The transcripts of the trial of Charles Taylor, former President of Liberia. More…

  • I again remind you of the need to speak slowly so that both the interpreters and the transcribers can record what you say. Mr Munyard, please proceed.

  • Mr Witness, we broke off yesterday in August 2006 when we were looking at the money that you had been paid by the Prosecution for the most part for information and I would like you please to go back to tab 19 and if we look at the second page yesterday we calculated that by July, by the end of July 2006, you'd had 575 US dollars almost entirely for information, just $25 for transport or lost wages, and then in addition to that tab 8 another 100, that's 675, tab 9, 200, that's 875 and then tab 10 you are given $100 for your family's accommodation and food, that's 975. Then we get to tab 11, the one that you were looking at when we were actually considering the previous - sorry, not tab 11, paragraph 11, when we were all looking at the previous paragraphs. Paragraph 11 is another $700, US dollars, for your family support while you were away from home and then not $200 as you were telling us yesterday, but $250 to get you from Monrovia to Freetown. Do you remember yesterday saying that you remembered well that the first time you were given $200 it was to take you from Monrovia to Freetown?

  • Yes, but I made a correction there later. Yes, I recall that I said that, but later I told you that it was a mistake.

  • We know that. Now, apart from earning some money in ways that you told us at the beginning of my questioning you, were you earning any other money apart from money earned from rental income of one sort of another?

  • Were you earning a living of any other sort?

  • You just tell the judges what other sources of income you had by the end of July 2006?

  • May I just caution the witness not to give any information that would particularly identify himself.

  • Yes, Mr Witness, you have heard Mr Koumjian. You should answer the question, but avoid giving the kind of detail that would show who you are.

  • Yes, apart from my rent I had motorbikes and I was also getting money from the Sierra Leone embassy at that time because at that time I was working along with the ambassador and I was getting support from abroad. Let me just say from abroad, because I was getting family support from there, so every month I used to get money from there.

  • Well, you said in fact, "I was getting money from over here" - no, no, no, I heard - I am just going to put the question if I may. I was listening to the words you were using and you used the words "over here", didn't you?

  • I said overseas.

  • Overseas, I beg your pardon. You were getting money from overseas. Was that from anybody to do with this Court?

  • All right. So the fact that you move from Liberia to Sierra Leone would not affect the money that you were receiving from overseas, would it?

  • It did not affect the money I was getting from overseas, but it affected the money that I was making from my motorbikes and the money that I was getting from the embassy.

  • And how much were you getting from the embassy for doing precisely what?

  • I just caution that, the witness would know better than myself, this may particularly identify him.

  • Mr Munyard, first of all you have asked how much he was getting and you have asked what he was doing. There are two questions in it. Secondly, Mr Witness, when you are answering these questions take care not to identify yourself.

  • How much were you getting from the embassy?

  • I cannot disclose that one here, because if I disclose that one here the ambassador will know exactly because I was one of the people who were working with him. He will know exactly who is the person testifying here now.

  • Where was the embassy? I mean in what city was the embassy?

  • Were you living in Monrovia at the time?

  • Yes, sometimes I used to come to Monrovia. Yes.

  • So when you were living in Monrovia and working for the embassy was somebody else running your rental business elsewhere in Liberia?

  • I used to go and collect my money myself, my rent. I was doing my business for myself.

  • But there was nothing to stop you using one of the people that you told us about a few days ago who had the use of some of your property one day a week - there was nothing to stop you using them to collect your rent, was there, or your rental income?

  • At that time I was there I only trusted myself to go and collect my money. I did not trust any other person, so I used to go and collect it myself.

  • You trusted them with your property one day a week, didn't you?

  • I did not understand that question, please.

  • You trusted those other people with your property one day a week, or have you forgotten telling us that earlier on in your evidence?

  • He may not understand the word "property" in this context.

  • Well, as your Honour will appreciate, I am being deliberately broad in the terminology I am using.

  • I see. I thought it was for reasons of security.

  • He has mentioned the type of property you are referring to, but --

  • I can do it equally vaguely, I hope, in a way that I believe anybody would be able to understand:

  • Now, Mr Witness, you told us some days ago that you received rental income from two particular sources. I am not going to mention the sources. Can you remember telling us that now?

  • I can't remember saying that.

  • Is there any truth in the suggestion that you received money by renting two different kinds of things?

  • One of the things that you rented you allowed the people who operated them for you to use for themselves one day a week. Do you remember telling us that?

  • So you trusted them to use and look after your property one day a week, yes?

  • Yes, with conditions.

  • Were you there when they had your property one day a week or were you in some other part of the country?

  • I would be there, but I gave them condition.

  • Well, what about on the occasions when you went to work for the embassy? You wouldn't be there, would you?

  • When I was working for the embassy I was going doing an external job. It was not always at the office. If they had something for me to go and do they will call me to go and do it, but they used to pay me.

  • Stay with the other items of your property for the time being. We will come on to the embassy. When you left Monrovia and went to Freetown - when you left Liberia and went to Sierra Leone, that is - did you carry on getting rental income from two different sorts of property that you owned in Liberia?

  • When I left Liberia, I had problem with one of the properties because of my absence and I was concerned and I blamed the Court for that, because I said they forced me and they asked me to go to Sierra Leone and that now I am facing problems with my properties. And even before I left I reminded them of that concern about one of the properties.

  • When you left Liberia and went to Sierra Leone, did you carry on getting rental income from the two different sorts of property that you owned in Liberia, yes or no?

  • Your Honours, I am concerned to pursue this in a little more detail and also the embassy matter and I am quite content to go into private session for this.

  • Mr Koumjian, you have heard the application and the Bench is minded to grant the application.

  • For purposes of record under the rules there are matters now relating to private details of the witness which may affect his security if made public and the Court will go into a short private session for that evidence to be adduced. Madam Court Attendant, please put us in private session.

  • [At this point in the proceedings, a portion of the transcript, pages 14681 to 14696, was extracted and sealed under separate cover, as the proceeding was heard in private session.]

  • [Open session]

  • Your Honours, we are in open session.

  • Thank you. Please proceed.

  • Your Honours, could the witness just be advised? Thank you.

  • Indeed, Mr Koumjian. Mr Witness, we are now going back into open session. I remind you not to mention names or other details that could identify you. Please proceed, Mr Munyard.

  • As has been noted, Mr Witness, you have already agreed that you were being paid money for providing information in the years 2004 to 2006. Now in 2005 in September you were given another opportunity to earn money for providing information, weren't you?

  • I disagree with you, because I have said I disagree with you by you saying that I was selling information. I don't know what you are talking here when you say in September I was selling information or that I used to sell information to somebody. I said I disagree with that.

  • Go back to paragraph 1 of tab 19. Do you see that on the screen?

  • 50 US dollars for information, Friday 9 September 2005, the same thing that you had already been doing for well over a year; selling information. Do you agree?

  • I disagree.

  • Well, we have been through all these paragraphs. I am not taking you through them again, but let us go to where we broke off yesterday. Tab 10, accommodation and food for your family, 100 US dollars on 19 August 2006. Where were you on 19 August 2006?

  • I was returning from somewhere to Monrovia and I was on a trip.

  • And were your family in either that "somewhere" or Monrovia?

  • Yes, were they in the place - I don't need to know the name. Were they in the place you have referred to as "somewhere"?

  • I was not coming from my family area on the 19th.

  • Were your family living in the family home on 19 August 2006?

  • Yes, they were living in their family home.

  • Did your family come with you to Sierra Leone, or did they stay back in Liberia?

  • Some stayed in Liberia, yes. Some stayed in Liberia.

  • Well, when you say some stayed in Liberia, when you - when we talk about family here are we talking about you, your wife and your children, or are we talking about you, your wife, children and other relatives?

  • Your Honours, I would just again caution the witness not to reveal the current whereabouts of any family members.

  • I am not asking about current times at all. I am asking about two years ago at the moment.

  • Your Honours, I am informed LiveNote is now functional again.

  • Can I enquire does that mean we have to get out of P1 and go back to our screens?

  • Your Honours, if you could go back to live feed and then press the switch button at the bottom of your monitors, the select button.

  • Thank you. My LiveNote went, so I will take me just a moment, if you wouldn't mind, while I connect.

  • Mine went with it. Mr Koumjian?

  • Can I briefly respond to Mr Munyard's observation. It's possible that the locations two years ago have not changed, so I am cautioning again the witness not to reveal the current whereabouts of any family members.

  • Mr Witness, you have heard Mr Koumjian.

  • Yes, I am sorry about the delay. It's now coming back on my screen.

  • Mr Munyard, please proceed.

  • Yes, I was actually not asking you about where your family were. I was asking you about what you mean by family when you said some stayed in Liberia. By family, what category of relatives are you talking about?

  • I am talking about my wife and children.

  • Right. Did they come with you to Sierra Leone?

  • No.

  • So did they all stay behind in Liberia, your wife and children?

  • Right. And without telling us where it is, did they all stay in the family home?

  • Yes, but the children are not staying together in the same place.

  • Right. But they are all still in Liberia? That's all I want to know.

  • Objection, that's irrelevant. [Overlapping speakers] irrelevant, but there is a security issue.

  • Liberia is a big country. He has already given a great deal of evidence about how he lived in Liberia. I really --

  • Mr Koumjian, we don't even know the numbers or the sex or anything else or their location. I allow the question.

  • They are living in Liberia, yes.

  • Thank you. Now, Saturday, 19 August 2006, box 10, tab 19, 100 US dollars for accommodation and food for family. You were travelling, you have just told us, from somewhere to Monrovia. Were your family on that particular day at home? This is the day before you leave to go and live in Sierra Leone.

  • Was there any particular reason why they weren't at home?

  • Home? I answered no, whether it was on the same day that I left, 19 August 2006, but they were living in their homes.

  • Right. Thank you. So what did you get $100 for for their accommodation and food?

  • Because they used me on 18 August I recall to go and get them somebody from outside Monrovia and when I went there I passed the night there and on the 18th in the morning - I left on the 18th in the morning hours and I returned on the 19th around 6 p.m. in the evening, so I think that money was for those two days that they used me.

  • So for going off to find somebody and coming back again the next day you got 300 US dollars, is that what you're telling us, from the Prosecution?

  • I got 100 US dollars to take care of the two days. The $200 was not for me, but to use for their own purpose, for the Prosecution's own purpose to go and get the person and bring the person to them, transportation, blah, blah, blah, everything.

  • What part of $200 pays for blah, blah, blah?

  • To charter a jeep from Monrovia to the area where I went to get the man to pay for lodging, because I did not get there that same day. When we were going the road was so bad and the car got to the point it could not move, so we asked people to assist us move it. So sometimes I went through certain areas and things were really difficult, but I tried to talk to people for them to understand to help me so that I can pass my way through. So that is what I am referring to as blah, blah, blah; just for me to go and get the person.

  • To charter a jeep, to get the man, to pay for lodgings. You just told us you had 100 US dollars for your accommodation and food as part of this trip because it was an overnight trip, or have you forgotten that, that you've just told us that?

  • It was on my return that they gave me the $100 because they knew that I had spent two nights for their own purpose and they did - and I was not supposed to have spent two nights with them, but they appreciated what I did for them, so on my return they gave me that hundred dollars and it was after I had returned from the trip that they gave it to me. I think it was just something like appreciation from them.

  • It was appreciation. It was an appreciation gift, was it?

  • Yes, they said so that I can go and maintain my family with it, because I had left my family for two days and --

  • Well, when this story began you only spent one night overnight. Now it has expanded to two nights. Can you explain how that has come about?

  • "Two days" I heard and see on the record, Mr Munyard.

  • Would your Honour give me a second while I check that?

  • I am referring to page 32, line 5.

  • Well, I am looking at page 31, line 21. At line 20, "It was on my return that they gave me the hundred dollars because they knew I had spent two nights for their purposes".

  • I see. Very well. Put the question. Unfortunately that part is blanked out on my screen.

  • Your story has grown from one night spent overnight to two nights now, Mr Witness. How is it that you have suddenly remembered a second overnight that they had to give you an appreciation hundred dollars for?

  • I said two days. Two days. From the 18th in the morning hours I left. I returned on 19th in the evening hours around 6. Around 6. And how come I said two nights? Because I said I returned at 6. That was the blank night because I was not able to do anything. That was - those were the two nights, because when I returned at 6 I just slept, so there were two nights. It is all under it, because when I returned they used me again to go and get hotel for them, for the same person that I went and called, so it was two nights. I left there about 7 to 8, so it was two nights.

  • And where was it that you went to?

  • Out of Monrovia. I can't show the location, because if I show the location you will know exactly what I am talking about.

  • Well, with great respect we won't. We went know anything other than you went to a particular location. Now answer the question. Tell us where it is you claim to have gone to for which you got $300 between 18 and 19 August?

  • I would ask that the witness's answer be redacted from the record. This explanation apparently would identify him. He is saying his name was broadcast on this particular - and he has associated it with a particular broadcast.

  • Well, Mr Witness, you have just given us an answer. Do you think that answer is going to identify you?

  • [Trial Chamber conferred]

  • We will have the passage redacted and the name that counsel is seeking to elucidate can either be written or recited in private session.

  • Madam President, can I just clarify I am only asking for the name of the place, or the area, for that matter, the broad, general geographical area. I haven't asked for any name of --

  • That's what I mean. I am quite clear in my mind you are asking for a location name, not for a person's name. I have never been in doubt about that.

  • Can I just suggest so perhaps the witness can understand counsel, he is only asking for a general area, a county of Liberia, or general area where you went, where the witness went, as I understand the question.

  • If we are going into private session then we can be as detailed as the Court thinks appropriate, but in public session if the Court thinks it's appropriate I am quite content with the area.

  • I have suggested writing it to save time.

  • Writing it. I am perfectly happy with that.

  • Mr Witness, would you be able to write the name of the place or the general area that you went to on a piece of paper if it was given to you.

  • Let somebody come and assist me, please.

  • Your Honours, I am probably intervening unnecessarily. I just want to make sure that the redaction order was understood that it was beginning on page 33, I believe line 16 - that witness's answer is redacted. Thank you.

  • It is being implemented, Mr Koumjian, as we speak. Mr Witness, have you written that? You are waiting for assistance.

  • I have written it, but I want to enquire about something.

  • Madam Court Officer, I note that the witness has written something on a piece of paper, but before he did that he wanted to enquire of you about something. Can you tell the Court what he said to you?

  • Your Honour, he wanted me to guide him as to spelling.

  • I see, thank you.

  • Madam President, my only request would be that he signs and dates the piece of paper.

  • We were just noting that ourselves, Mr Munyard. Madam Court Attendant, when you have dealt with the redaction I would be grateful if you would have the witness date and sign this piece of paper.

  • Your Honour, may that be given an MFI number for identification and marked confidential, please?

  • I think we are up to MFI-3.

  • Your Honour, it would be MFI-3.

  • Mr Munyard, please proceed.

  • Your Honour, may it be marked confidential, please.

  • If and when it is tendered it will be confidential, but I have noted carefully that you want it confidential.

  • There is no difficulty with that procedure as far as we're concerned. It seems to be appropriate:

  • Right. Can we have a look, please, at box 11, 20 August 2006, $700 for family support while you are away from home for an extended period and there is the $250 in travel costs for your relocation from Liberia to Sierra Leone. Now how was the $700 worked out, do you know?

  • They proposed to me to leave Liberia for Sierra Leone and I told them that, "How would I leave Liberia for Sierra Leone when I have a small job here? I can do a job here and make money out of that job". They said, "Oh, because of this particular reason that we are using you to go and call this particular individual we may not know - maybe he will comply with us or not. It would be a threat to you. So we would like you to leave this country and go over there". I told them I will think about that.

    I called my pastor the phone and I told him the same thing and he said, "Okay, if the people say you should go don't refuse them, they know what they are talking about". So I too decided that I would go. Then they said, "Okay, before you leave we know that you will lose your job at the embassy. We will not be able to pay you or accommodate you to be supporting your family so that you will be able to support your family here". I said, "Okay, I accept".

    The hour and the minute that I was leaving Pete McLaren came with $700 came and said, "I want you to leave this money with your family. You should give $300 to your daughter and other $300 to the other girl and the $100 to their mother. When you go over there every six months maybe we will be sending something to them" and I said, "Okay, I accept". That is how the $700 came about.

  • All I wanted to know was did the Prosecution ask you how much you would normally be paying or you would normally be spending to support your family and when you told them what your normal family expenses would be they agreed to pay that money, or did they just turn up and say, "We reckon 700 US dollars should cover your family expenses"? Which way round was it?

  • They just said they will give me $700. They said it will help me to cover my family's expenses.

  • Thank you. So this wasn't a sum that was worked out as a calculation of what your actual family expenses would be. It was just a lump sum that was given to you, yes?

  • Yes, just a small sum of money.

  • Now, you then get $250 yourself to go to Monrovia and did it cost $250 - sorry to go from Monrovia to Sierra Leone?

  • I was not the one that proposed $250 to them. The person whom they asked to travel with me was the one who said that. Can I finish, please? They asked him, "How much do you think you can travel with this boy to take him to Freetown?" They were the ones who spoke about this money, the $250. I was not the one who did it. Somebody travelled with me. Somebody took me along. He handled the money.

  • And how much profit did you make out of the $250 on that journey?

  • I used to eat. Whenever I am ready to eat I will eat. I rode a good car because they hired a car for me, because they said they didn't want people to disturb me in the car. These are some of the profits I made out of it. And I slept in a beautiful guesthouse, you know. Those were the only profits I made.

  • Now on 20 August 2006 you were brought under the protection of the Witness and Victim Section of this Court, weren't you?

  • It may be so, because I crossed over on the 20th. I know on the 20th they started taking care of me. I think so, but I can't remember the date any more.

  • And from that day to this day the WVS has been paying for your rent - has been paying for your accommodation, for your medical costs, your transport, all sorts of miscellaneous expenditure and all your bills and giving you subsistence allowance, do you agree?

  • Right, box number 12, please. The same date as you received $700 for family support, $200 to go to Sierra Leone, you receive another $400 for information from the Prosecution. What did you get $400 for on top of everything else that day?

  • I think this 20 August 2007, I think it was a mistake that had been made there because I remember receiving 200 --

  • Your Honours, can he repeat, please.

  • Mr Witness, the interpreter asks that you repeat. Pick up your answer, please, where you say, "I remember receiving 200". Continue from there.

  • I remember receiving $400, 20 August 2007, $400, but I don't remember receiving $400 on 20 August 2006. Maybe they just made they - maybe they've made their own profit out of me, but I don't remember.

  • "Maybe they've made their own profit out of me", do you mean by that that they have put down that they paid you $400 but actually they kept it for themselves? Is that what you're suggesting?

  • Or maybe you put it there, you who brought this document to me, I don't know, because I don't remember. They didn't pay me and I was not receiving pay and nobody gave me money at that time. Maybe it is you who made this, I don't know.

  • So now you're suggesting that I have put that figure into the document to trick you, just like Varmuyan Sherif you claim tricked you into going to give information in September 2005? You're claiming I have tricked you, are you?

  • Because the document, you are the one who asked for the documents and I don't remember receiving this type of money 20th 2006. It may be you, I don't know.

  • Mr Witness, refrain from making allegations that you cannot substantiate and are without foundation and improper.

  • I am not making an allegation. I am just proposing. I am suggesting.

  • Please do not argue with me.

  • Let's go back to your first suggestion that it was the investigators who have "made their own profit out of me". What did you mean by that?

  • Because I do not remember receiving money on the 20th - $400 on the 20th, 2006.

  • What did you mean by "maybe they are making their own profit out of me"?

  • Because I did not receive money and when I see money here it's an allegation against me and I am not aware of the money. I don't know how comes that the money is here. Maybe they just wanted to write it there, $400, to try me, or they ate the money. I do not know whether they wanted to try me or they ate the money, so I don't know. They made this receipt. I am not aware of this money.

  • It's a huge sum, isn't it?

  • For me it's a small money anyway. Maybe for you it's big money, I don't know.

  • It's almost a year's rent of a house, isn't it?

  • It doesn't matter. It's small money to me.

  • It is more than two months worth of doing almost nothing for the Sierra Leonean government but being on the payroll, isn't it?

  • Are you suggesting that I am doing nothing? I suggest that I was not doing nothing. I have been paid money, I was doing something.

  • Look at the box, box 12. Sunday, 20 August 2006 you were paid 400 United States dollars for giving information to the Prosecution. You claim that you were given - first of all you said 200 and then $400 in August 2007. What were you given either two or four hundred dollars in August 2007 for?

  • I did not say two or four hundred dollars. It was a slip of tongue. I said two and then later I changed it immediately to $400 and I told you nobody gave me $400, 20th 2006 August. Nobody gave me this money.

  • What were you given $400 in August 2007 for?

  • They said I should send it to Liberia to my family.

  • You see on the same day, 20 August 2006, you had already been given $700 for your family, hadn't you?

  • If $400 is not a big sum to you, is it possible that you were given it but, because it was so insignificant, you have now forgotten about it?

  • It's not possible, because I remember $200, $250. Like I remember $50, $25. If they gave me the $400 I will remember it, but I do not remember this.

  • Over the page, please. Box 13. You are now living in Sierra Leone. It is January of 2007 and you were given local currency, leones, 50,000 leones for transport. Can you remember why you were given transport costs in January 2007?

  • And what was the reason?

  • Because the area that they put me, I was not happy with the area. I told them that the distance from there to go to town, I won't be able to live here. Let them move me from here. They said, "Oh, for the security this is the only convenient place for you" and they told me I should live there. I said if you want to live here I proposed to them they would need to help me out with transportation because to leave there to go to town I actually did not have the money. You give me 10,000, but I pay 5,000 every day for transport, you actually brought me here to keep me suffering. So they gave me that for transport.

  • Box 14, please, 22 March 2007 you were given 700 US dollars for further family assistance. Do you agree with that, or is that something I have invented or they have just put in there so they could eat the money?

  • I agree with that.

  • Box 15, you were given money for top-up cards, local currency, 30,000 leones by the Prosecution on 13 April 2007. Box 16, August 2007, not $400 but $700, further family assistance. So where is the $400 in August of 2007?

  • It is on the 20th and this one is on the 14th, so it's six months later they gave me the other money.

  • So you got $700 in August of 2006 for the family, another $700 in March of 2007 for the family and then you say you got $400 on 20 August 2007 for the family. Is that what you're telling us?

  • I think I made a mistake on the other 400. I made a mistake on the $400. That $400 was in 2008.

  • Well, in that case --

  • Yes, in March 2008. So I can remember making a mistake over there.

  • Well, in that case go back to the $400 on 20 August 2006 and tell us what that was for.

  • I do not remember receiving this money on 20 August 2006. I do not remember this money. I do not know what it was for.

  • Right. 20 August 2007 you say you got $400, yes?

  • It was a mistake anyway. It was not August 2007. It was a mistake. It was in March 2008.

  • Have a look at box 16. 14 August 2007, another round sum of $700. Did you get that for your family, or didn't you?

  • I got it, yes.

  • Did you get any more on 20 August 2007?

  • Over the page, please. During September of 2007 the Prosecution paid you various sums: 30,000 leones on the 7th for a top-up card; 75,000 for transport on the 7th also and on the 12th you were provided with a mobile phone at a cost of 120,000 leones. Do you accept you were given all of that either money or items such as a mobile phone?

  • Yes.

  • And I should add for good measure another 30,000 for a top-up card on the following day, 13 September. Now over the page, paragraph 21, again on 5 October you are given 50,000 leones for transport for October. Can you remember receiving that?

  • The same amount in November and in December and in January of 2008. Can you remember receiving that?

  • Yes.

  • Over the page, box 25. 17 January 2008, 50,000 leones for transport due to long distance for the month of January, another 50,000 leones in addition to what we saw - we didn't look at it in detail - in box 24. 50,000 leones transportation due to long distance for month of January 2008. Any reason why you got double your money in January 2008?

  • I don't remember having double money for transport in one month.

  • Box 27. 1 February 2008, security for family, another 300 US dollars. Is this in addition to what you got in March of 2008?

  • This money was not all the money I was having in March. It was this money that I was making mistake about. I was having problems with this $300.

  • Your Honours, can he repeat slowly and more clearly.

  • Mr Witness, the interpreter asks you to repeat your answer. Please pick up where you said, "I was having problems with this $300". Please continue from there.

  • I had problems with this money. That was - that is why I am having problems with it in court, because they refused to give me this money. They said Brenda went and said --

  • Your Honours, can he repeat again from where he said "Brenda".

  • Mr Witness, your voice went down and the interpreter cannot hear you clearly. Please repeat your answer when you said, "They said Brenda went and said". Continue from there.

  • They told me after six months every six months they will give me something to be sending for my family. After this other six months when I asked them they said they cannot afford to give me any other money to send for my family because, you know, so and so, blah, blah, blah, and I said no. I said no. I said, "You should give me something. Whatever amount you should give me, I know you are not paying me". They said they were not able to afford anything and I said okay and I sat down.

    I was sitting down one day when one Mustapha called me and said I should put my case across and I put my case across to WVS and I think they forwarded the case to - I think they forwarded the case and after that Brenda went to Freetown and called me up and said, "We know that you have your family over there and there is no way to support them. Sign for this $300 and send it for your family". So I signed for the $300 and I gave it to one of the Prosecutors to take for me to Liberia for my family.

  • Right. "They told me after six months every six months they will give me something to be sending. After this six months when I asked them they said they cannot afford to give me any other money to send for my family because so and so, blah, blah, blah and I said no." First of all, who is the "they" who told you they would give you something every six months?

  • When I came to Freetown I think it was an arrangement between Prosecution, those that brought me to Freetown, and WVS. They told WVS and witness management about my family in Liberia. So I met the witness management boss before. I think that was a woman whom they called Sophie. I explained to her and she said, "Okay, the money that they gave to you before you came every six months - I think every six months we will be able to give you that same money to be sending to your family", but when Sophie left another management - witness management - another boss came, Rosco. Rosco told me that he or she will not be able to give that money to me at this time. And I said okay, I agreed. So it was Brenda that gave me the money. She said they should give me the money because I had my family over there in Liberia. They should give me $300 for me to send and I appreciated it.

  • And who is Brenda?

  • I think she is a lawyer I know.

  • Have you had other dealings with Brenda apart from this telephone conversation about your money?

  • When she went there for this money I made complaints to her. I put some concerns to her about my security, because at the time they said they would soon be getting ready for me to come and testify. I should come open and I said no, I was not coming in the open. That was another conversation I had with Brenda, about open and closed. She told me that she will work on it.

  • When you came to The Hague in June, and you were telling us yesterday that during a four day period in the week before you started giving your evidence you were in a room with a man, two women and two interpreters and you were able to remember that the man was Mr Koumjian and one of the women was Shyamala, the other woman who you said wasn't writing anything and wasn't asking anything, was that Brenda?

  • Are you quite sure about that?

  • Yes.

  • Back to this answer that you gave us a moment ago. "They cannot afford to give me any other money to send for my family because so and so, blah, blah, blah". What do you mean by, "So and so, blah, blah, blah"?

  • They were explaining things to me that I would not pay attention to. They were saying, "You know that we told you earlier that we will not pay you and now the Court hasn't got money to give you another money", this and that, I said okay. I was not paying attention to that, that was why I said blah, blah, blah. I was not paying attention to all that they were saying. I was just passing over my ears. I was not paying attention to them. I said they should give me a car to take me back home. That was why I said blah, blah, blah. I was not paying attention to all that they were telling me. They were talking and it was flying over my ears.

  • Were they complaining that you were costing far too much money?

  • I do not understand that question.

  • Were they saying, "We are not giving you as much as we have done in the past because we've had to spend far too much money on you"?

  • They did not say it like that. They said we did not arrange that they should be giving me something. I said, "No, check your record. You used to give me and Sophie promised me that the same money that they used to give me before I came here they will be able to help me with that same money and now you are telling me that you don't have any record about that". I said, "Please, check your record". He was telling me something different that I didn't understand.

    I said okay. I made the complaints to WVS. I went back to WVS and made the complaints there that the management is giving me a problem and I am having problems with my family in Liberia. So I think they worked on it. After Brenda went to Sierra Leone she called me and gave me this $300 and I signed for it. I was Rob Hotston who gave me the money and I signed for the money. It was the same Rob Hotston that I gave the money to take to Liberia.

  • Right. And so how much did you get in February 2008 for your family?

  • No, I was making a mistake on that $400 business.

  • Are you quite sure you got only $300 in February of 2008 for your family?

  • Over the page, please, to box 29. Same date, 1 February 2008, another 300 US dollars for your family. Is that something that either I've written in there or they've put in in order to make a profit for themselves?

  • I am not aware of this $300. I don't know anything about it.

  • On Friday, 1 February this year you were given a total of 600 US dollars for your family. Do you agree?

  • So what do you say this receipt that we see in box 29 is all about?

  • I am unable to say what the receipt is about. I am not aware of the money. You can go and ask them, the people who gave you the receipt. I am not aware of the money.

  • Mr Munyard, to be fair to the witness box 29 gives a reason, family security.

  • Your Honour, so does box 27. It is exactly the same.

  • So it doesn't necessarily follow that the witness received this money. Perhaps what you should explore is if he knows what family security is.

  • Do you? Do you know what family security is; what that particular phrase means in a Prosecution receipt?

  • No, I do not know what they call family security.

  • Box 28 we missed out. I just want to ask you about that. Another 50,000 leones for transportation due to long distance for the month of February 2008. Do you remember receiving that?

  • Yes, they gave me 50,000. Yes.

  • And then I am going to move over the other boxes following 29. They are either transport due the long distance for March or April or a top-up card and the same in box 33, 15 May, transportation due to long distance, another 50,000 leones.

    That brings us to the grand total, according to these receipts at any rate, that you received from the Prosecution from September 2005 to May 2008, do you agree looking at the last two lines on the last page, that the Prosecution have paid you 4,325 US dollars and 825,000 Sierra Leone leones?

  • Excuse me, that misstates the document. As the document indicates on the first page it is a list of disbursements for a witness and we have had this issue before.

  • I completely accept the criticism.

  • I will rephrase the question:

  • Do you agree that the Prosecution have spent on you or your family 4,325 US dollars and 825,000 Sierra Leone leones according to these official receipts?

  • I will agree. If they give me a calculator and we calculate all the money, I will agree.

  • Have you had any other money from the Prosecution from any of the investigators or any of the people who ever met you at any time?

  • I don't remember any longer.

  • Tab 20, please. Now this document in tab 20, which is dated 15 August 2008, sets out the amount of money that has been spent either on your behalf or supplied to you directly by the Witness and Victim Section of this Court. If you look at that document in the middle of the page, paragraph 2 says:

    "Subsistence allowance. Witness was brought under the protection of the Court on 20 August 2006. To date he has been paid a total of 13,122,800 leones."

    What is amusing you about that?

  • Nothing made me to laugh about that. It is just my usual habit. I am not laughing. I am chuckling.

  • We note your answer. Do you agree that you have been paid a total of 13,122,800 Sierra Leone leones as subsistence allowance in the last two years?

  • I can't just agree because except they put a machine and start calculating since the day they started giving me money up to present. I can't just agree.

  • Just help us with how you get paid your subsistence allowance from the Court as opposed to the money you have been paid from the Prosecution. How is it given to you, this subsistence allowance?

  • They gave me it weekly, 70,000 leones. 70,000 leones weekly. And they bought petrol for me for the generator, but medical, they just used to take me to the hospital. I do not know whether they paid this type of amount. I do not know. I am seeing it now. They did not show me any receipt for medical, but I know that they used to take me to the hospital at all times.

  • We are going to look at those sums in a moment. I just want to know from you out of your 70,000 leones per week in the hand what did you have to pay for out of that?

  • Food, soap, toothpaste, any other activity you can think about apart from buying petrol for my generator. Any other activity. For my clothing. Everything is in the 70,000 leones.

  • Did you ever complain that it wasn't enough?

  • Did they increase it when you complained?

  • How often did you complain?

  • So many times. Sometimes when they give me 70,000 I do not - I didn't want to even sign for it. I said I didn't want it, but they said this was what they were able to do for me.

  • What, you didn't think it was enough on the one hand, but you wouldn't even - you didn't even want it and wouldn't sign for it on the other hand? Which version of events is the truth?

  • Because I thought that it was not enough for me.

  • So medical expenses - you believe that whenever they took you to the hospital they paid the bills, yes?

  • Yes, I believe, because they did a major thing on me and I appreciated that. After we were --

  • Your Honours, can he kindly repeat this area very slowly.

  • Mr Witness, you are going too quickly. Repeat your answer slowly, picking up from the part where you said, "After we were". Continue from there.

  • Okay. Yes, after they had taken me to hospital they did something for me. After they had brought me to Sierra Leone they did something for me that I appreciated. They took me to hospital, I did an x-ray and they detected that I had a bullet - a fragment in my body and Special Court helped me to take everything out of my body and we were fighting a war for President Taylor and Special Court did that for me. So I appreciated that. That was the time I was more encouraged to work with them. I appreciated that. I knew that they would pay the bill, because you would not take somebody to hospital and not pay the bill. I know that they paid the bills.

  • Right. Now you were paid - sorry, they paid 775,000 leones for your medical expenses. Would you have had to pay for those yourself if the Court hadn't kindly agreed to pay for them?

  • They proposed that. They wouldn't advise for me to be carrying that thing in my body, so I knew that they would pay. They were the ones who proposed it. They took me to the hospital because I was complaining about my legs, my arms, that I was feeling pain and they asked me what happened and I said I was hit by a bullet there, so I knew that they would pay. If they were not going to pay they wouldn't have taken me there.

  • Right. Which year did they pay your medical bills?

  • I think I can remember when I crossed - 2006, I think so, I crossed.

  • You think it was in 2006?

  • Yes, 2006. I can remember 2006 after I had crossed, it was then that they did the operation on me.

  • And so this is at a time when you are still earning rental income from the two forms or the two sources that you have told us about already, but you were no longer earning your $175 a month from the Sierra Leoneans, yes?

  • I do not understand that word, "Sierra Leoneans".

  • Yes, I was not getting any money from them any more.

  • Now transportation. The Court, as opposed to the Prosecution, spent 1,132,700 leones on transportation. Without specifying names of towns or anything of that sort, can you assist us at all in relation to what these transportation costs were concerned with?

  • Yes, they were paying my transportation. From where I was living presently to come to the city is a far distance. Sometimes I told them that I wanted to visit my family upcountry, up in the interior, sometimes they used to help me to pay my way.

  • Thank you. Now, miscellaneous 3,578,700 leones. Now that wasn't all on gasoline, was it?

  • I think all was on gasoline. They gave me the money for gasoline. It was on gasoline. It was on gasoline.

  • If it was just on gasoline then we could expect to see that under the heading "Utility bills", so you help us with this: What did you get over three and a half million leones for over the last two years for miscellaneous expenditure?

  • The money they gave you, when they say it is gasoline, if this is the actual figure it was for gasoline. If this is 3,578,700 leones was for gasoline, it will be for gasoline. What they gave me for gasoline was for gasoline. What was for this was for this, as far as I'm concerned.

  • Mr Munyard, we have reached the end of the tape, so if it is appropriate we will take the mid-morning adjournment now.

  • Certainly, your Honour.

  • Mr Witness, it is now time for the mid-morning break. We will adjourn until 12 o'clock. Please adjourn court.

  • [Break taken at 11.30 a.m.]

  • [Upon resuming at 12.00 p.m.]

  • Mr Munyard, please proceed.

  • Thank you, your Honour:

  • Mr Witness, your gasoline was a utility bill, wasn't it?

  • I don't understand the word utility bill.

  • Fuel, electricity, gas, those things are called utilities. Do you understand that?

  • Sorry, Mr Koumjian, I am not sure if you are on your feet or not.

  • [Microphone not activated]

  • I don't know what you call electricity, because for me the area where I am I don't have electricity there. We only use generator, so I don't understand. We don't have electricity in that area - in that particular area at present. We only use generators there.

  • But a generator generates something called electricity and that now reaches the boundaries of my knowledge of electricity and generators, but that's what I mean. It's the power that the generator generates, hence its name.

  • Okay, I agree.

  • Well, then let's go back to miscellaneous. Over three and a half million leones were spent on what?

  • I don't know what you're referring to as miscellaneous, except if you can explain to me.

  • I am sorry, I don't think the document was in front of you and that was my error. Madam Court Officer is now going to show it to you again. Do you see paragraph 2 in the middle of the page? We've dealt with subsistence allowance, that's your spending money. Then we have got medical expenses. We have dealt with those. We have dealt with transportation and now there is a large sum there under the heading "Miscellaneous".

    Before we come back to it, just let me make clear that the final amount specified there is rent, maintenance and utility bills the equivalent of 19,750,000 leones. Now rent speaks for itself. You don't need me to explain rent, do you?

  • Yes, I don't even know how much they pay for the house I am living in because they just took me there and I was there. I don't know. Maybe it could be 50 million or hundred millions, so I don't know how much they are paying for the house.

  • Don't worry about the amount. It's contained within this figure of 19,750,000. Rent, maintenance. Now we've never been given any explanation of what these terms mean, but I am assuming maintenance means any bills for repairing the property that you have been living in, that's paid for. And utility bills, I've just explained what utility means, so generator fuel would be paid for within utility bills.

    So go back to the heading above that, "Miscellaneous". Can you think of anything else that the Court has either spent its own money on or has paid you for that you haven't yet mentioned that could possibly have come to a total of over three and a half million leones in a two year period?

  • Yes, I remember they did something for me that I was grateful for actually.

  • Are you going to let us into the secret?

  • Yes, I can tell you if you want to know.

  • Well, when I got to Freetown they asked me, they said I cannot just be sitting like that and I said yes. And they said, "What to you want me to do for you?" And I said, "Okay, you can help me by sending me to a computer school". They said, "Okay, we will send you to the computer school". And then I am aware of that. They sent me to the computer school and they paid - they paid good money because I was attending a good computer school.

  • How long were you attending the good computer school?

  • I don't know how long, but I started from Novice to Access and each programme takes about a month or one and a half months.

  • Roughly how many months were you attending the school?

  • Roughly eight to nine months.

  • Were you going every day, every weekday that is?

  • No, but sometimes I made effort to go every day, but the school did not want us to go every day, but with my own effort I used to go there every day.

  • About how many days a week on average did you attend the computer school over this eight month period - sorry, eight to nine months?

  • Well, the regular class was Monday/Tuesday and Thursday/Friday, but we had a study class. If you like you will go, so I used to go.

  • And would you be there all day on those days of the week?

  • According to the school the class lasts for two hours, two hours ten minutes, but because I did not have anything else to do I can be there for about five to six hours because I will look for somewhere where there is an empty computer and I will sit by it and teach myself.

  • And which year or years did this eight to nine month period cover?

  • I think I started, I can remember, in late 2006 to 2007. Up to the end of 2007 I was going to the computer school, but I can't remember the actual time now that I started.

  • And what language were you taught your computer courses in?

  • Both Krio and English. Both.

  • What percentage of the course was in English?

  • About 90 per cent.

  • Thank you. Any other things that you can think of that might be said to fall under the heading of miscellaneous that the Court provided the funding for?

  • First of all, I want you to break down this word for me, miscellaneous.

  • Miscellaneous means items that are not covered under the following categories: Subsistence allowance, which I have called spending money; medical expenses; transport costs; rent; repairs and utility bills. Now you have come up with the computer course. Do you know if the computer course cost over three and a half million leones, or might there have been other things that the Court either gave you money for or paid the bills for themselves that you haven't so far mentioned?

  • Yes, they paid some bills that I have not yet made mention of. Yes, like the buying of a memory stick for me, sometimes the payment for certificates and statements because sometimes like in the case of Naeem, he would want to see statements, so he will go and pay for the statement, that I can recall. And during the computer class they used to give me transport to go for the computer course. At that time I had not yet moved to the area where I was living and they used to give me 50,000 leones.

  • Transport is covered under transportation. Who is Niemi?

  • I did not say Niemi. I said Naeem.

  • And what is this statement that Naeem would want to see?

  • The result from the school, any of the results and how I was doing, because he said they can cannot just be paying money because maybe I was not making effort. So at any time we took an exam he will say I should bring the statement for them to see.

  • Who is Naeem who wanted to see these statements?

  • I used to see him in the WVS office.

  • Right, so occasionally the Court would pay for a statement from the school showing the results of the various courses you had done, yes? Can you think of anything else that the Court paid for out of this more than three and a half million leones?

  • I can't remember. It is possible they paid for other things, but I can't remember really.

  • Right. So, looking at the figures here, in addition to what you got from the Prosecution you have been either paid in your own hand or bills have been paid for on your behalf to a total of 38,359,200 leones in a two year period. Do you agree with that?

  • It depended on when they calculated the money in my presence.

  • And, for the sake of completeness, you have also been paid subsistence for the time that you have spent in The Hague. Do you know any other witnesses who have been paid even more money than you have by the Prosecution and the Court?

  • The Prosecution did not pay me, so I don't know if there was any other witness that they paid. I don't know if they paid some other people, because for me they did not pay me, so I don't know anything about payment.

  • What about your big brother, Varmuyan Sherif? Do you know how much he was paid?

  • Objection. What is the relevance of this witness's knowledge of that? Objection, relevance.

  • Yes, what is the relevance of that question, Mr Munyard?

  • Discussions between him and another witness.

  • On that basis I will allow the question. Please put the question.

  • Do you know how much your big brother, Varmuyan Sherif, was paid for giving evidence?

  • I don't know whether they paid Varmuyan Sherif, or whether he was even a witness for the Special Court. I don't really know.

  • Are you seriously claiming that you don't know whether Varmuyan Sherif was a witness in this case?

  • At the time I used to see him in Liberia, yes, I did not know. It was later, I think in January or February, that I heard the name Varmuyan Sherif, but I did not know which Varmuyan Sherif was that and at that time I had not been seeing him again.

  • So this is another person, is it, who has a name that applies to more than one individual? Is that what you're saying; that there might have been another Varmuyan Sherif who was giving evidence in this Court different from your big brother Varmuyan Sherif?

  • Yes, because since I heard - I saw Varmuyan Sherif, after that I did not know where he was again, so I cannot just conclude or claim that that was him.

  • How many ULIMO commanders do you know who were called Varmuyan Sherif?

  • I was not a ULIMO fighter so I don't know anything about ULIMO.

  • You weren't a lot of things, but that has not stopped you giving evidence about them. How many ULIMO fighters have you ever heard of who were called Varmuyan Sherif?

  • Asked and answered.

  • I don't know anything about ULIMO. I don't know how many fighters in ULIMO were called Varmuyan Sherif. I don't know anything about ULIMO. I only heard about ULIMO in Liberia and at the time ULIMO was fighting war in Liberia I was not there, I was not with them, I did not have any connection with them. I don't know how many Varmuyan Sherifs were in the ULIMO, whether they were one, or 1,000, or one million, I don't know, except you help me.

  • The witness has answered the question, Mr Koumjian. In any event he did not answer the previous question. The answer he gave did not go to the essence of that question. Please proceed, Mr Munyard.

  • Thank you, your Honour:

  • How many Varmuyan Sherifs do you know who were commanders in the LURD?

  • I did not know how many Varmuyan Sherifs. I don't know.

  • How many Varmuyan Sherifs did you know who were active in the Johnson-Sirleaf electoral campaign?

  • I know one Varmuyan Sherif.

  • And that's your big brother, as you call him, correct?

  • Yes, I said I regarded him as a big brother, yes.

  • Did he ever help you in your intelligence gathering for which you were being paid by the Sierra Leonean embassy?

  • He did not have to help me and he did not help me, no.

  • Did you ever share any of the money that you got from the Sierra Leonean embassy or that you got from the Prosecution with Varmuyan Sherif?

  • No.

  • Because it was Varmuyan Sherif who got you your first payment from the Prosecution, wasn't it?

  • I did not get any first payment from Prosecution. I only got first transportation from Prosecution.

  • I want to go back now to the early part of your account in evidence. In what year were you first involved in active fighting with the RUF?

  • I started fighting for the RUF in '95. I think '95.

  • So you were an active fighter in 1995 with them, is that what you're telling us?

  • That was the time I started firing gun at the front line.

  • Your Honours, the last bit of the witness's testimony was not clear to the interpreter.

  • Mr Witness, the interpreter did not hear the last part of your answer clearly. Please repeat from where you said, "Started firing gun at the front line". Either finish that sentence, or clarify it, please.

  • In 1995 I was at the front line and that was the time I started involving myself in battles, but I was not as active as the way he is claiming it to be, or the way he is thinking.

  • What way am I thinking?

  • You asked me whether I fought in '95. I don't know how you are thinking, but it was the way you asked the question.

  • The question I asked, and I will repeat it: "In what year were you first involved in active fighting with the RUF?" Now can you please deal with what you understand me to mean by that?

  • Mr Koumjian, you are on your feet.

  • Vague, "involved in active fighting". I am not sure what inactive fighting is and I am not sure what "involved" means. If the question could be put much more - I think the witness has indicated he would like it put more precisely.

  • To me active fighting is something you are actually doing. Mr Witness, do you understand the question?

  • I don't know if my learned friend needs me to explain it any further.

  • The witness understood the question. There is no need for a further exchange. Please answer the question.

  • I started fighting in 1995 at the battle front.

  • Firing guns, you just told us, yes?

  • Yes, I fired gun. Yes.

  • So why did you tell the Prosecution when they were interviewing you that you didn't take part in any active fighting between 1991 and 1997?

  • Like I said earlier, I said active fighting and firing guns at the front line did not mean that you have been taking part in active fighting. I started --

  • Your Honours, could the witness still slow down his pace and repeat from where I stopped.

  • Again, Mr Witness, you are speeding up. You are going too fast. Speak more slowly, stop after each sentence. Pick up where you said, "I started" and continue from there, please.

  • My boss, the man with whom I was at that time, he used to take me to the front lines since '95. He will tell me how to shoot and how to get used to the sound of the gun. But on my own at the time I started going on the front line when they chose me to take my own manpower to the front line was in '97. That was on my own without my boss.

  • Are you just trying to wriggle out because you've committed yourself to active fighting in 1995 and you have now been confronted with my suggestion that you told the Prosecution that you weren't involved in any active fighting between '91 and '97?

  • I believe with understanding you cannot just get up and do something at the same time. You cannot just get up and become a lawyer. You will go to school first and you go for your practical before you become a lawyer, so I want you to put it like in your own case, please.

  • Tab 8, please. I don't want Madam Court Officer to show the front page of this tab. I will simply establish the date. It's an interview conducted on 22 November 2006 with this witness, attorney present Alain Verner, investigator Brian Hutchison and interpreter Mariama Bockarie. Of course --

  • Mariama Bockarie, please.

  • I am going from what is written on the printed page. Mr Witness, at the end of 2006 you were doing your computer courses then, weren't you, 90 per cent in English?

  • Yes, I can remember. Yes.

  • Now again I am going to refer the witness only and not the public to the last page, which is page 25916, and your Honours will see from your own copies why I am not having that page put on the screen. It is just one line at the top of that page:

  • Do you agree that in that interview you told the Prosecutors, lawyer, investigator, and you had the benefit of an interpreter, that you did not take part in any active fighting from 1991 to 1997?

  • I don't understand that question.

  • Have a look at the page. Have a look at the one line under the words "Interview notes". I don't want you to read it out, but read it to yourself, please. Have you read it to yourself?

  • Yes.

  • Have the Prosecution correctly recorded you telling them that you didn't take part in any active fighting from '91 to '97, or have they got that wrong?

  • The way they asked me the question at that time they got me right. It was because of the way they asked me the question.

  • So you claim to remember the specific question you were asked on 22 November 2006 that led to that answer being recorded? Is that what you are telling these judges?

  • Can I make it clear, Madam President, and indeed to the witness, that I am now dealing with a whole series of what I will call miscellaneous subjects. They don't necessarily follow in chronological order, but they are subject areas that the witness has dealt with in evidence:

  • When did you first start to work for Benjamin Yeaten?

  • I can't remember the time.

  • What part of the year?

  • I think it was late '99.

  • Tab 2, please. This is an interview between you and the Prosecution on 3 December 2005. If you have a look at paragraph 2, is this right, that they confirmed the information you had given them in the first interview before they went on to ask you further questions?

  • No, it is not true, because like I told you earlier in 2000 and --

  • Your Honours, the year pronounced by the witness was not clear to the interpreter.

  • Mr Witness, the interpreters have not heard the year that you mentioned. Please make sure you speak into the microphone. I noticed you turned round. Repeat the year, please.

  • 3 December 2005 I did not have any confidence in the Special Court for me to give them correct information.

  • Nevertheless you accepted 100 US dollars for giving it, didn't you?

  • Yes.

  • Now back to the question. Is it right that in that interview they confirmed with you what you had told them in the first interview? In other words, they went over the content of the first interview with you in this second interview.

  • Mr Witness, did you hear the question?

  • I heard the question, but I thought he had not yet finished. They did not go over what they interviewed me during the first time and the second time. I can't recall them going over it.

  • Are you saying they didn't do it, or are you saying you've now forgotten whether or not they did it?

  • They did not read back anything to me for the first and second times. I don't remember that they read anything to me.

  • Well, I just want to be absolutely clear on this. Are you saying that you simply can't remember now, or are you saying they definitely didn't go over the first interview with you at the beginning of the second interview?

  • They did not go over any interview with me.

  • Right. So that first sentence there is false, is it?

  • Except if you can confirm it, but I don't think they read back anything to me. They did not read back anything to me.

  • Carry on. "The interview was directed at your knowledge of interaction between members of the RUF command structure and Charles Taylor".

  • Your Honour, can counsel kindly repeat the question, please.

  • "The interview was directed at your knowledge of the interaction between members of the RUF command structure and Charles Taylor". Did they ask you to tell them what was the - I am trying to think of another word for interaction - what was the connection between members of the RUF high command and Charles Taylor?

  • Yes, they asked me that question. I can remember, yes.

  • And they told you they wanted to know about all the connections that you could tell them between Charles Taylor and the RUF high command, yes?

  • The ones that I remember, they asked me whether the ones I can remember if I can help them with. I said yes.

  • So did they tell you they wanted to know about all connections that you could tell them about between Charles Taylor and the RUF high command?

  • Yes, they told me that I should tell them the ones that I can remember between the RUF and the Liberian government under President Charles Ghankay Taylor, yes.

  • Carry on. Where it says "the source" that means you. This is the fourth line down in paragraph 2. You stated that you had become a bodyguard to Benjamin Yeaten in 1998. Did you tell them that?

  • I think all the other statements were correct, but that one was a mistake from them, but I think I recall that I had corrected that particular area before.

  • Did you tell them in the interview on 3 December 2005 that you'd become a bodyguard to Benjamin Yeaten in 1998?

  • No, it was a mistake from their side, because when I came over to Sierra Leone they were reading out statements to me. I said, "No, 1998 was the first time I crossed over into Liberia and I returned". I think if you check all the other documents you will find out that that is what is there.

  • The Prosecution have been through all of your interview notes with you, haven't they?

  • Yes.

  • And you have made numerous corrections to what is recorded in many of those interviews, haven't you?

  • And are you saying all of those mistakes were mistakes by those who were writing down what you said?

  • Yes. If I am liable to make mistakes why do you think they too cannot make mistakes? Yes.

  • Tab 3, please, and again unless I invite Madam Court Officer to put it on the screen I am working on the basis that the witness himself will simply look at the document. This is the next recorded interview on 21 February 2006. This is the one you say was at the National Security Agency's headquarters. Now I don't want you to mention any names here, but I'd like you to look, please, at paragraph number 2 and does it say there that the investigators had previously interviewed you in November and December under one name, that I am not mentioning, and you were later arrested by the National Security Agency under a different name, but again a false name? Is that what is recorded there?

  • I don't remember. I don't even understand the question. Could you please ask the question again.

  • Recorded there is the fact that the investigators had interviewed you twice before under a name that you have already told us was a false name that you gave them, yes?

  • Yes, yes.

  • It goes on to say that you were later arrested by the National Security Agency under a different name which also is a false name, isn't it?

  • Excuse me, your Honours.

  • I just have one security concern. The issue of the agency that has just been mentioned was covered initially in my opening private session just with the witness's name just as something that could possibly identify the witness, so we had previously covered that, as far as I can recall, only in private sessions and I am a little concerned that that could identify him.

  • Mr Koumjian, I just don't see how that can happen. There is an agency been mentioned and all it says is that he was at an office. It doesn't say in what capacity, et cetera, that he was at it. I am afraid it doesn't follow and I think that agency has been named in open session too, although I would need to check the record.

  • We haven't said when he was arrested, we haven't said any reason, we haven't said whether or not he is the only person they ever had under arrest, et cetera.

  • I have ruled against the objection, Mr Munyard.

  • I am sorry, Madam President. Right. I will carry on:

  • Recorded there is that you were arrested by the National Security Agency under, that's to say you gave them, a different false name. Is that correct?

  • When they arrested me I gave them my real name because they arrested me under my real name, because when they arrested me they asked me for my real name. Maybe they got to know that when I was arrested I was arrested under a false name.

  • So have the investigators correctly recorded that when you were arrested by the National Security Agency you gave them a false name?

  • I gave them my real name.

  • [Overlapping speakers] Mr Munyard.

  • Paragraph 5, please. In this paragraph it says that the investigator told you that he wanted you to clarify certain statements that you had made during the two previous interviews. Did the investigator take you back over the two previous interviews in this third one?

  • The first one at where? At NSA? At NSA they wanted to read it to me. They started reading it out to me, but I said no.

  • You said no to what?

  • That they shouldn't read anything out to me, because I did not think that that place was the ideal place for them to read out anything to me.

  • I will be corrected if I am putting anything to you that is wrong, but there is no indication in any of these notes that they tried to read out previous interview notes to you and you stopped them. Are you seriously saying that they tried to read out the previous notes and you stopped them?

  • Yes.

  • And you have a clear recollection of that now two and a half years later?

  • You have a clear recollection of that now two and a half years and 23 different interviews later?

  • I believe the witness asked for clarification of recollection of what exactly.

  • Of stopping them reading out the previous interviews so that you could clarify what you had previously told them?

  • Yes, I can remember saying no and my no was too harsh at that time. I said no, I was not there for that, I was there for a different purpose. I was not there for that.

  • What purpose were you there for?

  • Unlawful arrest. I was just there for unlawful arrest.

  • Did you raise that with the Prosecutors?

  • You told us yesterday that you didn't?

  • That misstates the evidence.

  • Because he did not --

  • Pause, Mr Witness. Mr Munyard, Mr Koumjian has objected. He said you are misstating the evidence. Can you refer us to --

  • Madam President, I think I am likely to go over the lunch adjournment. I will check the transcript from yesterday.

  • Very well. We will defer that point and go to the next point.

  • Your Honour, if I have I will quite happily back down. If I haven't I will pursue the point.

  • Thank you, your Honour. I will also try and check but I am not sure it was yesterday. My recollection was it was earlier. It will also check Monday's as well.

  • Very well. And maybe Friday's too at this point.

  • We will defer this point.

  • Very well. I will move on:

  • You say you wouldn't let them clarify your previous statements or the contents of your previous interviews. The second sentence in paragraph 5 reads as follows: "He confirmed that he had entered Liberia in late 1999/early 2000 crossing the Sierra Leone Liberian border at Foya." Did you tell them that?

  • At the time I was going to base in Liberia I told them, yes. I told them that one according to the question that they asked me.

  • So is it right that you didn't enter Liberia until late 1999/early 2000?

  • So have they recorded that wrongly, or is that something that you - hang on.

  • I think this is recorded rightly.

  • So you told them that, is that what you're saying?

  • It may be that it was recorded rightly according to the question that they asked me, but in the other way round the way you are asking me it could appear wrong.

  • Did you tell them that you didn't enter Liberia until late '99/early 2000?

  • I did not tell them that.

  • So they have got that wrong?

  • They may get it wrong, or right, depending on the type of question I was asked and the type of question you are asking me right now.

  • Did you tell them that you had crossed into Liberia at Foya?

  • What year did you first meet Jungle?

  • Around Pendembu, Kailahun District in Sierra Leone.

  • What was he doing there when you met him?

  • He was bringing ammunition, but the vehicle broke down. The car was giving him some trouble.

  • Did you first meet him in 1998?

  • I met him in '97 during the AFRC regime.

  • Tab 9, please, and I am going to ask you to look please at page 26459.

  • Your Honour, can counsel kindly switch on his mic.

  • I am sorry:

  • This is an interview that took place on 24 November 2006 and I am going to ask you to turn to page 26459 first of all.

  • I am not sure the witness got the interpretation of the tab number.

  • It's tab 9, please. These particular documents don't bear the witness's identification. Do you see on page 26459 there are a series of bullet points? Do you see those, Mr Witness; little dashes in the left-hand margin?

  • Yes.

  • I am going to ask you to go to the last one, please, and it reads as follows:

    "That a few months after ECOMOG pushed the RUF out of Freetown Superman told the witness that the arms they were receiving, which the witness observed (RPG rockets, AK rounds and GMG rounds) were sent by Charles Taylor and that it was a person by the name of Jungle (who was a senior Taylor bodyguard) that transported the arms and ammunition to Buedu, Sierra Leone by road from Liberia."

    Do you see that? Did you tell the Prosecutors that?

  • Yes.

  • Carrying on 26460: "That the witness was best friends with Jungle during 1998-1999". Did you tell them that?

  • No? So what is it that they have got wrong with that?

  • Right. You tell us what you told them then.

  • After I had met him in '97 in Pendembu in '98 I saw him in Gbarnga at the President's farm.

  • I am going to stop you. I am going to stop you because I don't think you're answering the question, you're telling us the story. What I asked you was what did you tell the Prosecution, not what actually happened. Did you understand that that was the question I was asking you?

  • Yes, but the question you are asking me, what I told them is what I'm telling you. I told them that in '97 I met Jungle in Pendembu, in '98 I met him in Gbarnga at the farm and I knew him from '97, '98, '99.

  • So you told them all of that in this interview on 24 November 2006?

  • Your Honour, can counsel kindly --

  • I did not tell them in one go. At any time they asked me about Jungle, sometimes they asked me, "How come you knew him" and I would tell them.

  • Have you listened to the question? I am asking you what you told them on 24 November 2006 about your connection with Jungle and whether they have correctly recorded what you told them on that date. Do you understand that's what I am asking you about, not what you told them over a period of time or what actually happened?

  • I can remember telling them on this particular date that you are talking about during this interview. I can remember a few things. They asked me whether I knew Jungle, I said yes. Where? At what time? I said '98 I met Jungle on the farm, but before that I had told them about '97 before I told them about '98.

  • So they have failed to record that you met Jungle in 1997 in their notes of this interview, have they?

  • I think it could be in other papers because they have a lot of documents that they took from me. I don't know if they gave you all of them.

  • That is not the answer to the question, Mr Witness. Is something that you said about Jungle not in this record of interview?

  • Your Honour, something that he said on that day. He doesn't seem to have got that point.

  • It is this particular interview, this particular record of interview on this particular day, and that particular day was 24 November 2006. I would add, Mr Witness, I'm finding your answers confusing, because when you were first asked you said the words - when you were first asked what was wrong you said the words "best friend" and you never clarified that point.

  • Yes, what I said about best friend for the first time, they said '98 and '99 I became best friends to him. I said no, that word is not correct.

  • Did you tell them that or not?

  • So they have slipped in the word "best" next to "friend", have they?

  • Maybe. It may be a mistake. I don't know if it's a slip or a mistake. I don't know.

  • The next bullet point on page 26460, you told them that Jungle told you that during 1997 he used to bring arms and ammunition to Sierra Leone from Liberia and that he would turn the arms and ammunition over to Sam Bockarie in Buedu. Did you tell them that?

  • So why didn't you say to the Prosecutors, "And actually on one of those occasions in 1997 I actually met Jungle for the first time"?

  • I told them that in 1997 I met Jungle. I told them that.

  • On this particular date in the course of this interview?

  • I don't remember any longer, but I remember they asked me at what time that you started seeing Jungle for the first time and I told them. I don't remember if it was on this particular interview.

  • But why didn't you tell them when you were giving them the information that Jungle had given you about his activities in 1997? If you had really met him in 1997 on one of his arms trips why didn't you tell them that in this interview?

  • Because they did not ask me during the interview at what time you met Jungle.

  • Did they ask you what Jungle told you about, or is that something you simply - is that simply information that you gave them?

  • They asked me whether I knew Jungle and I said yes, whether I knew about any arms transaction between Jungle and Sam Bockarie during so and so period and I said yes. "When you were in Liberia did you talk to Jungle", and I said yes. "Did Jungle become your best friend", and I said he was my commander at the time, my best friend. That was what I used to tell you about the transaction between --

  • Mr Witness, do you think you could slow down? You might not need to breathe, but the interpreter needs to breathe between sentences. Please slow down.

  • You are saying that they asked you, "Did Jungle become your best friend"? Is that the truth?

  • Yes, they asked me before whether Jungle was my friend and I said, "Yes, my best friend".

  • No, what you just said, and I am reading from the transcript: "'Did Jungle become your best friend?' I said he was my commander at the time, my best friend". It's complete rubbish to suggest they asked you if Jungle became your best friend, isn't it?

  • That's not so. I don't think I am saying rubbish here. I am saying something serious, something serious. I can't talk rubbish.

  • Let us move on, please, to page 25941 in the same tab. It's the handwritten notes that were taken during the course of this particular interview and I am going to ask you about the second half of this page. The handwriting is not the easiest to read and so I am going to read it out, but if you have any difficulty following, please let me know.

    About in the middle of the page the following words appear, "Mosquito instructed them to go to Gbarnga" then there are some names and then three lines below that, "To escort ammunition and arms back to Sierra Leone". Now do you remember telling the Prosecution about that in the course of this interview on 24 November 2006?

  • Yes.

  • I am going to miss out some of the lines. I am just trying to get a time frame for this. The next paragraph or bullet point, "They took chopper from Foya to Gbarnga". Do you see that? Did you tell them that?

  • Read the question, please. I do not understand.

  • "They took chopper from Foya to Gbarnga". Do you know - I'm sure you know what we mean by chopper.

  • Yes. Did you tell them that?

  • Yes, I said we boarded the helicopter from Foya to Gbarnga, yes.

  • What year was this?

  • Next bullet point: "Landed in a field of President Taylor's farm. Spent the night in Gbarnga. Eddie Kanneh went to Monrovia". Did you tell them all of that?

  • Yes.

  • Below that: "Ben Yeaten was there, first time witness met him". Did you tell them that?

  • Over the page: "Jungle, Sampson Yai" and then in brackets "Weah". did you tell them that?

  • Next line: "They were introduced to them here". Well, the "them" obviously refers to Jungle and Sampson Weah, doesn't it?

  • Yes, Benjamin Yeaten also.

  • So you were introduced to Jungle for the first time in 1998, weren't you?

  • They did not introduce me. Yes, they introduced me to Jungle and Jungle was introduced to me in 1998, yes.

  • You didn't need an introduction because you'd already met him on your account in 1997, yes?

  • Yes, I met him in 1997, but it was not official, so when I met him officially they needed to introduce him to me.

  • That's your explanation for this, is it?

  • Yes, 1997 I met him, but it was not official. I met him on the highway. They told me to go and meet him on the highway. The day I met him it was official. His boss was there and my own boss was there so they did the introduction.

  • What to you mean by it wasn't official when you met him in 1997?

  • Nobody was there for him to be introduced to me as, "This is Jungle". He himself told me he was Jungle but it was not officially as it was done in Gbarnga on the farm.

  • How long did you spend with him in Pendembu area in 1997?

  • We just went and collected something from him and all of us drove to Kenema.

  • Who was at Kenema?

  • Sam Bockarie, Mosquito.

  • And did Sam Bockarie have any need to introduce you officially to Jungle when you all arrived at Kenema, or was it obvious to Sam Bockarie that you'd already been introduced?

  • It was so urgent - he was so urgent --

  • Your Honours, can he kindly repeat slowly.

  • Mr Witness, the interpreter needs you to repeat your answer. Speak much more slowly and repeat from where you said, "He was so urgent". Pick up from there, please.

  • No introduction was done because at the time Mosquito was so urgent and he was trying to say that we should bring the ammunition quickly to Freetown. There was no official introduction there.

  • What's involved in an official introduction? Do you get a certificate?

  • No, they do not give certificate.

  • Tell us what's involved in an official as opposed to an unofficial introduction.

  • Like when I entered here I said, oh, hello, I am so and so person. That's not official. But if I enter here through the Prosecution, the Prosecution introduced me that this is so and so person I think that's official. That is what I mean.

  • I am moving on to a different subject now:

  • There was considerable infighting within the RUF itself and between the RUF and the AFRC from the time that they joined together as a junta. Now I am going to break that down into two questions. Do you agree that there was infighting within the RUF itself from an early stage?

  • Tab 8, please, and for the avoidance of any concern I am not going to ask for the pages to be put on the screen. Page 25913, please. Now again there is a number of bullet points on this page and I am going to deal with a number of the bullet points on page 25913 and since we are on this page I am dealing with more than one topic. Do you see the second bullet point that starts with the sentence, "There was always infighting between the Sierra Leoneans and the Liberians"?

  • Yes.

  • This is an interview on 22 November 2006, two days before the last one that we were looking at, and again you had the assistance of an interpreter in addition to Alain Werner and Brian Hutchison. Did you tell the Prosecution that, that there was always infighting between the Sierra Leoneans and the Liberians because of repeated atrocities committed by the Liberians on the civilian population of Sierra Leone?

  • Yes, there was infighting. Yes.

  • And did you tell them that this infighting came to a head during '92 to '93 during operations Top 20 and Top 40 where a vast number of Liberians were driven back to Liberia by the Sierra Leoneans?

  • In fact those operations took place in 1992, didn't they?

  • I do not understand whether you are asking me a question.

  • I am asking you do you agree that those operations took place in 1992.

  • I can recall '92. I can recall '92, yes.

  • Next bullet point. Did you tell the Prosecution there was support from Charles Taylor in '91 to '92 because there were NPFL commanders and fighters fighting in Sierra Leone with the RUF at that time?

  • Yes.

  • But there was no support from Taylor during '93 to '94. Did you tell them that?

  • In fact, there was no support at all from Charles Taylor during the whole of the time that ULIMO had cut off the Sierra Leone - or had control of the Sierra Leone Liberian border, was there?

  • I was not aware at that time. I was not aware of any support.

  • Thank you. And indeed the fifth bullet point down, if you would have a look at that, please, do you see: "In 1993 ULIMO took control of the Sierra Leone-Liberia border and so all supply lines were cut off". Did you tell them that?

  • And the seventh bullet point down, did you tell them that you had no knowledge of any communication between Sankoh and Taylor after ULIMO took the border and so all supply lines were cut off?

  • Over the page, please, 25914. The first bullet point, did you tell them that CO Monica was a Liberian commander with the RUF, but you don't know her full name?

  • I have not seen the page you are talking about.

  • 25914. It should be on the back - well, it is either on the back or on the next page.

  • Thank you. Did you tell them that CO Monica was a Liberian commander with the RUF and you didn't know her full name?

  • Has somebody told you her full name since 22 November 2006?

  • Yes, somebody from the investigation. He was saying Monica, Monica, CO Monica, and they called the name, they said Monica Pearson and I recalled it was Monica Pearson, yes.

  • So one of the investigators for the Prosecution helped you with her last name, did they?

  • Yes, they proposed whether it was Monica Pearson that I was talking about and I said yes. They proposed, yes.

  • And so that's how you were able to give her full name when you gave evidence about this matter, is that right?

  • Yes, I said CO Monica and I think from the way I described her and the things she was doing the person was able to recall that from other background investigation that he was doing, that he thinks he was talking about this and they described her and they said Monica Pearson.

  • Right. What was the background that they were able to tell you about? Her background, I mean.

  • They did not tell me anything about her background, but I knew that they talked to other people who knew Monica Pearson's last name and I recall that it was Monica Pearson. I recalled the last name. I told them the first time that I cannot remember the last name, but after they called the last name, they said Monica Pearson and I said yes.

  • What else did they tell you about Monica Pearson?

  • Just Pearson name. Just the question, "Monica Pearson you are talking about?" I said, "Oh, yes, yes, yes". I appreciated it too much, yes.

  • And you didn't like her because she was aggressive and a very demanding commander, is that right?

  • Yes, she was too aggressive to us. I didn't like her.

  • She was violent to the people under her command, wasn't she?

  • Yes, when I was training under her command she was not treating us fairly at all.

  • And she either beat people or had people beaten up, didn't she?

  • She had people beaten very violently indeed, didn't she?

  • Yes, she beat people.

  • What did you see her do?

  • She did a lot of things. She trained people, she passed instructions to --

  • Your Honours, can he repeat. I don't know if he mentioned a name. It was not very clear.

  • Mr Witness, the interpreter is not hearing you clearly. Please pick up your answer where you say, "She passed instructions to" and then continue, please.

  • To go and fetch water for the other commanders. She did a lot of things.

  • Yes. When you said she beat people, did you see her beating people?

  • Yes, so many times. Yes.

  • Did she ever beat people to death?

  • I can remember they beat one SBU at the base. They took him away and I did not see him any more and they did not tell us anything about him, about his health or what. Everybody got concerned that he is dead.

  • And did you never seen him again? Give us other examples of the beatings that you saw Monica Pearson carrying out?

  • She beat people with rubber. Sometimes they say the people go free engine. She beat people mercilessly on the base. She beat people and they said they go off, or goes free engine. That's the term they used to use.

  • You will have to help me with "free engine". What do you mean by "go free engine"?

  • Sometimes when they beat you, you just lay down there without breathing for some time. You become unconscious.

  • Did you ever see her commit or order sexual violence on anyone?

  • I did not see her commit sexual violence on anybody.

  • Did you ever either hear her order any sexual violence to be committed or hear of anyone who was sexually assaulted on Monica Pearson's instructions?

  • I did not hear that.

  • Back to page 25914, please. I want you to go, if you would just count with your finger the number of bullet points in the left-hand margin and if you count down to the ninth one - do you see - can you count down nine bullet points and do you see a sentence that starts, "That after the creation of battalion system"? Do you see that?

  • And does it read as follows: "That after the creation of battalion system in the RUF in 1994, Sam Bockarie and Superman did not get along and this misunderstanding lasted until 1999". Did you tell them that?

  • I am coming, please. Let me read for myself. I think they have a small problem there. I told them something similar to that, but they did not write it correctly.

  • When they read it back to you, did you not correct what they had written?

  • I think I corrected that area. I think if you check the other documents.

  • I have and as far as I can see in none of the 24 sets of interview notes plus one extra document have I seen any correction of that.

  • Okay.

  • What is right about what is recorded there and what is wrong about it?

  • Okay, before the forming of the battalion in 1994 Superman, Sam Bockarie were having some conflict over weapons.

  • Your Honours, can he kindly repeat the name of the pistol. It was very fast.

  • Far too quick, Mr Witness. The interpreters can't keep up with you. Please repeat the name of the pistol that you mentioned.

  • Perhaps if he just starts over, because I think we all got a little lost there.

  • Yes. Repeat your answer from where you said, "Superman, Sam Bockarie were having some conflict over weapons". Continue from there. We will start it from the beginning. "Okay, before the forming of the battalion in 1994 Superman, Sam Bockarie were having some conflict over weapons". Continue your answer from there.

  • Yes, before the formation of the battalion in 1994 Superman and Sam Bockarie were having a conflict over a weapon, two pistol grips, they call it AO, two handles, it had two handles. The conflict was not - was not amended until the departure of the battalions in '95.

  • Right. So is it your case that Sam Bockarie and Superman did not get along for whatever reason and their misunderstanding lasted until 1999, presumably when Sam Bockarie left and went to Liberia? Is that your position?

  • No.

  • What are you saying, Mr Witness, about this misunderstanding between Bockarie and Superman? How long did it last?

  • They had the misunderstanding between them and they were still operating together, but each time they had a conflict they will bring that particular thing out. Superman will talk about that particular thing. So I knew that they had grudge for each other, but they were operating together. Yes, Superman was taking direct instructions from Sam Bockarie, so they were still operating together.

  • Superman had no choice but to take direct instructions from Sam Bockarie, did he?

  • Thank you. And indeed you say that this grudge between them lasted the entire time, is that right, until Sam Bockarie left and went to Liberia in exile?

  • Thank you. Now is it right that in the RUF for a long time there was no rank structure?

  • Individual ranks, yes, but they had positions.

  • Is it right that there were no individual ranks until some time around 1994?

  • Yes, yes. Individual ranks, they had individual ranks, but individually command structure.

  • What I mean is there is no colonels and majors and the rest of it until about 1994?

  • Your Honour, can he kindly repeat his answer again.

  • First of all, Mr Witness, the interpreter cannot hear you and the question is - well, you answered no when you were asked there was no colonels. I would like that clarified also, so repeat your answer in full, please.

  • He was asking me - I said no, they had colonels in the RUF at the time before 1994.

  • Right. When did they have colonels and other ranks?

  • 1994 before they constructed the formation of the battalions they had lieutenant colonels, Zino Mohamed Tarawalli.

  • When did that rank structure begin?

  • They had ranks second in command after the death of Rashid, one Rashid Mansaray, I think so.

  • When did that begin?

  • I can't remember really.

  • Well, was it in 1991?

  • I don't think so. I can't remember exactly.

  • I can't remember.

  • I can't remember.

  • So is this the best you can do: That by '94 you think they did have these ranks, but you can't say when they started to have a rank structure?

  • Yes, by '94 I can remember that CO Mohamed - when CO Mohamed came and went to Zogoda he was lieutenant colonel then. They used to call him lieutenant colonel.

  • Mr Munyard, Mr Witness, it's 1.30, so if it's appropriate to adjourn now we will take the lunchtime break. Please adjourn court until 2.30.

  • [Lunch break taken at 1.30 p.m.]

  • [Upon resuming at 2.30 p.m.]

  • Mr Munyard, please proceed.

  • Thank you, Madam President:

  • Mr Witness, since we were dealing with the question of ranks just before we broke for lunch, I'd like you, please, to turn to tab 15. This is an interview conducted on 17 and 18 October 2007, investigator Mustapha Koroma and also present was Shyamala Alagendra, the lawyer. Now do you remember that particular interview over those two days now, or not?

  • I can remember that Mustapha and Shyamala interviewed me, yes.

  • This is interviews number 16 and 17 and they started off, as you can see - they started off by going through some of your previous statements with you, yes? Do you agree?

  • Yes.