were destroyed and damaged. Many people were killed and wounded. And on that same day, in the middle of the working day, from 11.30 in the morning until 11.45, just before noon, the NATO Air Force threw two ³³⁰ containers with cluster bombs, and one of them, one of these containers hit the south-eastern part of the town with the medical clinical centre located there. The cluster bombs were fragmented around the hospital and in front of the department of pathology of the clinic, whereas the second container was thrown into the heart of town, which is where the university headquarters of Nis were located as well as the medical centre, a large central city market which at that time of day is full of people. People were killed at stalls. Then we have the Nis fortress, which was a historical monument too.

Many people died as a result of the cluster bombs, and we will be providing the public with the list. For practical reasons I'm not able to bring the lists in here and read them out.

May we now see, please, a few photographs which will illustrate Nis, what happened in Nis, Medosevac, and the bombing of Novi Sad. It doesn't matter what order you take them in because I have briefly explained what they are about, and I think everybody will be able to see for themselves.

These are the destroyed houses in Medosevac. Fourteen people were killed here, although there doesn't seem to be much destruction to houses because the cluster bombs did their job.

Here we can see the remnants, remains of the cluster bombs. Cluster bombs, you know, don't destroy houses, but they do kill people, and they are a prohibited weapon.

This is the corpse of Ljiljana Spasic. She was seven months pregnant and it lies at the corner and intersection of two streets. She ³³¹ was killed there at that corner where the cluster bombs were used. This is another damaged house in Medosevac. It is one of the approximately 50 houses that were destroyed and damaged on the 7th of May, 1999.

This is a crater left by a large bomb which practically incapacitated all of the residential buildings in that part of Novi Sad on the 6th of May, 1999. A figure of 100 apartments is mentioned here as having been destroyed or, rather, 100 families left without a roof over their heads. In just that one part.

This is part of Djuro Molnar Street where the primary school was damaged and with the residential blocks located around it and cars that have been submerged by the earth.

The terrorisation of Novi Sad and terrorisation in general of that part of Serbia is quite a specific goal, target, because in that part of Serbia, 27 ethnic groups live in harmony together. There were never any nationalistic conflicts or incidents, and that is why they had to be destroyed.

On the 7th of May, at 2350 hours, the building of the Embassy of the Peoples' Republic of China was targeted. In that building, the building of the Chinese Embassy, diplomats were killed and journalists were killed, and all the statements that were made as to the error or mistakes that were made are completely untruthful. First of all, they justified it by saying that it was a mistake because there had once stood a military building there and they didn't have an updated plan. That was a notorious lie because the Chinese ³³² Embassy in the area of Belgrade was built on an open space of land. It was a modern villa, palace, and many Western diplomats and spies would attend receptions and various ceremonies held in the Chinese Embassy, and they would take back reports about what they were given to eat for dinner and what the furniture looked like in the embassy and what the teacups looked like. And then they say that they didn't know where the Chinese embassy was.

The largest number of strategic buildings that were targeted were targeted on the basis of intelligence reports, and all these hundreds of diplomats, all of them supplying information and intelligence linked to targets just didn't simply know where the Chinese Embassy was in Belgrade.

It is quite clear, especially when we know that the attack was launched directly, even without the knowledge of some other NATO members, directly from the United States by planes which are only used for strategic targets at long distance, it becomes quite clear that Clinton wanted to go down in history as the first man to have bombed Chinese territory by bombing the Chinese Embassy in Belgrade. Otherwise, when in Rambouillet our legal team -- when our legal team in Rambouillet discussed part of a document which the American representatives offered up, and they made the remark that this was professionally very poorly done, it was poorly written from the legal aspect, the answer he got, a spontaneous answer, was how can you say it was so bad when it written by the same man who wrote the document about the autonomy of Tibet, if you please. This was no accident, just as in the case of many other things ³³³ related to these matters. Only somebody who is not allowed to see that, or dare not see that, can believe that this is some kind of a mistake, or that somebody did not know.

The village of Orljane, by Doljevac, I'm taking this only as an example of an insane, pointless thing. They were targeting peasants who were plowing their fields outside the village. Actually, it was a woman. I will show you the field itself, the maize. There is nothing on this picture. Only if you were to use a magnifying glass, perhaps you could see something in the distance, but there is only this killed woman. This was a savage game where people were targets.

On the 11th of May, Murino, near Plav, in the municipality of Plav, in Montenegro, was hit several times, this poor, small town of Murino. The population sought shelter in the surrounding areas, in surrounding villages over there, as in Kosovo, over there like everywhere else where bombs were falling. You will see the pictures from Murino. You will see the pictures of a little boy called Daniel who, on the 16th, in Vrbovac, near Vitina, was killed by a cluster bomb. On this first page it seems as if somebody had shot him from a hunting rifle. He is so badly hit, there are so many small wounds on his body, and on the other picture you will see that his limb was blown off, his leg, and that he was practically turned into an invalid.

I did not show you pictures of the building of the Chinese Embassy or the corpses. These images were shown all over the world. I believe that this is not a shortcoming in my statement, and I don't think that the Prosecutor will say that I do not have proof of the Chinese Embassy being ³³⁴ bombed.

Look at this field. There's nothing here and there is the killed woman. They kill a village woman, working in a field, from an aeroplane. Here she is. This is Doljevac on the 11th of May, 1999. The woman's name is Jagoda Mladenovic. She was killed as she was plowing her field. This is an example of bestiality, targeting people this way. This is what the houses that were destroyed near Murino looked like, near Plav, in Montenegro.

This is also Murino. This is this small town that such a misfortune had befallen. On the 18th of May, 1999, Jasenica, near Valjevo, was targeted. There is sufficient evidence of that as well, photographs included; also pictures of killed people. You will see Milka Krunic from the village of Jasenica. She was killed in her own house. Also you will see the destruction of the village.

On the 21st of May, in Sombor, houses. Sombor is in Vojvodina. You will see more about that as well.

On the 21st of May, Djakovica, in Kosovo and Metohija. On the 25th of May, Sabac, at 1305.

On the 25th of May, Nova Pazarska Banja. On the 26th of May, at 8.30, the village of Radost, the municipality of Orahovac, between the railroad and the Beli Drim River. Again, it was Albanians that were killed. You will see the corpse of a child, an Albanian born in 1988, from the village of Radost, near Orahovac, among others. ³³⁵ On the 26th of May, at 2310 hours, Ralja, a village on the outskirts of Belgrade. This family sought shelter at their weekend cottage, at the house that they originally came from. These two children, Stefan and Diana Pavlovic, were killed while they were asleep in their home. You will see that as well.

Could you please have these photographs shown. I'm trying to show these photographs set by set so that you could bear in mind what I had said in connection with that.

This is Jasenica, near Valjevo, where Milka Krunic was killed. This is a house that was destroyed on the 18th of May, 1999, in Jasenica, near Valjevo.

This is the corpse that I have been speaking about. Fifty houses in Sombor, on the 21st of May, in Vojvodina. This is the street of Vuka Karadzica. The owner was born in 1940.

A burned house, a demolished house, on the 21st of May, in Sombor.

You can proceed. This is in Djakovica. Ibrahim Cosi, an Albanian who was killed right there in his own house, you can see him here on this picture. This is from Sombor. There is probably another page before the previous one, but let us go on.

Also Sombor, the street of Svetisava. Go on. This is in Sabac, when Sabac was targeted.

This is Nova Parzaska Banja, over 30 houses in Nova Parzaska ³³⁶ Banja.

In this area near Novi Pazar, there is a population of Serbs and Muslims. This is a corpse of a child, Kajtomika [phoen] Strati, from the village of Kastrati, born in 1988. While he was tending to his flock together with his friends, he was killed by NATO bombs. This is the cattle.

You can go on. These are corpses of children who were killed while they were asleep. This was during the bombing of Ralja, a village near Belgrade, at 11.30 at night. They were in their pyjamas.

These were destroyed houses on the 26th of May. These are what the houses looked like. This is Ivanovic, whose daughter Biljana was killed, and so on and so forth.

Yesterday I spoke to you about the destruction of a small mining town called Aleksinac, where people work in coal mines, in pits. I spoke of the major crime that was committed by NATO on the 5th of April. On the 28th of May, that is to say, a month and a half later, or perhaps even a bit more than a month and a half later, at 30 minutes past midnight, again Aleksinac was attacked. As a matter of fact, with 14 rockets. The centre of the town of Aleksinac was hit by seven rockets, and one hit the area of the municipality of Sverlig as well. And then there is a list of everything that was totally destroyed. Aleksinac should be shown separately. Please, could you show these photographs.

Why Aleksinac in such a savage manner and for a second time at ³³⁷ that? That's a pointless question, because this entire war was pointless, and it constitutes a crime. Those who come to kill children who are asleep can hardly sleep peacefully themselves if they are human at all and if they have any kind of moral sensitivity.

That's the corpse of Biljana Momcilovic. Please go on. Please show the photographs in the same order in which I gave them to you.

This is the point of impact where people were killed and wounded on the 28th May. Spring had already started. It's green but there are no more houses left.

Please go on. These are destroyed houses. The names of the people who were killed are listed here. Husband, wife, daughter, seriously wounded, killed. Sisters, et cetera.

This is also one of the victims from Aleksinac, Dusanka Savic, killed in a neighbour's house.

These are also victims of the bombing of Aleksinac. Destroyed houses in Aleksinac again. The dead were pulled out of the rubble. This man was pulled out of the house that you saw a minute ago. Branko Mitrovic is his name. Totally destroyed houses in Uzicka Street in Aleksinac.

This is the 28th of May in Aleksinac. Eighty houses, most them in Uzicka Street and Niska Street.

These are houses destroyed in Petrovaradin near Novi Sad on the 29th of May, 1999. This is one of the destroyed houses in Petrovaradin, the settlement of Ribnjak in Novi Sad. ³³⁸ On the 29th of May, Cumurlija was bombed near Nis, and here, too, you will see the ruins and the bodies.

On the 29th of May Cuprija was bombed again when more than a hundred civilian buildings were destroyed and damaged. You will see some of the points of impact of some of the projectiles on the 30th of May. Family homes were bombed, and the village cemetery in the place Drvenik near Raska. You will also see the houses and the cemetery. The living and dead Serbs, but on these are only the dead, but both the living and the dead were bombed.

On the 31st of May, Ripanj, a village near Belgrade. Again you will see the bodies of women. Also on the 3st of May, Ripanj, destroyed houses.

The 31st of May, the village of Drazevac, near Obrenovac. Again women were the victims.

On the 3st of May, a very heavy airstrike was conducted on Novi Pazar. This is the area I referred to where Serbs and Muslims lived together. They are the dominant ethnic groups. And the attack was against a residential part of Novi Pazar. On the first strike 11 were killed and an enormous number seriously injured. I don't have data for those who succumbed to their injuries later.

The elementary school was damaged, so was the medical centre, Jedinstvo, a large number of family homes, the bus station and so on. That was the worst crime that was committed in Novi Pazar since Novi Pazar has been in existence in new Yugoslavia.

On the 8th of June, at 0015 hours, again the area of Novi Sad was ³³⁹ attacked. This time the neighbourhood of Sangaj. Because it is quite obvious, as the dates indicate, residential districts and settlements were always struck at night when they were sure that people were asleep inside and they would get killed.

You can show this set of photographs, please. This is Cumurlija with which this series of photographs begins. I mentioned the woman who was killed.

This is Cuprija, the air raid of the 29th of May, 1999. One hundred civilian buildings destroyed and damaged in Cuprija on that day. A small town. One hundred civilian buildings.

This is the point of impact of one of the projectiles, again in Cuprija. These are destroyed family homes and the village cemetery in Brvenik near Raska on the 30th of May. This is also Brvenik in Raska on the 30th of May. This is the destruction and damage of 17 tombs at the village cemetery in Brvenik near Raska.

Next, please. This is Ripanj, a village near Belgrade, showing the house in which the owner, a woman, was killed on the 31st of May, 1999. Her name was Slavica Stojiljkovic. Here is her body. This is again in Ripanj, a house destroyed, and the names of the victims. The appearance of the crater in Ripanj, a village near Belgrade.

This is Novi Pazar. This is in the vicinity of the bus station. On this spot that you just saw, 11 people were killed. These are destroyed houses in Novi Pazar. You see here people being pulled out of the rubble. Again a view of damaged buildings where Djordje Pantovic was ³⁴⁰ killed in his own shop. This is the victim.

Golub Ratkovic, born in 1953. He is from Novi Pazar. Dragan Simovic, born in 1953, also from Novi Pazar. Miodrag Nikic, born in 1970. Zvezdana Jajic, born in 1962, also from Novi Pazar. Simic from Novi Pazar. A child, Vladan Simic's child, called Marko Simic, born in 1977 in Novi Pazar. Dejan Milosevic, born in 1973, from the village of Saronje near Novi Pazar. The remains of Mirko Roglic, born in 1983, also a victim from Novi Pazar.

These are destroyed houses in Novi Pazar, destroyed on the 31st of May. About 40 houses were destroyed on that occasion. A close-up view of some of the houses.

On the 20th of May, five minutes after midnight in Belgrade or, rather, over Belgrade, an airstrike was carried out on the Dr. Dragisa Misovic clinical hospital centre. It is a large hospital centre, one of the best known in Yugoslavia. It is situated in Belgrade, as I was saying in the Bulevar Mira or Bulevar of Peace.

The neurological clinic was struck of the clinical centre, and patients were killed, of course. Patients were also killed in the intensive care unit. In this strike, all the buildings within the complex of the clinical centre were damaged, including the maternity ward, the gynecology and obstetrics department, and the children's hospital for tuberculosis and lung disease.

There is no one in Yugoslavia who does not know of the Dr. Dragisa Misovic clinical centre. And it is also situated in the residential part of Belgrade where virtually all representatives of the Diplomatic Corps ³⁴¹ reside, at least as far as the ambassadors and senior diplomats are concerned. I will show you a few, only a few, photographs from the Dragisa Misovic clinical centre.

I don't think there is any point in my commenting on these photographs. These are all patients from the neurological department of the hospital. The patient is Zora Brkic. The pictures speak for themselves.

This is the surgical theatre, which was also damaged. Another patient of the neurology clinic. His name was Radosav Novakovik, and he was killed in the hospital.

This is the intensive care unit or, rather, what was left of it in the neurological clinic.

Please proceed. This is the interior of the central part of the destroyed neurology clinic and the place where the body of Branka Boskovic and Radosav Novakovic were found.

These are all victims. Please go on. This is what the destroyed neurology clinic looked like on the 20th of May, 1999. Again a view of the buildings of the clinical centre Dr. Dragisa Misovic.

This is the institute for urology and nephrology and a patient's room after the raid.

I mentioned Surdulica to you, describing it as a small town in the south of Serbia that was bombed and in which people were killed and the town itself virtually razed to the ground. On the night of the 30th and 31st of May, 1999, Surdulica was struck again, only this time it was the ³⁴² sanitorium in Surdulica that was directly struck. It is a specialised hospital for lung disease, a sanitorium, in the south-eastern part of Surdulica. And the projectiles fell not only on the hospital for lung patients but also a building of the old people's home and hitting virtually everything in the vicinity.

The targeting of the sanitorium, I find it difficult to rank those war crimes, to rate them in any way. You are lawyers whose speciality this is, and you probably have your own idea about that, because all these crimes are grave. But striking a sanitorium full of patients is something that probably the person who did it should explain, and I hope he will. Please be kind enough and show these few more photographs. I've reduced the number of photographs of the sanitorium. These are bodies on the balcony of the sanatorium building. These are photographs taken immediately after the strike so that most of the people were not identified.

The head of Dusan Manojlovic, born in 1927, it was found in front of the sanatorium.

Stamen Rangelov, from the village of Bozica, in Surdulica, who was killed in the laboratory premises.

The bodies pulled out of the sanatorium building. As you can see, a yard full of bodies on that morning.

The bodies of a mother and daughter, Bosilka Malobabic and Milena Malobabic. They were refugees from Karlovac.

These are again the bodies of victims. These two were refugees from Korenica. ³⁴³ Again, victims from Duga Resa.

These are the bodies of the people killed in the old peoples home attached to the sanatorium, and their names are listed here. They were from Vladicin Han, the village of Kalemance, which is in the neighbourhood.

This is again the body of a victim pulled out of the rubble, Napilo Dragic.

Again, a victim, a woman, Bogdanka Janjanin, born in 1925, from Vrhin Most.

Slavko Popovic. Two hospitals, one after the other. As you saw, the clinical centre Gragisa Misovic, and then the sanatorium in Surdulica; in the former, a clinical ward, and in the latter, an old peoples home as well. I have many documents about the bombing of cultural facilities. But I will place this at the disposal of the public and to you. It consists of 20 pages. I'd rather not read out now those 20 pages of documents, but they refer to the destruction of cultural facilities in Belgrade, in Nis, in Nova Pazar, in the Nova Pazar Banja or spa, in Gucevo, Novi Sad, Vrdnik, Ursac, Kapaonik, Kursumlija, Balenac, Smaila, Zablace, Zvetne, Priline, Svrtenik, Djunis, Krcmar, Pancevo, Grcanica, Draganac, Kragujevac; a large number of facilities, almost as many as in Belgrade. Decani, Goracevac, Cacak, Valjevo, Kadinjaca, Velika Hoca, Sreckovac, Bustranja, Vinca, Belo Brdo, Gornja Nerodimlje, Zitoradja, Smederevo, Palis, Sabac, Gazimestan, Tekeris; the villages in the environs of Kraljevo, close to which such cultural monuments are to be found, ³⁴⁴ Cuprija, Trsnik, Mrsac. I have listed only the names of the localities in which several cultural monuments were bombed, and the review consists of 20 pages.

I should now like to mention the bombing of the prison.

JUDGE MAY: If you're moving on to another topic, that would be a convenient time for the adjournment.

Mr. Milosevic, how much longer do you think you're going to be?

THE ACCUSED: [Interpretation] I don't know exactly because, as you know, I have no conditions to prepare in, nor do I have any assistance, so I really don't have any idea how long this could take. But I assume that I've covered one half, I assume I've covered a half. I'm sure I have. One half of what I would like to say.

JUDGE MAY: Well, we shall expect you to finish this evening. That will give you two days, which was the same as the Prosecution had, and it seems a reasonable amount of time.

THE ACCUSED: [Interpretation] I don't think you should limit this statement of mine, regardless of whether the Prosecution had two days or not. After all, yesterday --

JUDGE MAY: We will determine -- we will determine what is a reasonable amount of time for you to make a statement, as we have to have regard to the amount of time taken up by this trial. Yes, we'll adjourn now until half past eleven.

--- Recess taken at 11.00 a.m.

--- On resuming at 11.30 a.m.

JUDGE MAY: Yes, Mr. Milosevic. ³⁴⁵

THE ACCUSED: [No interpretation]

JUDGE MAY: We have no interpretation.

THE INTERPRETER: The microphone was not switched on for the speaker.

THE ACCUSED: [Interpretation] Could you please tell me the amount of time that I have at my disposal to speak.

JUDGE MAY: Yes. We've reflected on that. You can have the rest of today and you can have until the first adjournment on Monday. That will be an extra hour and a half; that will be ten hours in all.

THE ACCUSED: [Interpretation] So that means an hour and a half on Monday; is that right?

JUDGE MAY: Yes.

THE ACCUSED: [Interpretation] Very well. Then I will have to shorten what I want to say, including the documents, because they require a great deal more time.

I should like to mention the bombing of the prison in Istok because I have been -- I heard here when the indictment was read out that it was said that the Serb soldiers threw hand grenades and that that was the way that they destroyed that particular prison at Istok, in Kosovo.

That particular prison was bombed on the 19th and 21st of May, but I'll skip those photographs. I'll just show you the bare necessities. But in this unfortunate indictment, it says that the Serb policemen used hand grenades, whereas you're going to see a crater made in the reinforced concrete, a crater big enough for a whole train column to pass through, ³⁴⁶ and that the crater had indented the reinforced concrete. And you'll be able to see the victims. Many of the prisoners were killed; 95 prisoners were killed in fact, and 196 detainees were injured. Could you just show these two pieces of paper, these sets of photographs. I won't be showing the others. And while you're doing that, let me say that throughout the aggression the bridges were bombed, Zezelj Bridge on the Danube at Novi Sad was bombed again, the Ostruznica Bridge. Take a look at this photograph and the crater up there. That is where the projectile made a direct hit, hitting the prison. That is just one photograph.

Please proceed to the next one. And let anybody say that that damage and demolition was caused by a hand grenade. This is a pavilion where a number of prisoners were killed. Next, please. This is the hallway, the corridor. Next, please. These are the corpses in one of the prison cells. Corpses after the bombing. You can see what it looks like. Have a look here. And whether that kind of destruction can be caused by a mere hand bomb, hand grenade.

Look at these bodies under the rubble. Next, please. This is what the bombing looked like. The bombing of bridges continued. The bridge at Ostruznica. I am not going to show you any more photographs.

The Sarajevo Bridge in Grdulicka Klisura. The railway and motorway bridge at the village of Toplica. You can see dead people who were killed on the bridge. ³⁴⁷ On the 1st of May, at 1340 hours, on the main road running from Pristina to Nis, at the village of Luzane, the Podujevo municipality in Kosovo and Metohija by the bridge on the Lab River, that was also targeted. They targeted a bus full of passengers, amongst whom many women and children. The bus was hit with a direct hit and cut in two. And in the bus, killed on the spot, were 39 passengers and 13 -- which means that the bus was packed jammed full. The other 13 received serious injuries and some succumbed to them. I can't just skip over that. The bus that was targeted by NATO, killing so many civilians. And already on the 3rd of May -- that was on the 1st of May, whereas on the 3rd of May, at Savine Vode, at 1145 to 1330 hours, missiles and cluster bombs were used to target the Pec-Kula-Rozaje regional road. And another bus, once again pack jammed with passenger, running between Djakovica and Podgorica. The passengers were killed in that incident as well. A number of people were killed, a few people were wounded, but you can imagine the state those wounded people were in. But I'm going to cross that out. I'm not going to show you that. I don't want to take up too much time.

Let me just show you a few characteristic photographs. I have a set of photographs showing the casualties, the victims. Two busloads in the space of three days or, rather, on the 1st and the 3rd of May in Kosovo and Metohija, which were targeted by NATO, all the civilians and practically everybody else killed, massacred. Altogether over 100 people.

There you have them. You needn't show the photographs that have ³⁴⁸ been crossed out because those pictures were taken from far off. Give the close-up ones.

This is part of the bus that was destroyed on the bridge. Next, please. Next, please. Next, please. These are the corpses, the carbonised corpses scattered about round the bus that in the hit was scattered to parts around the bridge. The corpses that are still burning. Next, please. Carbonised bodies. Next, please. Once again, carbonised bodies.

Next, please. Scattered around the road bodily remains. A male body. Next, please. That was the bus conductor. Next, please. And a little girl that was killed.

This woman was identified. Her name was Faza Andonovic. Next, please. An unidentified body here, once again from the bus.

Next, please. This is a passenger vehicle in the vicinity of where the people were killed, and the passengers in this vehicle were killed too. The car happened to be nearby. The number plates were from Pec. Milovan Ceklic, he was killed.

Next, please. This is his daughter. Milijana was her name. Next, please. That's all.

The railway bridge was destroyed between Belgrade and Bucarest near Vrsac. I won't be showing you any more pictures of bridges. The railway ridge at Bogutovac, the railway bridge running from Kraljevo to Kosovo Polje. The road running from Kraljevo to Kosovo Polje. The railway line -- the railway bridge on the railway line across the Ibar ³⁴⁹ River, the bridge across the Niseva River Nis and Velika Morava near Mijatovac. Here you have on the destroyed bridge a car belonging to the Romanian Red Cross with the Red Cross emblem on its roof, both on its roof and both in the front of the vehicle. So two Red Crosses there. The PTT post office building Uzice. The bridge at Velka Plana. The bypass around Cacak. The corpses of passengers who happened to be on the -- their journey. The bridge on the River Lim. On the 11th of May, 1999, another attack on at the very Hungarian border, Horgos, that is to say the most northerly part and the bridge in Kokin Brod. The bridge in Murin, the bridge in Vrbas. The overpass in Visoko near Kursumlija, at the Truparske Sume area. The bridge at Vladicin Han on the 18th of May. The bridge across the Jasenica River in Velika Plana near Belgrade. The Cekavica bridge at the Jablanica River. The Djenova bridge once again on the Jablanica River. The corpses lie beside the roadside next to the bridges that were targeted, that were hit. On the 30th of May, at 1305 hours and at 1315 hours in Varin the bridge across the Velika Morava River was hit at a religious holiday when there were several thousand people on the bridge and several hundred civilians on the bridge itself who were easily visible at 1305 hours in the daytime, during the day on that day. The people were killed. You can see the bodies of the victims. Many victims. Just take a look at these corpses.

One hour later from the time of the hit they came again to target again when they knew that the first aid teams were on the bridge giving first aid assistance to the casualties, and they came back to kill even ³⁵⁰ more people. Amongst those people were -- was a girl. Her name was Sanja Milenkovic. She was a mathematical genius. She was born in 1983. And we have a school certificate of hers here, a school report. On 29th of May, 1999. The Television Novi Sad building was destroyed and completely demolished. I'm not going to show you photographs because you have shortened my time, the time I have at my disposal.

The bombing between the 1st and 2nd of May took place of the water supply system without -- which left a large part of the town of Pristina without water. Most of Pristina was left with its water supply cut off. And then we had the bombing of all the infrastructure. The electric power facilities on the Nikola Tesla in Obrenovac electric power plant, thermal power plant. Then we have the bombing of the factory of Cer, Cacak. I don't have enough time to show you all those photographs of the complete destruction and demolition. It was one of the largest factories in Serbia, giving a livelihood to most of the citizens in Cacak. Another case in point was the Prva Iska factory near Belgrade, the mining and smelting basin of Bor, the sole major producer of copper in Europe. That was bombed too, along with the complex of factories, the Krusik in Valjevo on the 18th of May. A repeated bombing. You can see the factories that were destroyed and razed to the ground. Vinacka Morava in Gnjilane. That was on the 19th of May.

And we see the corpses of Sabija Cijan, for example from Binacka Morava. Dzevat Ademi from Gnjilane, and so-and-so forth. The Mladost company in Gnjilane. Once again dead bodies, both male and female. I ³⁵¹ would say more female ones, actually.

Borovo Boreli [phoen] and Sombor on the 25th -- 21st of May. The thermoelectric power plant Veliki Crnjenik at Lazarevac. I'm not going to show those photographs either. The thermoelectric power plant Urbica and at Obrenovac. I'm not going to show those photos either. The Elektroindustriaja facilities in Nis and the Bezanijska Kosa. It's an entire field the size of several football fields and Vojvodina gets its electricity from there as well as the Bezanijska Kosa electric power plant, which is instrumental for electricity in Belgrade. And when there's no electricity in Belgrade, there's no water, there's no heating, there's nothing which electricity enables us to have. The centres in Sombor. All the facilities ranging from hospitals, maternity wards, the water facilities and resources, passenger buses, trains, all prohibited by the Geneva Conventions and Protocols and all the other norms of international law; that is to say, war crimes, in fact, crimes of genocide, and crimes against humanity. The warehouses of fuel, all of them were bombed and destroyed, and most of them created a real ecological catastrophe. This is an incomparably greater damage, ecologically speaking. Much great ecological damage was done to nature and the ecology, more than the factories themselves and the material damage that this caused. I have set this out in a very restrictive -- I have been selective and had to move fast with respect to the civilian facilities destroyed in the NATO aggression on Yugoslavia in which all these crimes were committed. All the crimes that I mentioned a moment ago were committed. ³⁵² Now, I'm asking you, what kind of Tribunal can you talk about if you refuse to try people for all these crimes, the crimes committed by the leaders and governments and army of the NATO pact countries that I enumerated, that I quoted, on the territory of Yugoslavia. And you call yourself a war crimes Tribunal for crimes committed on the territory of Yugoslavia. Not even in the Security Council Resolution which set you up, although it was unlawful in taking that Resolution, but not even in that Resolution with respect to crimes in Yugoslavia are the Americans, French, or anybody else exempt. And nowhere is it written that those are the crimes that should be tried in Yugoslavia. And not only the ones that you say were committed by the Serbs.

So you yourselves have interpreted your competencies and authorities in terms of reference that you -- that some perpetrators of crimes were exempt, but that you try only those who defend themselves from attackers in their homes, and you refuse to consider those attackers as being responsible and the true perpetrators. You keep repeating the fact that this is a trial of the side that defended herself -- itself. And thus you have defined yourself as the exponents of the side that perpetrated the crimes and as accomplices in crimes against somebody who defended themselves on their own territory.

You say that you are not trying Yugoslavia or Serbia but that you are trying me personally. However, I have put forward a series of arguments which you yourselves have put forward here. You have said that you are going to try everyone, but you tell me I am responsible by virtue of a chain of command, a command responsibility that exists in no laws. ³⁵³ That means that the armed forces of Yugoslavia whom I commanded committed a crime in defending their country, in defending their people. So you are actually holding a trial of a whole country here, a country that stood up in defence against its attackers.

You are confronted with obvious forgeries here. You saw everything that was on the tape played yesterday. You see that the Prosecutor abides by Walker's lies which were refused. And as the Prosecutor is well aware of the truth because you have seen the statement given by the forensic experts from Finland, for example, Mr. [sic] Ranta. She said, rather, that she handed in a report of her findings to the Prosecutor, which means that the false indictment has been rigged and that the truth has been hidden on purpose.

Not only that. Over the past two days, the Prosecution has shown pictures from a camp in Bosnia-Herzegovina, but they are false images. In view of the fact that the Prosecutor showed these images, I have a videotape which shows that this is -- this lie is in the functions of an anti-Serb propaganda, that it is rigged, that it has been mounted. I don't want to enter into the question of this camp in Bosnia, but I do want to say that these are false television programmes in order to bear out this anti-Serb policy.

Now, if I think that I have enough time to play my own video cassette, then you will be able to see that these pictures that we saw and that the Prosecutor showed false images and photographs which have gone all round the world to Satanise the Serb people because this is -- what we're dealing with here is an English, let's say, journalist, if we can ³⁵⁴ call her that, a journalist who came to a collection centre for refugees who were free. They could move around neighbouring villages, buy their own food, and came there to seek refuge from the war, destructions of war. And then she entered this collection centre which is -- has a wire mesh around it because it was a warehouse. And then it was from this warehouse that she filmed inside and talked to the detainees, and she wanted to make it appear as if they were behind this wire mesh. And this is a subject that was raised by the public. I will, if time allows, show this videotape. If I don't have enough time, I shall just hand it over to the public and then the public can become acquainted with it and all the falsities. Let alone the Racak ones and the refugees at Kosovo and Metohija which we have alleged to be settled. There was a negligible amount of refugees there, below 1 per cent, 0-point-something per cent, and so on and so forth, without enumerating all the forgeries that have been used.

Now I'm asking the public: If the Prosecutor knows that something has been rigged and is false but nevertheless uses it, can he be -- can he do his duty? Judge May, I'm sure you know the British court's ruling that if a Prosecutor is not executing his business properly, he must be stopped from continuing it, and the abuse of due process. We have been talking about justice and fairness, as far as the UN is concerned, concerning the function of the Prosecutor, but let us not go into that because these categories are thousands of miles away from all of this. I'm just talking about plain forgeries here. Of course, you also know about rulings concerning abuse of due ³⁵⁵ process if habeas corpus is not taken into account. I'm really surprised that even the amici curiae did not react to the fact that habeas corpus was not dealt with. You appointed them yourself, and they, as lawyers, should know what kind of weight this kind of legal argument carries. I'm addressing the public here and I'm calling upon the professional public to react according to their professional conscience. A lawyer does not have the right to remain silent before such drastic examples of abuse of proceedings and violations of the law. I am expecting you to state what you have to state in relation to the abuse committed by the Prosecutor and all of this in the public eye. As for these false accusations and my arguments, first and foremost, as far as the truth is concerned, before the world public, I should indeed avail myself of my right to cross-examine and examine witnesses of all these events in view of the peace process, in view of the decisions, in view of the policies and realisation of these policies, notably in relation to crimes.

I'm going to call witnesses here and I want it to be possible for me to question Clinton and Albright and Kinkel and Schroeder and Kohl and Dini and Vollebaek and Kofi Annan and Sharping and Dole and the American team at the Dayton Accords, and all those who were present during the signing of the Paris Agreement, that is to say, everybody except for Blair and Schroeder whom I did not talk to. All the rest I talked to personally. I had personal contacts with all of them, of course official contacts, and I discussed these matters that are at stake with them and all of this is related to this. ³⁵⁶ As for this list of foreign witnesses, I'm going to submit this through my associates when I finally compile this list. As for the list of witnesses from home, I'm going to submit that when the Prosecutor takes care of his business.

According to what you did in terms of this false accusation and indictment put forth by the OTP, it seems that you are charging me with so many crimes, so in addition to explaining the causes and consequences of the crimes committed over my country and my people, it will be important to clarify an answer to a question: How come I enjoyed general support in 1995, 1997 and 1998, and so on? And even now, after a decade, I am charged with genocide no less in 1991, 1992, 1993, whatever, but at any rate before these negotiations that were being held. And all these political and material circumstances have to be taken into account. I am going to indicate some more of them now and I will deal with others later. Now I'm going to speak about the crimes of genocide in Kosovo, committed after the security mission came; namely, KFOR, and also the civilian UNMIK mission of the United Nations, or rather, after the 10th of June, 1999.

Grave crimes were committed there against humanity, the crime of genocide and other war crimes. And also there is evidence of that, of direct cooperation in the commission of these crimes between the occupying troops - that's what they turned into - from being the Protection Force of the UN, they, on the one hand, and on the other hand the KLA that continued to loot, plunder, kill everybody and everything that was not Albanian in Kosovo including part of the Albanians themselves. ³⁵⁷ Resolution 1244 from 1999 of the Security Council of the UN makes it incumbent upon this mission to provide peace and security for all of the inhabitants of Kosovo. However, facts have shown that KFOR did not carry out its mission. These countries, through their contingents in Kosovo in fact control certain sectors of Kosovo, but they are supposed to provide basic protection to ethnic and religious communities in Kosovo. And they are duty-bound to do that on the basis of various international covenants including conventions on the prevention on any kind of discrimination. They have not done this.

The result of their presence is 3.000, that is to say, under their protection, 3.000 killed Serbs. Mostly Serbs, but other non-Albanian citizens as well. Even some Albanian citizens; 2.500 were kidnapped, and nothing is known about 1.300 of them. And their families are afraid that they have been killed too. Most of them are Serbs. Several tens of thousands of houses were burned, primarily Serb houses. Private and socially owned property was taken away by force. Crimes were committed. And over 360.000 Serbs and other non-Albanians were expelled and they were under the protection of the United Nations. 360.000, including, for example, 10.000 Croats from Janjevo, in Vitina, where they had lived primarily. And then also churches were razed to the ground and holy places of the Serbs.

We have seen a countless number of times on CNN - I'm not criticising this - but a countless number of times we saw the Taliban destroying the Buddha statue in Afghanistan. That is vandalism, no doubt. However, under the protection of the United Nations, in the ³⁵⁸ presence of their troops, 107 churches were destroyed in Kosovo and Mehotija. I did not see a single one of them. Not to mention abuse of the kind that was committed.

The gravest crimes committed by Albanian terrorists occurred with the benevolent attitude of KFOR, and until now, practically no perpetrators of crimes over Serbs and other non-Albanians were found. For example, in Ugljari, KFOR hid the massacred bodies of Serbs for months, and in this way they were accomplices in these crimes. And also when the relay station in Mokra Gora was destroyed, they were also involved in this crime. All the crimes from the 10th of June were committed in the presence of UN forces.

Where is the responsibility there? Do you apply the same rule to them, that they knew or had reason to know? Who is going to convince anyone that somebody did not know what was happening 100 metres away from their base? But I'll get to that later.

Almost not a single provision of Resolution 1244 of the Security Council of the UN was carried out. The number of killed Serbs went up day after day, and the number of crimes as well. Only the day before yesterday, bombs and hand grenades were thrown in a village near Kosovska Kamenica. I have this written down and I'll get to that later. This shows that this chain of crimes has not been cut off yet. It is February 2002 now and they have been there since the 10th of June, 1999. Plunder, looting, terror, torchings, taking property to Albania, all of that continues. Instead of protecting borders, KFOR allowed several hundreds of thousands of citizens of Albania and Macedonia to ³⁵⁹ enter Kosmet. After that it is quite clear -- I realise I have to speak slower for the interpreters. On the other hand, my time is so short. I'll try to strike a balance between the two.

After everything, it is quite clear that the objective of NATO aggression against Yugoslavia is the realisation of strategic objectives of certain states which has nothing to do with the protection of human rights; all of this is done at the expense of the gravest possible violations of human rights. These states formed, financed, coordinated and supported, until the present day, Albanian terrorist groups, and they started doing that before 1998 in order to create a reason for aggression.

Instead of manning further the verification commission of the OSCE in Kosovo on the basis of the agreement reached between Yugoslavia and the OSCE on the 16th of April, up to the number of 2.000 staff numbers, that was supposed to be the largest OSCE mission, in Rambouillet, in Clabere [phoen], they were supposed to influence the Albanian representatives that would be conducive to a reasonable agreement.

Yesterday I spoke to you about this, what the only difference was. We insisted that also this should be based upon the principle of equality of all rights of all citizens and of all ethnic communities. It seems to me that this is a well-known thing throughout the world, that that is the best kind of solution for such a population pattern. During the aggression, in the clashes between these terrorist groups and the army of Yugoslavia, they intervened on the side of these terrorist groups and they were bombing the units of the Yugoslav army ³⁶⁰ while they were fighting these terrorist groups. They promoted these people into some kind of new forces of law and order in Kosovo. And finally, they have not done a thing to prevent these same groups in the commission of new crimes.

I am not going to read further figures concerning the number of persons killed. I have already said that 3.000 persons were killed. I'm not going to read lists and other pieces of information about those who were wounded, injured, beaten up, all of this while they were enjoying UN protection. Also, I'm not going to read the number of persons kidnapped, abducted. I have already said that nothing is known of the fate of 1.300 people.

After all, in Kosovo, the rights of the UN have been usurped by these forces just like these forces and these troops have usurped the UN organisation as such when this court was established. I'm not going to talk about 2 million destroyed books written by Yugoslav and other authors; tens of thousands of icons and other holy objects that were destroyed in Kosovo; entire factories that were transferred to Albania and thrown into scrap yards. Between 250.000 to 300.000 citizens of Albania and Macedonia crossed the border, and all of this in the presence of the heavily armed military and police.

We did not have law and order and peace in Kosovo, and when the terrorist activity was at its height in 1998, we had that. This was checked by the verifiers; this was checked by the Holbrooke mission. When we increased the number of police because of terrorism, this number ³⁶¹ reached 10.024. With 10.000 policemen, nothing of this could have happened; with the presence of 50.000 UN troops, the gravest of crimes are being committed.

The crime against the Serbs was not stopped. The latest information I have deals with the 13th of February, when hand grenades were thrown at Serbs in the village of Kolatec, near Kosovska Kamenica. Already on the 12th of June, so that is the day after this responsibility for the safety and security of all the citizens of Kosovo and Metohija was taken over, as the Resolution says, automatic gunfire was opened against the Belacevac workers.

On the 12th of June, Dobnice and Novo Selo were attacked, in the municipality of Prizren, by Albanian terrorists. On the 13th of June, they attacked Serb houses in old Kacanik. On the 13th of June, they opened fire against members of the police who were in the village of Ljubis, in the municipality of Orahovac, and the village of Studencani, the municipality of Suva Reka.

On the 13th of June, in the villages of Gotovosa and Drajkovac, in the municipality of Strbce, they opened fire from automatic rifles and mortars against the villagers from this village. On the 14th of June, in Zaskok, in the municipality of Urosevac, they shot at a column of refugees. I should deal with this briefly in order to save the time that I have and that you have made shorter for me, but I hope that I will be able make all of those points that are sufficient to illustrate all of the things that are taking place under the protection of the UN in Kosovo. ³⁶² On the 15th of June, in Urosevac, they barged into factories and other institutions.

On the 17th of June, in Pristina, they carried out an armed attack against a refugee camp.

On the 20th, from the territory of Albania, they attacked the villages in the municipality of Dragas. Dragas is an area that is populated by Muslims, by the Gorani. But Albanian terrorists cannot tolerate anyone who is not an Albanian.

On the 28th of June, in the village of Miloseve, the municipality of Pristina, again an armed attack on Serb houses, including the throwing of hand grenades and bursts of gunfire from automatic rifles. In June and July 1999, the territories of Gnjilane and Kosovska Kamenica, major forces of the KLA were set up with about 1.000 terrorists who had come from Albania. Every day, from automatic rifles and hand-held rocket launchers and mortars, they opened fire every day, every day in the months of June and July against Ranilo, Pasjane, Odovce, Rajanovci, Bosje, in order to speed up the expulsion of the non-Albanian population, and all of this permanently, day in, day out, with the presence of UN troops. On the 13th of July, in the village of Movila, with bombs and mortars and Molotov cocktails, they attacked Serb homes. I cannot read out all the data because it is taking up my time. But I will say that during the attack on the Bocic house, six members of his household were tied up, the house locked and the house set on fire with a Molotov cocktail.

On the 14th, they forced workers in Prileznica out of their ³⁶³ workplaces. On the 14th, they threw a grenade at a Serb house in Gnjilane.

On the 15th of July, in Urosevac, they blew up a cafe called Serbia.

On the 18th of July, in the area of Vitina, they carried out a terrorist attack and threw hand grenades and opened fire on an entire refugee column of Serbs. And at least the column should have been protected by KFOR, at least the moving columns that were leaving Kosovo. On the 25th of July, Albanian terrorists shelled Vrbovac inhabited exclusively by Serbs in Vitovo municipality. I will skip over many of these incidents.

On the 10th of August, in Kosovska Mitrovica, two projectiles were fired at the northern part of this city inhabited by Serbs, hit buildings, and attempted to enter them, and only then, after this act of violence, did KFOR stop them from breaking in and causing even greater bloodshed, because they saw that they wouldn't be able to do it easily. On the 26th of August, in the village of Pones, in Gnjilane municipality, again automatic fire was opened on citizens and Serbs as they were working the fields.

I shall leave out things because of the time, many things. On the 16th of September, in Lipljan, hand grenades were thrown at Serb family homes in the immediate vicinity of the KFOR headquarters. On the 22nd of September, in the village of Kmetovci, in Gnjilane, they attacked with automatic rifle fire vehicles that were moving and they killed a father and son that were in the vehicle. ³⁶⁴ On the 25th of September, in the village of Svinjare, Albanian terrorists and their commanders broke in and opened fire, bursts of fire in the village. And when the citizens reported this to KFOR, who must have heard it because one can hear rifle fire, their patrol, instead of arresting them, made it possible for the terrorists to leave. On the 25th of September, bursts of fire against the Pasjane village in Gnjilane municipality, once reported to KFOR, the next day they intervened and they accused a Serb, Milorad Krstic, of opening fire and searched his house, claiming that he was concealing weapons that had been used in the attack.

There are more killings here that were committed. Opening fire on passenger vehicles of Serbs, throwing of hand grenades, stoning a group of, for instance, 154 Serb citizens, on the 27th of October, 1999, in Djakovica, men, women, and children.

On the 28th of November, in Gnjilane, two groups of 1.000 extremists each in Stojana Trojica Street, inhabited exclusively by Serbs, demolished 50 Serb houses. Gnjilane, in Kosovo terms, is a large town and there is a KFOR headquarters there. And to demolish 50 houses in their presence?

On the 29th of July, 1999, in Donja Dubica, 100 metres from the administrative border of the Autonomous Province of Kosovo and Metohija, they fired at and killed a citizen by the name of Dejan Djordjevic. On the 22nd of July, in Prizren, they attacked Muslims, and when KFOR members arrived on the spot, they could not guarantee their safety and they had to leave Prizren. And they had set fire to their house, ³⁶⁵ seized the vehicle of that Muslim family, money, et cetera. On the 28th of July, with sticks and axes they took out Dzafer Selimovski and Skender Arif, Mehmeti Ruzdi, Albanians and Muslims, therefore. They beat them up and plundered them. On the 15th of August, an armed attack on the Dzum in Prizren municipality, inhabited by Albanians of Roman Catholic faith who were celebrating a religious holiday on that day. After that the inhabitants of the village of Dzum left en masse.

At the end of September 1999, masked Albanian terrorists broke into Semso Mucevic's house, also a Muslim as you can judge by the name. They beat him and his wife up and stole their property. In September 1999, they set fire to the shop of Salija and Ahmet Sarda, also Muslims.

In mid-October 1999, the villages of Lepnica and Sasovci, in Vitina municipality, of Croat ethnicity, were threatened to be killed if they did not move out within ten days. After that the remaining 300 Croat villagers, led by the priest Nikola Duckic, of Roman Catholic faith, decided to move out of Kosovo province.

On the 1st and 2nd of November in Gnjilane they threw five grenades at apartments of non-Albanians but Muslims, all of them Muslims. On the 3rd of December in the village of Orasje, Pec municipality, they entered a part of the village inhabited by members of the Romany ethnic minority, beat them all up and set their houses on fire. On the 20th of December, in the village of Dobrocane, Gnjilane, under constant threat they forced out all Romany families. ³⁶⁶ In mid-December 1999, also in Gnjilane, in the Presoevo Street, they threw hand grenades at Romany houses, and at the beginning of December, they also forced out Romanies and Muslims from the village of Dragasa.

Because of my considerable isolation, I am not able to get hold of other data, but there's obvious collaboration in a common criminal effort of the KFOR and the terrorists. I think what I will now add will be sufficient and which you probably don't know. I draw the attention of the public to this information, too, which shows that the Albanian terrorists didn't have an easy time to force out 360.000 people, and what -- all the other things they had to do in their savage and criminal behaviour with the permission of the KFOR and the UN police, UNMIK. And I don't know where the public opinion that is listening to this can believe that on such a small area as Kosovo is 50.000 troops doesn't know nor has reason to know of all these things that are happening.

I shall read out only the drastic examples of crimes committed, of plunder, torching, and killing to force them out. If they had forced them out in the most decent way, it would have been a crime. If 1 per cent of this had been done while we were in power there, that would have been a crime that would have been ringing all over the world. This was done in the presence of 50.000 troops of the UN and the UN mission in Kosovo and Metohija, and this is something that the whole world should know. Between the 12th and the 17th in the village of Orlane and Podujev, they plundered, set fire to a house and all farming facilities of peasants. On the 19th, they broke into the Suncani Breg settlement, set ³⁶⁷ fire to apartments in several apartment blocks.

On the 19th in the village of Sleovo, they plundered and set fire to Serb houses and forced the inhabitants to move out. On the 20th, they set fire to virtually all Serb houses in the municipalities of Istok and Vucitrn.

I'm talking about the territories of four municipalities and almost all Serb houses. I'm not talking of isolated cases. On the 20th of June, in the settlement of Goles, Lipljan municipality, they plundered and set fire to all Serb houses. On the 22nd of June, in the village of Orlovic, Pristina municipality, Albanian terrorists set fire to all Serb houses and forced the villagers from the village in the presence of the United Nations and under the auspices of the United Nations.

On the 22nd of June, in the villages of Nedokovac, Nevoljani, and Vrbica, Vucitrn municipality, they plundered and torched all Serb houses in the presence of the protective forces of the United Nations. On the 24th of June, in the village of Zegare, Gnjilane municipality, they set fire to all Serb houses. During June and the beginning of July, 1999, they plundered and burned down all houses owned by Serbs in the Prizren settlements of Dusanovo and Potkaljaj in the presence of the UN.

On the 28th of June in Obilic, in the Subotic settlement, Qerim Abazi's house was set on fire. And he was a member of the provisional executive council president of the Democratic Party of Egyptians. Under the auspices of the UN, at the beginning of June 1999, 22 ³⁶⁸ houses were set on fire in the village of Kovatin [phoen] near Kosovska Kamenica and many houses in the village of Lestari and Donji Sipastica. Albanian terrorists, at that point in time and in the period I have mentioned, forced out of this area the entire population of other ethnic groups, Muslims, Turks, Romanies, Egyptians, Croats, all of them. On the 3rd of July, in the village of Milosevo, in Pristina municipality, a large number of houses out of a total of 100 that were there, 50 Serb families were forced to move out on the spot. I will leave out all the individual cases.

On the 11th of July, in the village of Strmac in Kosovska Mitrovica, three Serb houses. On the 12th of July, four Serb houses in the village of Gornji Livoc. Sometimes the number is reduced because others were torched in the previous period.

On the 14th of July, in the territory of Kosovska Mitrovica municipality, seven Serb houses under the auspices of the United Nations. On the 15th of July, in the territory of Kosovska Mitrovica, they set fire to, but of course previously looted, 35 houses. On the 16th of July, in the territory of Kosovska Mitrovica municipality, again they plundered and set fire to 62 Serb houses.

As I was saying, on the 15th, 35; on the 16th, 62. And Kosovska Mitrovica is one of the largest towns in Kosovo and Metohija. There is a marked presence of KFOR. Can anyone say that they did not know and did not see 100 Serb houses being plundered and burned down in two days and nobody batted an eyelid?

On the 16th of July, in Vucitrn municipality, eight houses. On ³⁶⁹ the 17th of July, in the villages of Lubisda and Muzevine, they set fire to all Serb houses and 20 Romany houses in the village of Sinaje. On the 19th of July, they set fire to seven Serb houses in the territory of Kosovska Mitrovica and Vucitrn under the protection of the UN. On the 21st of July, 12 houses in the Kosovska Mitrovica and Vucitrn municipalities. I will not read out the names of the families. On the 21st of July, in Vucitrn municipality, houses were burnt in the village of Taradza. Again, I will not read out the list because my time is limited.

On the 22nd of July, again under auspices of the UN in Kosovska Mitrovica municipality, 26 houses.

If you were to add up the figures for Mitrovica only and only the figures that I have given here before the cameras and the public, you would see what was done in a single town under the protection of the United Nations.

On the 23rd of July, they set fire to an entire Serb village called Klobukar in the municipality of Kosovska Kamenica. In the territory of Vitina municipality in the village of Zitinje, Trpeza, Pozara, Novo Selo, Grnovo, Drobez, Kabas, and Binas, with mixed populations, all the Serb houses were set on fire. On the 28th of July, it was discovered that Albanian terrorists had completely destroyed the villages of Rudnik and Donja Strmic in the village of Suvo Grlo houses were plundered and demolished and burnt. And in the village of Crkolez, only three houses.

On the 28th of July in Prizren, they set fire to six houses under ³⁷⁰ the protection of the UN. In the one-time Old Prizren inhabited by members of three ethnic groups, members of Albanian gangs in Urosevac plundered the apartments of all non-Albanians and after that set fire to 80 per cent of the houses, family houses.

Under the protection of the UN at the beginning of August in the village of Muzicane, Stimlje municipality, they plundered and set fire to all Serb houses. During July and the first half of August in Gnjilane, they plundered and burnt a long list of houses that I have here which I cannot read out because of limited time, but all the figures will be made available to both you and the public.

On the 4th of August in Kosovo Polje in Braca Jankovic Street number 26, the terrorists set fire to the houses of Djordje, Slavko, and Goran Lakusic. In order to protect his family and property, Goran Lakusic resisted the terrorists, upon which representatives of KFOR arrested him and took him to prison in Gnjilane.

A very recognisable method. He's defending his home. He must be guilty for KFOR sends him to prison. It applies universally. During August 1999, in Ajvalija, Pristina municipality, they plundered and set fire, under auspices of the UN, 12 houses. On the 30th of August, in the village of Krpimej and Lausa, in Podujevo municipality, they plundered and then set fire to all Serb houses. I am leaving out the cases when five, six, or seven houses were plundered or burnt, but I cannot leave out when all the houses or entire villages were burned down under the auspices of the UN for which this Tribunal does not consider to have jurisdiction even though it is the ³⁷¹ territory of the former Yugoslavia.

On the 31st of August, all the houses in Kabas village, Vitina municipality, were burnt down.

Furthermore, in the presence of KFOR, Albanian terrorists threw a grenade at a business premises. When the Serb resisted, KFOR members arrested him and his three sons and took him to the village Trstenik and held him in detention there for a week.

I shall leave out all the facts and figures about the enormous number of forcible expulsions because particularly in urban environments and particularly in Pristina, people were looted and thrown out of their apartments for them to move into them. So if they needed apartments to move into, they wouldn't set fire to them. They kept that property for themselves.

And there is a typical example in Pristina, in the Suncani Breg district, which are elite areas. In block 2, five Serb families were thrown out by the Albanian terrorists, and KFOR had on the previous day searched their houses for weapons so that they couldn't resist. So they said to them, "Look, we've searched them. You can freely move into those apartments."

So endless lootings, countless forcible expulsions. In July, on the 11th, 12th, 14th, 16th, 19th, and the 20th, 21st, and 22nd, in Pristina, in Mitrovica, in Vucitrn, and in Gnjilane, Serbs were en masse thrown out of their houses, looted, and their houses moved into by Albanians. The lists that are still not complete will be made available to you and the public. Countless numbers of killings, plunders, ³⁷² and forcible expulsions. So far they have set fire, plundered, and illegally seized more than 50.000 Serb houses and apartments under the protection of the UN, KFOR and UNMIK.

I will leave out acts of sabotage, the destruction of the Kosovo Polje-Kosovska Mitrovica railway, the fire in the TV Pristina building to prevent Serbs from coming to working there. I had photographs here, but I don't have time to show them because it is more important for me to say certain things than to show them.

But please show just these two where in the presence of KFOR Serb houses are burning, and in the presence of KFOR Serb villages are burning. Just these two. And then let my associates distribute these others to the public information media, as I don't have a chance to show them here because I have not been given enough time for that. Let them be shown by those who have the courage to show the victims -- the crimes committed against the Serbs.

This is a Serb village on fire. And here you see Serb houses burning in the presence of KFOR members.

Because of the time, I cannot speak in detail about the destruction of Serb churches, but since the arrival of the KFOR mission -- a church is usually a big building. A church is not usually a grain that is invisible or inconspicuous. A church is usually located in the most conspicuous place in a town or village. It can always be visible from several hundred metres away. So it is impossible for KFOR and UNMIK not to have seen all this.

And instead of my explanation, I should like to give you as a ³⁷³ present a book issued by the Serbian Orthodox Church, which contains a list of 107 Serb churches destroyed and devastated under the auspices of the United Nations. Annexed to the name of each of the churches, the Orthodox has placed the flag of the country within whose area of responsibility the church was destroyed.

Many churches date back to the thirteenth and fourteenth century. They were a great cultural treasure. Perhaps there are little other areas in Europe where there were so many Christian churches. There were more than 1.400 in Kosovo and Metohija, including the Pec Patriarchate, the Base of the Serbian Patriarch.

I will not read out the names of the churches, but you will see what the ruins look like. I also had photographs to show what the churches looked like before and what they look like now; a heap of rubble.

But if anyone can explain to world public opinion that it was by accident that in the presence of 50.000 international troops someone can destroy 107 churches in such a short period of time and destroy many of them which are part of the world cultural heritage, that goes beyond the scope of reason and understanding of any normal human being. That is why I have said that as CNN can show us a thousand times, I personally have seen at least 50 times the blowing up of the Buddhas in Afghanistan to show what savagery was being done. Let them tell us the kind of savages that did this and whether any of this they explained anywhere near in such detail. And perhaps the Prosecutor, too, who ridicules the Battle of Kosovo and St. Vitus Day can read out and find out ^{374 BLANK PAGE 381} what it was all about, that the battle of Kosovo was for Serbia and for Europe some 613 or 64 years ago and what it meant. However, from this whole overview, it is obvious that this extensive crime that is ongoing and that this is criminal association of the powers who committed the aggression on Yugoslavia together with terrorist killers and the drug Mafia of Kosovo Albanians who today are killing not only Serbs and also Albanians. Maybe you don't have the facts and figures about it and are not interested in it, but this same killer, Hasim Taci, whose nickname which was given to him by his friends, not by Serbs, a "snake" because he poisoned his enemies, this same killer, Hasim Taci, and a collaborator of NATO and Clark, it is not sure how many of Rugova's associates he had killed. And he would have killed Rugova too if he had not been protected by our police. And our police protected him and nine members of his family and killed an assassinator who tried to jump over the wall and kill him with a muffled weapon, and they were caught. And I saved his life and nine-member family including a baby for whom diapers were bought by our policemen. And I sent him to Italy. I called up Alberto Dini by phone and asked him to send a plane in the middle of the war and sent his family to Italy so that Hasim Taci should not succeed in killing Rugova.

Well, of course, we know full well what your newspapers reported about this, not to mention about the other slanderous statements which don't differ anyway from those contained in this indictment. So the instrumentalisation of criminals and terrorists in order to destabilise Yugoslavia and then launch an aggression on my country can be ³⁸² seen in all phases of 1998 and 1999 when the aggression finally took place, and the continuation of a concerted, coordinated crime which has gone on right up to the present day, the coordination -- the coordination of the crime.

To illustrate that, could I just have this photograph shown and enlarged, because you see people holding their hands clutched together like this. They are Wesley Clark, Hasim Taci, Agim Ceku, killers, murderers, and criminals. And this photograph symbolises the alliance of an organisation commanded by Clark, Clark together with Albanian terrorists in the terrain, an alliance, the consequences of which are everything that I have read out to you so far.

Can we see it blown up, please? A larger -- zoom in on the photograph, please. I think you can recognise this. Taci, Clark - there they are - Agim Ceku [phoen], Michael Jackson who stated in the summer of 1999 that KLA had been disarmed, which was his responsibility, and then that disarmed KLA continue to shoot and kill.

There you have it. I'm going to have that picture blown up, because this is the only one I have. It has been taken out of a book, actually of a little newspaper, but it does exist in colour, too. Because this photograph indicates what an associated crime represents, a criminal enterprise.

Right up until 1998, a full ten years from the time when Serbia was accused for having taken over state competencies on its own territory in Kosovo and Metohija, in those ten years, there were no killings practically anywhere, or burnings or kidnappings or anything of that kind, ³⁸³ and nobody was imprisoned for political reasons. Even the Albanian separatists and Albanian parties were free to work. All the Albanian journalists were published on a regular basis. They had some 20 newspapers that could be bought on every corner, street corner. And let me state once again not a single issue was ever banned. Not a single copy, let alone issue.

The Albanian language stood side by side with the Serbian language. It was the official language of the province. Documents were published in two languages, both in Albanian and in Serbian. For all Albanian children who attended state schools, tuition was in the Albanian language. All the road signs and signs on public buildings and facilities were bilingual. They were in Serbian and Albanian. Where in areas inhabited by Turks, they were written up in Turkish and so on and so forth. The Turkish, too, had their newspaper. But we're not talking about the Turks. The Turks are the victims of the Albanian terrorism just like the Serbs in Kosovo are.

The Albanians from Kosovo, like all other citizens of Yugoslavia, were free to travel the world without any restrictions, including all their leaders. This applied to all their leaders too. They were free to travel around. Nothing ever happened to any one of them. And in the middle of Belgrade they could hold press conferences and then cross the street and go to have lunch in a hotel opposite, although previously they had hurled slanders with respect to the state without any sanctions. Nothing happened to them, and they were not even criticised for doing so. There was no repression and everything was allowed except violence, ³⁸⁴ barring violence.

After Dayton, throughout the territory of Yugoslavia, there was an easing of tensions. And on one occasion here, I mentioned that in my assessment the nervousness and the trigger for the onslaught toward the destabilisation of Yugoslavia began precisely after the summit of the countries of South-eastern Europe on Crete, because that summit of South-east European countries on Crete opened the road to cooperation and without a doubt indicated that a peaceful solution would be applied to all the problems that the Balkans were facing, and that we were having broad prospects opened up in front of us, the prospects of successful cultural, economic, and all other cooperation.

And it is at that conference that I had individual talks and meetings with all the heads of state and government, amongst them the Albanian Prime Minister Fatos Nano. We decided, we reached an agreement to normalise relations fully, to abolish visas, to open our borders, to develop trade, communication and tourism. And he himself spoke in front of television cameras about this. He said it all, and this is all on the record. You can read it. You can find it, records of that. Unfortunately, he said that Kosovo was an internal affair of Yugoslavia and this served as a trigger. It triggered off the following developments: Several months later I got Kinkel's and Vedrine's letter expressing their deep concern for the situation in Kosovo. I was very surprised to receive the letter because there was nothing going on at Kosovo at that time. On the contrary. We had talked about people going back to school on a regular basis. We had signed an agreement, Rugova and ³⁸⁵ myself, calling for the Vincenzo Palia from the Vatican to help us in reaching the agreement, and things were progressing towards peace, towards understanding, towards a solution of the problems and without any violence at all.

However, the German intelligence service -- and little is know about that. Kinkel is well known as a Foreign Minister throughout the world, but it is less known, less common knowledge that he is head of the German intelligence service and that is the post that he fulfilled before that. For any of those -- for those of you who don't know that, you should know it. The German intelligence service rallied up criminals from all over Europe. They were pushed to Kosovo. I don't think he'll deny that, because too many people know that fact. So he's not going to bother to deny it. Don't worry.

And all these people were sent to Kosovo to start killing. It was then that terrorist activities exploded, and you will see what this looked like, what happened. But before I go on to this area to show you what happened, what it looked like, I'm going to read just a few quotations by a German. So not a Serb. These quotations are by a German, Jirgen Elzeger [phoen], the writer who wrote the book entitled "War Crimes: The Deadly Lies of the German Government and Her Victims in the Kosovo Conflict."

I just have brief excerpts from that book. Elzeger states the following: A formula for all wars that happened in the former SFRY was the same. And I said that to you yesterday. The main pyromaniac in Yugoslavia, that fanned the flames of war in Yugoslavia, was Germany, and ³⁸⁶ the United States put out the fire using fuel. And it was the Germans that recognised in 1991 the independence of Slovenia and Croatia. This is no secret. Mitterrand complained that he was under pressure from Germany, and he allowed the European Union to recognise Croatia and Slovenia ahead of time, prematurely.

Against the will of the parties of NATO partners, the Germans armed Croatian right up until 1994 to take over Bosnia-Herzegovina and Krajina. Even the MIG war planes were used which belonged to the former DDR. It was the Germans who Umelek [phoen] of the KLA in Kosovo helped him at the beginning of the 1990s, sending him instructors from the BND ranks by is the German intelligence ranks. The BND it's called. Or, rather, when they allowed money to be collected in Germany, several million marks were collected for these purposes. And they did that while the USA, right up until March and April 1998, treated the KLA as a terrorist organisation.

At the moment when the balance of forces changed along with financial assistance from Germany and when this became a realistic factor of power able to change the geographical map of the region, the USA began to radically change its policy and to take the lead. After Croatia, along with German assistance, successfully prepared and began to arm itself for an attack on Krajina, Pentagon sounded the alarm and suddenly took the lead, taking over the whole operation. That's what happened with the KLA, too.

Yesterday's edition of the Washington Times includes David Keene's quotation, President of the Association of American Conservatives, who ³⁸⁷ claims that Clinton was involved in the storm operation when the Serbs were expulsed from Croatia and that this was done by the administration. The observer has written about that. And there is much more proof about that. And even Holbrooke was not careful enough and wrote about it in his book.

And that's what happened with the KLA, too, with support from Iran and Germany. In the summer it took control over a third of Kosovo, and the Americans threw in their own terrorists. In this series of bloody events, amongst the Albanian terrorists, the USA, between 1998 to 1999, steered the influence -- steered influential people in the KLA. I have a feeling that the interpreters are having a difficult time.

So with their assistance in February 1999, Taci's faction was victorious.

And as far as America is concerned, early enough on, says Elzeger and I quote: " Sufficiently early on, an Albanian lobby existed in American foreign policy rallied around Senator Dole, who already at that time collaborated with the KLA while at the same time the American government spoke about a terrorist organisation. That's what happened a long time ago in Germany when the Chancellor was Willie Brandt [phoen]. The BND, the German secret service, gave support to its Yugoslav partner in persecuting Ustasha terrorists while at the same time, as he said, the Bavarian wing the BND, under the patronage of France reels of Strauss, protected these same Ustashas, conspiring already at that time against the SFRY. ³⁸⁸ It goes on to say --

JUDGE MAY: Well, if you find a convenient moment, it's 1.00. Would that be a convenient moment to stop or do you want to add something else?

THE ACCUSED: No, no, no. If it is time to stop, we can stop. I suppose we are continuing in one hour and a half.

JUDGE MAY: Half past two.

--- Luncheon recess taken at 1.00 p.m. ³⁸⁹

--- On resuming at 2.30 p.m.

MR. KAY: Your Honours, before the accused resumes his opening address to the Court, there's a matter we would like to raise on his behalf at this stage and that concerns the length of time allotted to him in his opening and about which he clearly feels aggrieved and has made a number of remarks in his opening address. We would ask the Court, although a deadline has been imposed until the first adjournment on Monday morning, to perhaps consider the position that the accused is in by the end of this afternoon and how he progresses through Monday before making a final decision about the termination of the time allotted. It's obviously an important issue for him in the presentation of his defence. He's not aided by a support staff in court and that would obviously have an effect on lengthening his address to the Court. And --

JUDGE MAY: How much time are you suggesting he should have?

MR. KAY: I think it's --

JUDGE MAY: Infinite?

MR. KAY: Not infinite, and I don't think the accused is asking for infinite, but what he is asking for is that he be able to cover the points that he seeks

[Trial Chamber confers]

JUDGE MAY: We'll look at it again on Monday.

MR. KAY: Much obliged.

JUDGE MAY: Yes, Mr. Milosevic.

THE ACCUSED: When can I consider then at when a time -- what time is given to me? ³⁹⁰

JUDGE MAY: We'll see how you get on. Aim to finish in the time we've suggested. See how you get on.

THE ACCUSED: [Interpretation] Furthermore, in this interview, Osser [phoen] said, and I said that he is the author of the book on "War Crimes and German Lies in the Kosovo Conflict," he said Kinkel himself in February 1998 stated that the German Federal Government, and then he quotes him, that he supported Albania with a total of 1 billion German marks. Not a single country got that much per capita assistance. The source is FAZ of the 9th of February, 1998.

It was also strange that a special unit, part of IFOR was stationed in Zadar for a while.

I'm not quoting him now, but I'm saying that it is a well-known fact that Willie Wimmer, a CDU MP in the German Parliament said towards the end of March, "Never before did individuals lie so thoroughly and fully as during the time of the Kosovo war. That is why people lost their lives."

And even according to Spiegel, the media hysteria was supported and instigated by the BND, that is to say, the German secret service. Eldeser [phoen] says further on in connection with Fischer or, rather, Kohl's secret plan of the split Macedonia in the Federal Republic of Yugoslavia what this German plan was like. Towards the end of March, the German Foreign Minister said that the Albanian issue was a pending one. This comes from world history. The German issue is open, and that is what everybody said, all of those who did not really want to have reforms in the GDR. ³⁹¹ The German issue was open for as long as the Brandenburg Gate was closed and this ultimately led to the unification of Germany. Therefore, will Macedonia be obliterated altogether and will the Albanians be united? That is to say, will there be a Greater Albanian after Fischer made Albanian revanchism of a solemn nature.

There is one more sentence of the German Foreign Minister that says that -- the International Community will not allow a forced change of borders. However, if we analyse this question more precisely, we will see that Mr. Fischer is not refusing the revision of borders altogether, only the use of force. What happens if borders are not revised through manifestation of force but through a threat of force as was the case in 1938 with Czechoslovakia after the Munich Accord? Mr. Fischer himself recommends to the Albanians to apply Kohl 's methods. Again this is his quote. The International Community is in Kosovo and in the Balkans in order to show that the Albanian issue is -- does not have to be resolved with the agreement of the neighbours, and this draws on the German issue. And this will certainly remain in the memory of Prague and Warsaw who were completely left out of the 4 plus 2 negotiations. And if the Germans fooled Paris and London in such a way, this can be read about in Attli's [phoen] memoirs and also in Mrs. Thatcher's memoirs. However, what is recommended by Mr. Fischer to the Albanians from the German example of 1990 is nothing else but the obliteration of sovereign states. This should make the blood in the veins of Macedonian politicians freeze. And Lubca Gigarski [phoen], the Prime Minister spoke a week later and said openly the Macedonians cannot shut ³⁹² their eyes before the fact that the Western democracy is creating new Talibans in western -- in Europe and that nobody in Europe can be convinced that the German and US governments do not know the chiefs of these bands.

Already on the 30th of March, Fischer says in the Bundestag, and this is a quotation, that one has to think about a general solution for the Balkan problem because the problem of Bosnia-Herzegovina has not been resolved yet or of Montenegro or the Kresovo Valley. That is actually Southern Serbia, Southern Serbia and Macedonia.

I'm mentioning this because it is linked to historical facts that I will draw your attention to. In the creation of a Greater Albania, we see that Macedonia is next and then come Montenegro and Sandzak and then Greece. All of them are in --

JUDGE MAY: Could you slow down, please, Mr. Milosevic.

THE ACCUSED: [Interpretation] All of them are on the planned list of Albanian terrorists, and if the -- this already worked with NATO assistance, then why would it not work even more often? What Eldeser [phoen] says only confirms that Germany, after its reunification, especially with questions related to Yugoslavia, continued at an accelerated pace there where it was stopped by its defeat in the Second World War, and then in the Second World War, a Greater Albania was created as a Nazi fascist state, and I hope that nobody can deny that. We should remind precisely those who struggled before against Nazism and Fascism of certain historical facts.

From 1993 onwards, there was an ongoing activity of fascist Italy ³⁹³ against Yugoslavia. On the 7th of April, 1993, it annexed Albania, which is a well known fact. The Foreign Ministry of Italy Ciana [phoen], already in July 1939 gave instructions to Albanian emigres to act in Eperis [phoen] and Kosovo and Metohija. He often repeated that the Kosovo Albanian irredentism is, I quote, a knife aimed at the back of Yugoslavia. The same year, in Rome, a bureau was opened to organise the Albanian irredentist movement. In Albania, the Albanian fascist party was established and on the occasion of his visit to Albania, the Minister promised that the project of a Greater Albania would be implemented soon. Already in the beginning of 1940, the secretary of the fascist party said in Skadar [phoen] that Italy would soon annex parts of Yugoslavia populated by Albanians. And in Tirana, very much a new Albanian committee was established.

When World War II broke out, and a bit after that, when the fascist forces attacked Yugoslavia and they were headed by Germany and Italy, the blood-soaked implementation of the product of a Greater Albania started. Podujevo, Vucitrn, and the Kosovo -- Kosovska Mitrovica districts and all of Kosovo and Metohija were annexed to the fascist Greater Albania. Parts of Gnjilane, the Urosevac district north of Pasjani, Kacanik, Vitina, and Sirovacka Zupa were annexed to the newly created greater Bulgaria.

Western Macedonia, including Tetovo, Gostivar, Debar, Kicevo, Strugar, and Sveti Naum also came to belong to the Greater Albania. The agreement of April 1941 established a demarcation line between the Greater Bulgaria and a Greater Albania. The head of the puppet ³⁹⁴ government of Albania, at the Royal Italian Academy had a lecture about the roots of Greater Albania. He visited in July Kosovo and when speaking to the top Albanian people, he said in public that an effort should be made to replace the Serb population in Kosovo as soon as possible, that all the Serb inhabitants who had lived there from way back should be considered to be immigrants and as such should be sent to concentration camps in Albania. Later Serb settlers should be killed. These are historical texts that I'm quoting. Once again, in the project of a Greater Albania, there was no room for any other people but the Albanian people. You could see this from the reality that I have just described and that is now taking place in Kosovo and Metohija. In four years of the government, a lot has been done. Local Albanians under the protection of the occupation forces and assisted by their compatriots from Albania committed many crimes against Serbs. The European public does not know the proportions of these crimes. However, according to the office of strategic service of the United States, the Albanians, from April 1941 until August 1942, killed about 10.000 Serbs. When these areas were occupied, Italy started not only ethnic cleansing but also the systematic implementation of a Greater Albanian cultural project and also in all other spheres of life. Serb children who attended school under Italian occupation were forced to study in the Albanian language. The same thing happened to children in Western Macedonia. There was a mass expulsion of Serbs from Kosovo and Metohija and several tens of thousands of Albanians from Albania were settled there. Some historians believe that this number is about 100.000. ³⁹⁵ Until April 1942, on the southern border of occupied Serbia which was under German rule, there were about 60.000 refugees from Metohija, parts of Kosovo that came to become part of a Greater Albania. After the capitulation of fascist Italy, the Germans instigated the establishment of the so-called Second Prizren League in 1943. The league was organised under the protection of AVR, that is to say, the German military service. We can see that the BND over the past few years has taken over that role, the same one.

Terror over the Serbs with a multitude of individual and massive crimes lasted until 1943, when it started abating. As for the proportions of the ethnic cleansing of Serbs from these areas in addition to a multitude of other testimony is spoken of by Herman Neubaher, who was a special political plenipotentiary of the Third Reich in South-east Europe from autumn 1943 onwards. There is a quotation of his that says Albanians hurried to expel as many Serbs as possible from the country. Local strongmen will often expelled and actually they required gifts of gold in order to have this done.

When General Nedic , who was President of the Serb quisling government in that small occupied Serbia under the Germans, when he bitterly addressed himself to me, I recommended urgently to the Arbanis [phoen] government that these expulsions be stopped immediately. When I realised that my intervention was a failure, I wanted to resign my mission in Albania and that's what Neubaher says, the plenipotentiary of the Third Reich.

After the capitulation of fascist Italy under the German ³⁹⁶ occupation force, the notorious Skender-Beg SS Division was established. It consisted of Albanians. And until these areas were finally liberated from Nazi and fascist troops and their quislings, they persevered in the project of a Greater Albania. Now these troops that are there and also this new SS division which they came to call KFOR, which was actually a transformed terrorist organisation, the KLA, they are doing the same thing. All of this considerably changed the ethnic structure of this part of Serbia and Yugoslavia and basically it was one of the most important prerequisites for the successful implementation of the project of a Greater Albania.

Let us go back to the end of 1987 and the successful summit of the countries of southeastern Europe which had held peace, cooperation, and stabilisation, especially the successful contact and talks between the Albanian prime minister and me and his statement that the Kosovo issue was an internal affair of Yugoslavia. So this alarm was sounded and it started up a round of activities.

From then onwards an explosion of terrorism, that's the way I'd like to put it, started in Kosovo and Metohija. During the entire previous decade, there were very few attacks, and then only within about a month's time, and from the beginning of 1998 until just before the NATO aggression, 1.068 attacks were launched against individuals, citizens only, that is to say, about 100 times more than in any one of the previous years. And it is quite obvious that this was a turning point and that the process that had started had been cut off.

Everybody was a target, including Kosovo Albanians, especially ³⁹⁷ those who were employed in the government; that is to say, people who were employed in post offices, clerks who worked in government offices, et cetera. This time members of the terrorist organisation KLA killed, in a brutal way, 387 citizens. Out of this number, 75 were citizens -- 75 citizens, not 75 per cent. Seventy-five citizens were ethnic Serbs and Montenegrins, and 196 were ethnic Albanians; that is to say, the Albanian terrorists killed two and a half times more Albanians than Serbs in order to discipline them, in order to subjugate them, in order to force them to follow their policy and to behave the way they wanted them to behave. Also, 15 members of other minorities were killed, primarily the Romany. And in one case it was impossible to establish the identity of the persons who were killed.

In that same period, about 200 citizens disappeared and went missing or were kidnapped; half were Serbs and Montenegrins and the other half were Albanians, that is, 77 Albanians and 12 of other ethnic groups. In addition to these individual killings, there were various acts of sabotage, planting of bombs such as in Podrevo and Kosovska Mitrovica, where explosive devices were planted on marketplaces. Six were killed and 60 injured, again mostly Albanians, and so on.

Parallel with this there was an enormous number of terrorist attacks on the facilities and members of the Ministry of the Interior; 1.642 attacks. When these are taken into consideration as well, then the average for the previous year is not 100:1, that is, compared to previous years. The ratio is much worse. Among these attacks, most of them were attempts to kill; 163 attempted murders. And actually 241 members were ³⁹⁸ killed, and together with them 28 citizens, 23 wounded. Another 478 members of the Ministry of the Interior were seriously wounded and another 363 injured.

At the time, in that period, 246 terrorists were erected [as interpreted], eight injured, and 238 killed in clashes with members of the Ministry of the Interior. I will leave out the locations of these incidents to make the best of the time available to me. At the same time but with some delay, terrorist attacks against members of the army of Yugoslavia began. Out of the 309 registered attacks on members of the VJ, a large number caused the death of soldiers or their serious injuries. Lists of citizens killed, members of the Ministry of the Interior, of people kidnapped and missing, members of the army of Yugoslavia that were killed and wounded, all these lists I will submit to you and the public.

Only from the 1st of January, 1998, until the 24th of March, 1999, when the NATO invasion started, 40 killed and missing members of the army of Yugoslavia were registered. A description of the incidents in which these people were killed or went missing clearly indicates that these were terrorist activities in preparation of the NATO aggression on the Federal Republic of Yugoslavia which followed.

I have here a number of warrants for convicted killers, but I don't have time to go through them. Number 1 is Hasim Taci, who has been convicted to a prison term for a large number of murders of Serbs and Albanians; and many others on search warrants who are charged with multifold and cruel killings, including Osmani Bujar who took part in the ³⁹⁹ formation of a terrorist unit called the Mujahedin Detachment in Kosmet, Abu Bekir Sadik, which involved the participation of foreign mercenaries. As a member of this terrorist unit, he took part, on a number of occasions, against border guards of the army of Yugoslavia and police patrols in the area of Metohija. This Mujahedin unit, Abu Bekir Sadek, is, in a certain sense, also be legitimised in this day and age when the whole world is being told that there's nothing more important than the struggle against terrorism.

All this was happening even while Lugova was claiming that the KLA, this terrorist KLA, was a figment of the imagination of Serb propaganda, and that figment of the imagination deprived all these people of their lives, that this was all the product of Serbian propaganda. In the first half of 1998, the number of victims rose rapidly. In the first months from February to June, the terrorists carried out 409 operations or an average of three daily. They didn't do as many in the previous ten-year period. In 261 cases, the target was civilians. And in that period only, 35 people were killed, and 29 seriously wounded; 21 lightly wounded.

The police were the target of 148 terrorist attacks. Not a single government in the world - gentlemen, there is no government in the world, and I don't believe that there's anyone in the public who could deny this - would remain passive to such activities by armed bands which, in less than two years of an armed revolt, killed 152 persons. Not only did the police have to react to these frequent attacks by the police, but it also undertook active operations to break up these terrorist groups and ⁴⁰⁰ gain control over the territory, especially over roads of a regional and national significance which, in certain places, they tried to block and to paralyse the life of the citizens and public services and generally all people using those communication routes.

Among the first recorded attacks on the army of Yugoslavia up to their offensive activities against KLA forces, almost four months went by which was more than enough for an answer to be given to the question as to who it is in Kosovo and Metohija that resorted to weapons, and who is it that attacked whom.

In February 1998, the American ambassador in Macedonia called the KLA a terrorist organisation, and everything would be fine if the State Department did not make a correction later on. Richard Holbrooke came to Belgrade with the task of saving the KLA from a complete breakup and to impose a solution that would suit the interests of the US and Albanian separatists. And instead of condemning the terrorist organisation like we expected, and we didn't understand at the time his approach, in talks he described the KLA as an autonomous political factor without which no serious talks can be conducted.

So Holbrooke joined the other American representative, Albright, and met a group of terrorists in Kosovo and conducted a talk with them which was filmed by TV cameras. That was the operation when this criminal organisation was taken over from the Germans by the Americans. At the same time the Americans systematically prevented the Security Council issuing even a formal announcement that would condemn terrorism in Kosovo and Metohija. Nevertheless, in spite of that, in ⁴⁰¹ three Security Council resolutions, you will find reference to terrorism in Kosovo and Metohija.

In August and September 1998, the military and police forces practically neutralised the KLA terrorists and their strongholds. And when, in the autumn of 1998, terrorism had been neutralised, and when they were handing in their weapons in tractorfuls to police stations; when the local police, a separate local police had been formed in hundreds of Albanian villages under our auspices and sponsorship, and we had imagined it so that the Albanian villagers themselves should select local policemen who would be given a uniform and a pistol from the state and everything else a policeman should have to take care of law and order in his village, they themselves selected their policemen. In hundreds of villages such local police was established, and terrorism had been virtually totally defeated, weapons had been handed in, a local police had been established, and things were going back to normal.

And then Holbrooke came back again and his delegation. Long negotiations; for 12 days I think they went on, because he demanded observers, military presence, and so on. And I said to him then, "You're not really interested in the Albanians at all. You have another objective," and he asked me which. And I said to him, "To confirm America's leading role in Europe and to confirm America's leading role in NATO." And he said, "Yes, that is our interest." Now, I ask the public: What does that interest mean? The interests of killers in the street who slaughters a victim to take his wallet, he does so out of interest. But where are the other principles on ⁴⁰² which human relations are based? If every single move and every crime is going to be explained by our interest, and then it is the interest of an America 10.000 kilometres away, that their national interest is greater in our country than our own national interest with respect to our own country, who can approve that? Except out of fear, which appears to be quite widespread nowadays. And people are just nodding their heads and approving whatever is said from that quarter.

That is when sponsorship was taken over over the terrorists. And a verification commission was formed, and as it was the OSCE, we trusted it; but whose task was obviously to manufacture a justification for a war against Yugoslavia, because the people they protected, their terrorists, proved uncapable of doing it. They had been completely defeated and widely condemned by the Albanian masses. The Albanian masses did not accept them.

With the formation of that mission, and obviously encouraged by such a development, the Albanian terrorists, at the end of 1998, continued to commit crimes in an even more brutal and widespread manner. As a result of these activities, the number of terrorist operations in 1998 amounted to 1.854. I'm not going to read the casualty figures; 284 wounded, 556 injured. Cafes were blown up. For instance, Panda, in Pec, a bomb went off. Six young men were killed. These were boys who had gathered to listen to music as they do in any other cafes all over Europe.

But let me go back to the political background. In an analysis of the Republican Commission in the US Senate, already in August 1998, NATO ⁴⁰³ intervention had been planned already, but all that was lacking at the time was an acceptable media event which would serve as a political alibi for the intervention. That media event was construed on the 15th of January, 1999, following a scenario which had already been tested --

JUDGE MAY: Mr. Milosevic --

THE ACCUSED: [Interpretation] -- in Bosnia.

JUDGE MAY: -- slowing down, please. We've got a message here. Now, to assist you, we've just been considering the position, in light of the request from the amicus over there that you have more time, and to assist you today and in your preparation over the weekend, we will extend the time that you have. It will be until lunchtime on Monday, so you'll have another three hours.

THE ACCUSED: I understand that is up to 1.00.

JUDGE MAY: 1.00, yes.

THE ACCUSED: Okay, thank you.

JUDGE MAY: But if you'd keep in mind the interpreters.

THE ACCUSED: I will. [Interpretation] This was a scenario tested in Bosnia. The Mrkela incident is well known, and that alleged massacre was again repeated in Racak. And an experienced head of mission, William Walker, experienced, from Latin America, he described it as a misdeed that was never seen before by the Serbs. And that was the task that the OSCE mission had, and especially its leader, which justified the NATO aggression. As is known, we accepted forensic experts from many countries to investigate. A team of Belorussian experts came, and they are well known ⁴⁰⁴ in the world. There was a team of our own experts, who are also renowned in the world, university professors. And all of them submitted their findings which showed that it was quite clear that this was a terrorist unit, because it was established that each of the people killed had shot and fired his weapon at the police. Walker insisted on Finnish experts, and we accepted them as well. And anyway, we heard yesterday the opinion of the Finnish experts.

Unfortunately you know that this whole hullabaloo was used to mount enormous accusations against the Serb forces which were unfounded, because this was a conflict between a police unit, no paramilitary unit whatsoever, as I heard them being described here, but a regular police unit clashing with a terrorist group. And that's all. And I cannot exactly cite the date, but I will find that too. Even the Albanian commander in the region, quite recently in a speech, said that his fighters had been killed bravely in Racak, because he realised that the thing had been already utilised and why should he continue concealing the bravery of his fighters, as he saw it, from his standpoint. There is a large number of people during the verification commission's time who were killed. More than 500 terrorist attacks by the KLA were effected, and the external sponsors repeated this and armed this. So it was in this period that there was ethnic cleansing of 35 villages, cleansed of the Serbs and Montenegrins. And it was only in the -- and in the first 11 days alone of 1999, the members of the KLA effected 80 terrorist attacks on the police and army of Yugoslavia, and civilians as well, in which six civilians were killed, four policemen were ⁴⁰⁵ killed, and ten policemen and other citizens were wounded to some extent. This all shows the situation in Kosovo and Metohija and how it was used as a means to fan the flames of a crisis and to lead in that crisis. We are talking about the use of terrorism in order to realise the strategic goals of the USA and NATO in southeastern Europe, and the example was Kosovo and Metohija.

Clinton's Administration, with that example, showed that they have dual standards towards terrorism, depending on their own interests. For them, they even changed the term terrorist. First of all, they were referred to as terrorists; later on they weren't terrorists anymore. So terrorists and freedom fighters depends on the profile of the victim, the terms used, and what the interests are. When the victims are Americans or the people they protect, then the killers are terrorists who deserve the worst possible sentences. And so while the USA today in Afghanistan is radically settling accounts with terrorism, in Kosovo and Metohija and other regions throughout the world, they are making use of terrorism as an effective weapon, an effective means of that strategy for domination. When, on the other hand, the Serbs are victims, as was the case in Kosovo, then, in the worst of cases, those killers were only referred to as the armed Albanians. Nothing more than that. That was all. While American planes transport the Al Qaeda terrorists from Afghanistan to Guantanamo, chained and fettered, at the same time, of the puppet regime in Belgrade, they are requesting that all Albanian terrorists be freed from the prisons along with the explanation that they are in fact political prisoners. ⁴⁰⁶ Now, can anyone, even if you're not a lawyer - you don't have to be a lawyer, you don't have to be a judge - but people who cut heads with sabres, that cut the heads off women, children, elderly persons, kill postmen, Albanians, Serbs, anyone, can you call them political prisoners, regardless of how much they defend their crimes were political reasons. If we take the example of America, that example is the best if we want to see how bad sponsored terrorism really is, and it represents the greatest danger to mankind today.

For many years America has been applying this double-standard policy, and as the attacks on New York and Washington have shown, they have turned against America themselves. To include the Islamic fundamentalists, the Mujahedin, in the training of terrorists of the KLA in Albania has contributed to the radicalisation of their terrorist actions and the application of the most vigorous methods in settling accounts with members of the police and army, but also with the civilian population including the Albanians themselves.

As to the presence and active inclusion of the training of the KLA fighters and the supreme leaders of the Islamic fundamentalists, including Osama bin Laden and the others, the German Depressor has written about that in December 1998, and the Sunday Times wrote about it too in that same year, and it was not in dispute.

After the destruction of the embassies, the well-known US E