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

  • Yes, ma'am.

  • Please proceed, Mr Werner.

  • Thank you, Madam President.

  • Good morning, Mr Witness.

  • Your Honours, could the witness speak up a little.

  • Mr Witness, if you could sit a little closer to the microphone and speak a little louder so the interpreters can hear you. Thank you. Proceed.

  • Mr Witness, yesterday you told us that you were abducted in 1991 and you were trained in Pendembu and then you were sent to work with Morris Kallon, who was an RUF vanguard. Now, how long did you stay with the RUF?

  • Well, I was with the RUF right until the final disarmament in 2001.

  • And yesterday you told us that you were acting as adjutant in Bunumbu for Morris Kallon in target C. For how long were you involved in administrative affairs within the RUF?

  • I was involved in that activity for almost throughout the exercise.

  • And when you say "throughout the exercise", what do you mean?

  • Right up to the final disarmament until there was peace.

  • And when was that again?

  • 2001.

  • Now yesterday I asked you some questions about the civilians who were captured with you and sent to the training base in Pendembu, do you remember?

  • And I'm referring to the transcript of yesterday, page 10869 to 10870. So you said that:

    "Well, yes, at that time we were up to about a hundred or so people who were sent. We were mixed. The young ones, the small boys, women, men, the youths, adults. We were many up to about a hundred or so, those of us who were captured and sent."

    Then later I asked you, "And the ones who were about nine years, what were their genders, Mr Witness?", and you said, "There were males who were nine years and there were females who were about 11 to 12 years, but they too were young anyway." What happened to these young girls who were about 11 to 12 years after the training, Mr Witness?

  • Well after we had graduated, those girls some senior officers took them so that they would be together at their houses to take care of them.

  • And what kind of training did they undertake?

  • Well, they too underwent the same basic training that we underwent.

  • Mr Witness - excuse me, Mr Werner, when the witness says "to take care of them", who is taking care of who?

  • I was going to clarify that. Thank you, your Honour:

  • Mr Witness, you said that some senior officers took them and they would be together at their houses to take care of them. Could you clarify that?

  • What I meant by senior officers, those who were above us who trained us and those us whom we met at the front lines under whose commands we were, they would go at the base. When there was graduation, they would go and request for those small boys and girls to be with them so that they will take care of their wives at home. They would be doing domestic chores.

  • And just to be completely clear, when you say "to be with them", to be with whom?

  • The senior officers.

  • Now, you told us yesterday about the kind of training that you received in Pendembu. Now who, if anyone, was the ideology instructor in Pendembu training base?

  • Well, just as I said yesterday, like the Pendembu training base at the initial stage I cannot recall the ideology training instructor's name. There were many instructors at the base, but just as I said some names were too queer for us to recall now.

  • But were there ideology training instructors?

  • At that initial stage I did not hear about ideology business at that base. It was just basic training that we underwent.

  • Now, you told us yesterday about the SBUs and you explained that SBUs meant Small Boys Unit. Now after the training in Pendembu, where did they go?

  • Some of them went with us to the front lines, the SBUs, and - yes, some of them joined us to the front line. Some of them, as I said, the senior officers took them to their houses where they resided.

  • And to your knowledge for how long did the RUF have SBUs unit?

  • Right up to the time for the final peace there was SBU in existence.

  • And when you say "some of them went with us to the front line", when you were sent to target C in Bunumbu did you see any SBUs?

  • Now, you told us that at the time of your training in Bunumbu you knew that Foday Sankoh was the leader of the RUF. Do you remember that?

  • At that time to your knowledge who, if anyone, was the deputy of Foday Sankoh?

  • Well at that time it was one CO Mohamed, who was called Mohamed Tarawalli. He was the one we knew to be Foday Sankoh's deputy.

  • Your Honour, I believe that Tarawalli was already spelt for this Court:

  • Now, do you know if Mohamed Tarawalli was known by any nickname?

  • And what was his nickname?

  • Well, we heard him being called Zino.

  • Again, I believe that was already spelt:

  • Now, yesterday you explained what happened to the ones who tried to escape from the Pendembu training base and you spoke about something that you referred to as tabae. Do you remember that?

  • Yes, sir.

  • How would you spell tabae?

  • Well, I think tabae was just a slang. It could be T-A-B-A-E or T-A-B-Y. I don't think there is any standard spelling for that.

  • Now, Mr Witness, at the time you were in Bunumbu with Morris Kallon - and I will be referring again to the transcript of yesterday, page 10893. You said yesterday that when you were with Morris Kallon, at target C in Bunumbu, you received a letter and it was a directive coming from Foday Sankoh and I asked you, Mr Witness, to your knowledge what did directive mean and your answer:

    "Well, what I understood from that letter was that directive was a very strong command or order that came from the high command that you shall go by."

    Now, what did you mean when you said that?

  • Well, just as I said yesterday, it was later that I knew the meaning of a directive in the military terms: That it was a word that could only be used by the high command and when that word is used it should be treated as an urgent issue and you must respond to it. Whatever instruction is given to you, if the expression "directive" is used you must leave everything you are doing and go by it.

  • And when you said that it came from the high command, what did you mean by high command?

  • Like Foday Sankoh, who was the leader of the revolution. Later I came to know that he was the only one who should use expressions like those.

  • And why was he the only one who could send a directive?

  • According to my understanding, because he was the overall leader in the revolution, so he was the only one that had the right to - the authority to use that expression.

  • Madam President, I recognise I will have the opportunity to examine the witness, but there might be a distinction. When the witness uses the phrase "that expression" he might be referring to high command, vis-a-vis Foday Sankoh, versus Foday Sankoh being the only person who could issue a directive. I mean it's up to counsel how he wishes to examine, but counsel --

  • I'm not entirely clear what you're saying, Mr Anyah.

  • I can read the relevant portion of the transcript, Madam President. The question posed by counsel - and on my screen it's at page 7, starting at line 8 - was:

    "Q. And when you said that it came from the high command,

    what did you mean by high command?

    A. Like Foday Sankoh, who was the leader of the

    revolution. Later I came to know that he was the only one

    who should use expressions like those."

    Then comes the next question:

    "Q. And why was he the only one who could use - could send

    a directive?

    A. According to my understanding, because he was the

    overall leader in the revolution, so he was the only one

    that had the right to - the authority to use that

    expression."

    My understanding of the witness's evidence is that the expression to which he's referring is this characterisation of high command, as Foday Sankoh being the only person to which that expression is associated, versus Foday Sankoh being the only person who can issue a directive. It's not an objection, I just seek clarification and it's up to - I'm in the Court's hands, basically.

  • I will leave it to counsel to clarify.

  • I'm happy to clarify one thing, coming back to the transcript:

  • So, Mr Witness, when you say, "According to my understanding, he was the overall leader in the revolution, so he was the only one who had the right - the authority to use that expression", what did you refer to when you said "the only one who had the right" to use that expression?

  • Just as I said, he was the leader of the revolution. There were other commanders, but they all fell under his command. There were other senior officers, like his deputy CO Mohamed. If Foday Sankoh was around in the revolution, CO Mohamed would not use a directive. If Foday Sankoh was present he was the only one to use it. That's what I meant.

  • I think on the transcript he said - the words "Mohamed Tarawalli" were not transcribed. Mr Witness, you said, "If Foday Sankoh was around in the revolution, CO Mohamed would not use a directive." Who would not use a directive if Foday Sankoh was around?

  • So to your knowledge what would CO Mohamed use if he could not use directives when Foday Sankoh was around?

  • Well, to my knowledge from what I came to know later he would use instructions or order.

  • Thank you, Mr Witness. Now, yesterday you explained that you went with Morris Kallon to Pendembu to see Foday Sankoh. Do you remember that?

  • And then you said that they were referring to a place called the Mansion Ground. Do you remember that?

  • Who was referring to that place as the Mansion Ground?

  • Like he, Morris Kallon himself. When we were going he told us that we were going to meet Foday Sankoh at the mansion where he was based as the leader of the revolution. He said the place was referred to as Mansion Ground.

  • To your knowledge, why was that place referred to as the Mansion Ground?

  • Well, I think it was because the leader of the revolution, Foday Sankoh, was based there. It was a secure place for him, according to my understanding.

  • To your knowledge, who, if anyone, was assigned to the security of the Mansion Ground?

  • Well, we had some of our fellow junior commandos and some other Liberian vanguards who were referred to as Executive Mansion Guards, the EMG. That was how they were being called. That was the security people who were there to guard the Mansion Ground.

  • To your knowledge, how long were they called Executive Mansion Guards?

  • Well, from the beginning they used to call them Executive Mansion Guards, right up to the time the Sierra Leone government pushed us to the border between 1992/1993. When we went to the border between Sierra Leone and Liberia, that was the time those names were dissolved and it was changed to other names, because at that time we took up to other jungles, new jungles.

  • And at that time, to your knowledge, what was the other name used?

  • From that time they started calling them the Black Guards.

  • And who started to call them the Black Guards?

  • He, Foday Sankoh himself. He changed the name from Executive Mansion Guards to Black Guards.

  • Just to be completely clear then, who were the Black Guards then at that time?

  • The securities who were guarding him, Foday Sankoh.

  • Thank you. Now, what happened when you went to Pendembu with Morris Kallon?

  • Well, just as I said, it was Foday Sankoh who called him for briefing and so we went there to him at the Mansion Ground, to him Foday Sankoh, but I stayed outside because we were not allowed to enter. I was outside and he entered to Foday Sankoh and he was briefed and he came back and we returned to Bunumbu Town, target C.

  • Mr Witness, to your knowledge, at that time when you went to Pendembu how did Foday Sankoh move around at that time?

  • Well, when we went to Pendembu, when we arrived at the Mansion Ground gate there was the guard post where the Executive Mansion Guards were. When we got there they took our arms from us and they told me to wait and CO Morris Kallon entered the Mansion Ground. But the way I saw the movement of Foday Sankoh, I saw a vehicle that was in the compound because you could see into the compound from the gate. Some open truck vehicle was there. I think he was moving by vehicle at that time.

  • To your knowledge, at that time do you remember which kind of vehicle was it, which brand?

  • Well, the way I saw that vehicle and the label could have been Toyota van, yes Toyota, because I saw it written on it, because the front was facing us. The front of the vehicle was facing us.

  • Thank you, Mr Witness.

  • Well, Mr Werner, why does he say it could have been a Toyota van if he saw the word "Toyota" written on the van?

  • I will get some clarification, your Honour:

  • Mr Witness, why did you say that this vehicle could have been a Toyota van if you saw "Toyota" written on the front of the vehicle?

  • I said the vehicle was a Toyota van vehicle the way I saw it, because it was written on it. The front was facing us and the label was on it, Toyota. That's how I noticed that it was Toyota van.

  • And, Mr Witness, when you went back with Morris Kallon to target C, Bunumbu, what, if anything, did you bring back with you?

  • To Foday Sankoh in Pendembu?

  • No, when you went back to the target C?

  • When Morris Kallon came out of the Mansion Ground and met me at the gate he told me that - because at that time all of them used to refer to Foday Sankoh as Lion. He said Lion had given him ammunition for us to take with us. They brought some ammunition outside and we took it and we went with it to target C.

  • If you can remember, what kind of ammunition was it at that time that you brought back to target C?

  • It was AK-47 ammunition and RPG bombs. Those were the things we went with.

  • And to your knowledge at that time, how did Foday Sankoh get that ammunition?

  • Well, to my knowledge, the way I saw Foday Sankoh and the very first time we were at the base when we heard that Foday Sankoh was there we heard that he had come from Liberia into Sierra Leone, so I just thought that he had got the ammunition from Liberia and brought them to Sierra Leone.

  • Now coming back for one second to your duties with Morris Kallon in Bunumbu acting as an adjutant, you told us yesterday that you saw a letter coming from Foday Sankoh. If any, which other kind of document did you see when you were working acting as an adjutant for Morris Kallon?

  • Well like the initial stage when we were in Bunumbu we hadn't a radio station, but radio messages were prepared from Pendembu and given to junior commandos and they will travel with it and bring it to Morris Kallon. We got those.

  • And how many of those messages did you see at the time you were working for Morris Kallon?

  • Well I cannot recall the exact number now, but messages used to come and even letters used to be brought.

  • Now to your knowledge at that time which signature, if any, can you remember having seen when you were working acting as an adjutant for Morris Kallon?

  • Well, I saw Foday Sankoh's signature. I can recall Foday Sankoh's signature when I was working with Morris Kallon.

  • And when did you see the signature? In which context, can you remember?

  • Like the first letter that I referred to that I told you about --

  • Your Honours, can the witness repeat this.

  • Mr Witness, the interpreter needs you to repeat the answer. You've said, "Like the first letter I referred to that I told you ..." Continue from that point, please.

  • The first letter which Foday Sankoh wrote to Morris Kallon where he used that directive was where I saw his signature. That was the first letter I saw Foday Sankoh's signature on.

  • And on that occasion apart from the signature what else, if anything, did you see on that letter?

  • Well, at that time again he used the Revolutionary United Front Sierra Leone stamp. He had a stamp. Whenever he wrote a letter, before signing it he will stamp it first and then he will sign. The stamp was a round stamp. It was written on it "Revolutionary United Front" and in the middle of the stamp he will sign.

  • And did you see this stamp again?

  • Yes, I saw it on about one or two occasions again when he was writing letters.

  • Now I had asked you about signatures, if you had seen any signatures, and you spoke about the signature of Foday Sankoh. If any, which other signatures did you see?

  • While I was at target C with Morris Kallon?

  • Well it was more Foday Sankoh's signature that I saw, because he was the one whose letters I saw because he was in Pendembu when I was in target C with Morris Kallon.

  • Now, Mr Witness, you told us about letters and you told us about having seen some radio messages. Now again - sorry, and then you told us as well that at that time there was no radio set in Pendembu. Is that correct?

  • I did not say Pendembu. I said Bunumbu.

  • My mistake. My mistake, Mr Witness. In Bunumbu?

  • Yes, sir, at the time we were at target C too at the initial stage there was no radio station at Bunumbu.

  • Is there a difference between radio set and radio station, because I think, Mr Werner, you referred to a radio set and the witness speaks of a radio station?

  • Did you see any radio set in Bunumbu, target C, at that time?

  • Now, Mr Witness, you told us about the EMG, Executive Mansion Guard. In the EMG who, if anyone, did you know at that time; the time you were in Bunumbu with Morris Kallon?

  • Well I knew like there was a guy called Captain Ben, because all of us were in Bunumbu when we were captured and taken for training. I knew Captain Ben from the EMG. Then I knew Jackson Swarray who we used to call Ray, he too I knew him, and some others.

  • Your Honour, Ben would be the usual spelling. I believe that we gave Jackson Swarray, the spelling of Jackson Swarray, but let me double check:

  • Now talking about Captain Ben, which nationality was he, Captain Ben?

  • He was a Sierra Leonean.

  • And do you know his last name, or do you just know Captain Ben?

  • I only knew captain - the name Captain Ben. That's the only thing I knew.

  • Is Captain Ben alive today?

  • And when did he die, to your knowledge?

  • Well, Captain Ben died during the Zogoda time when we had gone into the jungles during '94/'95. That was the time Captain Ben died.

  • And Zogoda was - the name was given to your Honours already:

  • Now, how much did you interact with Captain Ben at that time?

  • Well, I interacted with him on several occasions.

  • I'm not getting any translation.

  • I'm just wondering what "interact" means?

  • Maybe I'm the only one, but I'm not getting any translation on my --

  • I heard the witness say, as recorded, "I interacted with him on several occasions."

  • I will clarify that, your Honour:

  • Just pause, Mr Werner. Are you now hearing the interpretation?

  • I am hearing you.

  • It's the interpreter I would like you to hear. If not, I will ask our Courtroom Attendant to --

  • I will tell you if the problem continues:

  • Mr Witness, when you said that you interacted with him on several occasions, what do you mean?

  • Well when we used to meet, when we would meet together, that's what I meant. We would share ideas and we would speak to each other. That was what I meant by interact.

  • And at that time what, if anything, did Captain Ben tell you about his moves?

  • Well like the time we were in Bunumbu at target C, at that time RUF had captured Kono, phase 1. He, Captain Ben, and others were the ones who captured Kono, together with CO Mohamed, and Bunumbu is on the main road to go to Kono and that was the route they used to go to Kono and from Kono to go to Pendembu, or Kailahun. So when he was coming from Kono he would go through Bunumbu and he would meet us there. That was how we spoke to each other. That was how we met.

  • And apart from Kono - and we will come back to that in due time - where else to your knowledge did Captain Ben go?

  • Well Captain Ben was travelling together with Foday Sankoh, because he was his bodyguard, within the RUF territory and they would enter into Liberia and from Liberia they would come again into the RUF territory.

  • And how did you know that Captain Ben went to Liberia with Foday Sankoh at that time?

  • He was his security. The Executive Mansion Guard security was very close to him and so the two of them would go together. So any time they went and returned we would see them in that area, we would meet them because we had close talk with each other --

  • Your Honours, can the witness slow down and repeat this bit.

  • Mr Witness, you're talking too quickly for the interpreter. Please speak a little slower and continue your answer, repeat your answer again, where you said, "... we would meet them because we had close talk with each other." Continue from there, please.

  • The two of us would meet and when they would go into Liberia, he and Foday Sankoh, when they would come from the RUF territory they would go to Liberia, then they would come from Liberia and return into the RUF territory. And when we too would come from Bunumbu at times, when we would go to Pendembu or Kailahun we would meet with each other, so that was how we spoke to each other and that's how I knew that they were moving around together with Foday Sankoh and others.

  • And what else, if anything, did Captain Ben tell you about his travels with Foday Sankoh to Liberia?

  • Any time they were going when we would meet he would tell me that they had brought ammunition for the fighters, for the RUF. They will go in and bring ammunition for us. Those were some of the things he used to tell me.

  • And now about - you told us before that Captain Ben was in Kono and then you said that when he was coming back from Kono he used to meet you in Kailahun District, so when Captain Ben was coming back from Kono what if anything --

  • Mr Anyah?

  • With respect, the witness's evidence was that Ben was in Kono and when Ben was passing through Pendembu to go to either Kailahun - I should just read. The witness's evidence was that Ben was in Kono and Ben would stop at Pendembu when he would be on his way - Ben would stop at Bunumbu when he would be on his way to Kono, or to Kailahun. I believe that was the witness's evidence.

  • And I believe that the question I asked was what, if anything, Ben said when he was coming back from Kono to Kailahun District. That's the question I asked and that's exactly what the witness said. Bunumbu is in Kailahun District.

  • Well I am trying to find the transcript, your Honour, because I stand by my objection.

  • What is nature of your objection?

  • What is the objection?

  • The objection is that counsel is misstating the evidence given by the witness.

  • My answer is that I'm not misstating the answer because Bunumbu is in Kailahun District.

  • Madam President, the page in question is on my transcript and I'm using 12 point font, page 18, and the answer starts in line 14. The question, starting at line 12:

    "Q. And at that time what, if anything, did Captain Ben

    tell you about his moves?

    A. Well, like the time we went Bunumbu at target C, at

    that time RUF had captured Kono, phase 1. He, Captain Ben

    and others were the ones who captured Kono, together with

    CO Mohamed and Bunumbu is on the main road to go to Kono

    and that was the route they used to go to Kono, and from

    Kono to Pendembu, or Kailahun."

  • Yes.

  • And Pendembu and Kailahun are in Kailahun District and I asked the witness what did --

  • Is it Kailahun District, is it Kailahun Town? The witness in this response I have just read, I suspect and I suggest, is referring to Pendembu or Kailahun Town and not the district.

  • Mr Anyah, I'm not prepared to make that assumption. You may, but the witness said Kailahun and if there is doubt as to whether it's Kailahun District or Kailahun Town, then it will have to be adduced as evidence, not as speculation. Mr Werner, I allow the question.

  • So, Mr Witness, what, if anything, did Captain Ben tell you when you met him when he was coming back from Kono?

  • Well, on one occasion when Captain Ben came from Kono, after they had captured Kono they were there and we too were in Bunumbu, in target C, he met us there. He was passing to go to Foday Sankoh and he told us that he had some gems, I mean diamonds. He had them in the band of his trousers, the inner part. He cut it open and he put the diamonds in there and he opened it and he showed us the place. He said, "I am taking diamonds to the Lion." He said, "They have given it to me, I am going with them to the Lion." He said, "I'll be back soon", and he went.

  • I'm sorry, Mr Interpreter, you keep breaking. We do not understand what you're saying. Perhaps the witness could repeat his answer. It's all very confusing. Just repeat what the witness said properly.

  • Your Honours, can the witness repeat, kindly.

  • Mr Witness, could you just tell us again what Captain Ben told you at that time?

  • On one occasion when Captain Ben came from Kono he met us in Bunumbu. He was passing to go and meet Foday Sankoh in Pendembu and he told us that he had diamonds, he was going with diamonds and the diamonds - that was my first time - in fact, I did not even set eyes on them, but I saw them in his band, where his belt would be. He cut it open and he put the diamonds in there and it was sewn again. So he showed us the place, myself and a friend of mine, and he showed us the diamonds. He said, "Those are the diamonds that I am taking to Foday Sankoh. I'll be back." We said, "Okay."

  • I'm a little bit confused, Mr Werner. He said, "He showed us the diamonds." Earlier in the same answer he said, "I did not even set eyes on them." What is he saying exactly?

  • I will try to clarify that, your Honour:

  • So could you help us to understand your answer, Mr Witness, because first you said that he showed something to you and other people, but you said as well that you didn't set eyes on the diamonds, so what exactly happened?

  • The diamonds were in his band, the band of his trousers, where the belt would be, inside of it. He cut there and he put the diamonds in there. So he showed us that those were the diamonds that he was taking. The inner part of the trousers was where he showed to us where the diamonds were, but he did not take out the diamonds and put them into his palm and we saw it with our naked eyes, no. But he showed us where the diamonds were, in the inner part of his trousers. That's what I meant.

  • To your knowledge, what, if anything, happened to these diamonds?

  • He went with it and gave it to Foday Sankoh.

  • To your knowledge, what, if anything - what Foday Sankoh did with these diamonds to your knowledge at that time?

  • Well, to my knowledge Foday Sankoh took those diamonds to Liberia, to Charles Taylor. That's what I felt.

  • And why did you feel that?

  • Because there was where he used to go to bring ammunition for us to fight.

  • Mr Werner, are you satisfied with this kind of evidence that has absolutely very little or no foundation? Are we now taking opinions and feelings? Please establish some kind of foundation for these kinds of answers.

  • Mr Witness, did you speak again with Captain Ben at that time about his travels to Liberia?

  • What else, if anything, did he tell you about his travels to Liberia?

  • Well, he told me that when he normally went to Liberia they would bring ammunitions, arms and ammunition, for us, for the movement, for the revolution. They would bring ammunition. That was what he used to tell me.

  • Did he tell you anything else?

  • Well, that was one of the major things he used to tell me. He said normally when they went to Liberia, himself and Foday Sankoh, they will bring back ammunition and that the ammunitions we used to use to fight with, they brought them from Liberia.

  • Now, you told us that in one occasion you had a conversation with Captain Ben about diamonds and you explained in detail about what happened during this conversation. Did you talk again with Captain Ben about diamonds at that time?

  • Now, Mr Witness, you told us about Jackson Swarray and we are ready to give your Honours a spelling for Jackson Swarray. Swarray would be S-W-A-R-R-A-Y and Jackson would be the usual spelling. Again, Mr Witness, who was Jackson Swarray?

  • Well, Jackson Swarray was also an Executive Mansion Guard. He was a security to Foday Sankoh.

  • And at that time, to your knowledge, what was his position among the Executive Mansion Guard, if any?

  • Well, he was the Executive Mansion Guard commander over the securities to Foday Sankoh.

  • And what, if anything, did you know about his moves at that time, of Jackson Swarray?

  • At the point in time we understood that Jackson Swarray and Foday Sankoh went to Liberia and Charles Taylor saw Jackson Swarray and, according to him, he said Charles Taylor told Foday Sankoh that he and Jackson Swarray were resembled and Charles Taylor said that he should stay with him at the mansion there in Liberia and we understood it that he remained there and stayed there with Charles Taylor and he did not return to the Sierra Leone territory. That was what I knew at that time about Jackson Swarray.

  • When you say that Charles Taylor told Foday Sankoh that he and Jackson Swarray were resembled, who is the "he", to be completely clear?

  • I did not understand you clearly.

  • Charles Taylor told Foday Sankoh that "he" and Jackson Swarray were resembled. Who is the "he"?

  • He himself, Charles Taylor.

  • And how did you learn about that?

  • Well, when Captain Ben returned we later asked for Jackson and he said Jackson stayed in Liberia with Charles Taylor, because he said that Jackson and Charles Taylor resembled, so he wanted him to stay there with him at the mansion.

  • And what do you mean when you say that they were resembled. What do you mean?

  • They looked alike, either in complexion, or in the face, or maybe like the complexion of Jackson Swarray was the same complexion Mr Taylor had, or maybe they looked alike in face. That was what I understood from that.

  • To your knowledge, how long did Jackson Swarray stay with Charles Taylor in Liberia?

  • Well, he was there for a few months with him in Liberia. He was with Charles Taylor for a few months at that time.

  • Now, Mr Witness, at the time you were in Bunumbu with Morris Kallon, what trip, if any, did you take outside Sierra Leone yourself?

  • Yes, I recall at one time when the same Captain Ben used to pass frequently through us and when he went to Pendembu and sometimes went to Liberia and returned, at one time I told him myself - I told Captain Ben myself that I would want to go with him on that trip for me to go and see Liberia at a point in time. And, fortunately, at a point in time when Foday Sankoh was going, they chose us to serve as escorts to him to go to Liberia and myself, Captain Ben and some other securities, we all went. We went to Liberia. That was the trip I took together with him, Captain Ben.

  • And can you tell us where did you go in Liberia when you left Bunumbu?

  • Well, we all met in Kailahun Town and there we went on board an open truck van and we went through Foya. We travelled through Voinjama, Zorzor and we went to Gbarnga. That was how we travelled.

  • So you said that Captain Ben went with you. Who else was in this convoy?

  • I remember one Liberian vanguard who was called CO Lion. We were all on board that same convoy.

  • And who was CO Lion, to your knowledge?

  • Well, CO Lion was a Liberian vanguard and they were the ones who came to help train us in Sierra Leone to fight the war.

  • And how many vehicles went to Liberia at that time, during your trip?

  • It was just one pick-up van. We were in the open back and then Foday Sankoh was in the front.

  • Now, you said you went to Voinjama. You spoke about Voinjama and Zorzor and, your Honours, I believe that these names are already in evidence. They are already spelt.

    Where did you cross the border between Sierra Leone and Liberia, can you remember?

  • It was through Koindu. There was an area called Mendekoma. That was where the border was between Sierra Leone and Liberia and when you cross there you go and enter Foya.

  • I believe, as well, Mendekoma was already spelt:

  • Now what, if anything, happened when you crossed the border at Mendekoma?

  • Well, we were just going forward until we went up to Foya and from there it was he himself, Captain Ben, who used to show me the villages and the towns. He said, "This is Foya. This is Voinjama. This is Zorzor." We went on until we got to Gbarnga.

  • And did you experience any problem along the way from Mendekoma all the way to Voinjama and where you crossed the border?

  • Now you told us that you yourself, CO Lion and Captain Ben were in - went on that travel. Who else - if anyone, who else was present during that travel?

  • Well, they were the Mansion Guard securities. We travelled with them and we went.

  • And how long did it take you to go from Sierra Leone to Gbarnga?

  • Well, we travelled for almost a whole day and we got there early in the morning.

  • And where did you eat along the way?

  • I recall when we got to Voinjama we ate some food and then from there we continued.

  • And who was in Voinjama at that time when you stopped to eat there?

  • There were NPFL fighters present there.

  • And then what happened when you arrived in Gbarnga?

  • Well when we got to Gbarnga, the securities that we met in Gbarnga, we got to a particular checkpoint because that was my first time to get - to go to that particular area. When we got to that particular checkpoint, those of us who went as escorts they asked us to alight from the vehicle and they asked us to take our magazines out of the arms and then they asked us to declare. By that I mean if you had any other ammunition that was on advance in the gun you should take it out of the gun. Then after doing that they asked us to give our guns to the securities, who were there at the gates, and we remained in possession of the magazines. They asked us to wait at that particular area, because we were not allowed to get to the particular Mansion Ground area where Charles Taylor was. I did not go there. I did not go there at all.

  • Now, you spoke about a gate. What gate was that?

  • It was a security gate, a security checkpoint. It was a gate, a security checkpoint.

  • And then you said that they asked you to do a number of things, to alight from the vehicle and to take out the magazine and they asked you to declare and then they asked you to give the gun to the security. Who asked all of that?

  • The securities whom we met at the gates. They were manning the gate. They told us that.

  • Mr Werner, I hope at some stage you will give us a time frame for this evidence.

  • I will, your Honour. I will:

  • Mr Witness, when did that happen, to your recollection?

  • It was in '92. In 1992, I recall.

  • And can you recall the month?

  • Now what happened after that, Mr Witness, when you were in Gbarnga?

  • Well the place where we were lodged, in the morning they brought us some food, we ate and in the afternoon they provided us some food again and we ate. We saw CO Lion arrive. He brought some ammunition, AK-47 rounds, RPG bombs, land mines, they were all in a vehicle, and then he asked us to on board the vehicle again and then to go back to Sierra Leone. And then we travelled back to Sierra Leone, but Foday Sankoh stayed in the Liberian territory.

  • Now you said that Lion "... brought some ammunition, AK-47 rounds, RPG bombs, land mines, they were all in a vehicle, and then he asked us to on board the vehicle again." Who asked you to on board the vehicle again, Mr Witness?

  • CO Lion. He asked us to jump into the vehicle and go back to Sierra Leone.

  • Now, you talk about - you mention Foday Sankoh. How did you know that Foday Sankoh was in Gbarnga at that time?

  • Well we left him there because when we got there the following day, Foday Sankoh and the others they entered the Mansion Ground and we stayed at the security post. The next day - the following day when CO Lion brought the vehicle with the ammunition he told us that we should go and that the Lion said he will follow us later, and then we moved with the ammunition in the vehicle and then we went back to Sierra Leone.

  • So to be completely clear about that, Mr Witness, was Foday Sankoh on that travel from Sierra Leone to Gbarnga?

  • Now --

  • Didn't he say he was in the front of the vehicle?

  • That's what I thought as well, but I just wanted to be completely sure. Thank you, your Honour:

  • Now, Mr Witness, where were you lodged when you stayed in Gbarnga?

  • Well, there was a house just by the security checkpoint where they asked us to surrender our arms to the securities. There was a house very close to there. That was where we were lodged. They said, "Gentlemen, you are going to be lodged here", and then we said, "Okay", and they asked us to safely relax ourselves, but we had our magazines in our possessions.

  • Now, you said that - you talk about AK-47 rounds, RPG bombs, land mines and you said that they were all in a vehicle, so which vehicle are you talking about?

  • It was an open Hilux pick-up van and the ammunition were at the back in the open van. A pick-up van.

  • And who provided this pick-up van, Mr Witness?

  • Well, it was the same pick-up van that we travelled with from Sierra Leone that Foday Sankoh had. It was the same that we travelled and entered with into Liberia and it was that same pick-up van that we used to go back to Sierra Leone.

  • And then what happened after that, Mr Witness?

  • We returned to Sierra Leone with all the ammunition, together with CO Lion.

  • And what happened to that ammunition?

  • When we came back the ammunition was unloaded right at the Mansion Ground, and then those of us who went as escort all of us returned to our various deployment areas.

  • Now just to clarify that point, so you went back with - how many vehicles did you use to come back?

  • Thank you. And again to be completely clear, who stayed behind in Gbarnga?

  • Foday Sankoh stayed there.

  • Now, you mentioned the - you said that you brought this material to the Mansion Ground. Again, where was the Mansion Ground?

  • Well, at that time they had established another Mansion Ground in Pendembu - I mean Kailahun Town. That was where we went and unloaded all the ammunition.

  • Now, Mr Witness, I just want to ask you one more question about the - not your own travel that you just talked about now, but the one Captain Ben did and the one that he told you about. So, you testified that Captain Ben told you that he would go to Liberia and bring back arms and ammunition. Now what, if anything, did Captain Ben say about who gave them the arms and ammunition at that point?

  • It was Charles Taylor.

  • Now, Mr Witness, you told us about AK-47 rounds, RPG bombs and land mines. Now who, if anyone, taught the RUF to use land mines?

  • Well later, when we had brought the ammunition, we understood that an artillery unit from the Liberian NPFL had come to train our own artillery units how to use the land mines and how to operate them.

  • When you said that "we understood", how did you understand that? How did you learn about that?

  • We heard it because it was not something hidden. At any time they came to train our brothers - in fact, when they came they called for the artillery unit people and then they went, they taught them how to set it and how to operate it. It was not something secret.

  • But again, even if it was not something secret, how did you learn about that?

  • It was a discussion - a privileged discussion - and even the artilleries that they were taught about they explained to us how to fix them, how they fixed the land mines and how to operate them. They told us that - they explained to us that it was the NPFL artillery unit that came and taught them how to use the artilleries and how to use the land mines.

  • And you talked about a privileged conversation. If you can remember, who told you about that?

  • I can't recall the name of the specific person, but it was something we knew about, that of course people were training, that people had come to train the RUF artillery unit for that mission.

  • Now, you said that NPFL trainers went to explain to the artillery unit of the RUF how to use land mines. To your knowledge at that time what else, if anything, did they teach the RUF artillery unit?

  • For instance, there was another weapon that they brought that was called chaser. They said that was what they used to shoot at Alpha jets that will come flying around to disturb us. It was a very long kind of weapon that they could put on their shoulders and to shoot at the Alpha Jets, and when they came they said they taught them how to use those weapons and the Alpha Jets used to disturb our territory.

  • Now, Mr Witness, to your knowledge who brought the chasers to Sierra Leone at that time?

  • Just pause, please. Yes, Mr Anyah?

  • I would be grateful for some foundation as to the time frame for this training both in respect of the artillery and in respect of the chasers.

  • Yes, I think that's appropriate, Mr Werner.

  • Mr Witness, you told us about these NPFL trainers coming to Sierra Leone to train the RUF artillery unit. To your recollection, when did that happen?

  • It was around late '92 going towards '93. It was around that time they came to train our artillery unit.

  • And you spoke about a training about the land mines and subsequently you spoke about a training about the chaser. To your knowledge, was the training around these two weapons given at the same time?

  • Well, the training around the land mines started first and later the chaser training followed, but it was within that same time: Towards the end of 1992, going to 1993.

  • To your knowledge, who brought the chasers to Sierra Leone?

  • Well, we understood that even at the time Foday Sankoh was coming he brought some of those weapons with him, the land mines and the chasers. He brought them into Sierra Leone from Liberia.

  • And you said even at the time Foday Sankoh was coming, which time are you talking about?

  • When he came from Liberia, within that same time, towards the end of 1992 going to 1993 when he came from Liberia back into Sierra Leone.

  • Mr Werner, the witness keeps saying "we understood" thus and thus, "we understood". I'm not sure what that means.

  • I will try to get some clarification:

  • Mr Witness, you said that you and others understood that at the time Foday Sankoh was coming he brought the land mines and the chaser. How did you understand that at that time?

  • Well, like at that time the Alpha Jets used to disturb us at all times, especially around the Pendembu areas and Kailahun areas and when he brought those chasers, at the moment he brought the chasers, the news spread out quickly to all the zones and they told us that Foday Sankoh has brought a weapon with him that will bring down the Alpha Jet and they told us that it was a good news for us. So the news was spreading far and wide in the RUF territory.

  • Now, Mr Witness, you told us yesterday about an NPFL Special Forces called Dopoe. Do you remember telling us about him?

  • Yes, sir.

  • Now, to your knowledge, in 1992 where was Dopoe?

  • Well, at that time in 1992, whilst we were at target C, General Dopoe we understood was around the target B area, that is Baiima facing the Daru target, that was where he was, and he was in between that area, between Daru target and Pendembu, but he was facing the barracks.

  • Now, Mr Witness, what do you mean when you said "we understood" that Dopoe was around the target B area?

  • That was where he concentrated during the fighting, that is the Daru barracks axis, target B. That was where he was. That was where he concentrated.

  • And how did you yourself learn about that, Mr Witness?

  • Well, I recall there was an attack on Daru and by then we were in Bunumbu and even some of his colleague Liberian fighter, that is General Dopoe's colleague Liberian fighters, they told us that General Dopoe and others were going to attack Daru barracks that particular day and indeed we heard the bombardment on Daru barracks and it was during the early hours of the morning and the bombardment went on up to about the afternoon hours, and his colleague Liberian fighters were telling us at that time that it was General Dopoe and others who had attacked Daru barracks. So that was how I came to know that he was concentrating and fighting around the Daru barracks axis.

  • And you talk about some Liberian colleague fighters of Dopoe. Can you remember any names?

  • Well, yes, during that particular attack on Daru we heard of another RUF vanguard who was called CO Fembeh. They said it was General Dopoe and CO Fembeh who attacked Daru barracks and that Dopoe was concentrating on the main road going towards the barracks, to attack the barracks, and that Fembeh was using the bypass behind the Daru barracks to attack the barracks. That was what we heard.

  • And, Mr Witness, would you be able to spell CO Fembeh for the Court?

  • Well, CO, C-O and Fembeh, F-E-M-B-E-H. That is how I think it could be spelt, F-E-M-B-E-H.

  • Thank you, Mr Witness. Now, to your knowledge, who, if anyone, ordered Dopoe at that time to attack Daru barracks?

  • Well, to my knowledge it was Foday Sankoh who issued the orders to attack Daru barracks.

  • And how do you know that?

  • Well, at that time Foday Sankoh was within the RUF territory and with regards such major attacks, he was the only person who the authority to give instruction, or to give orders to attack, because we needed Daru barracks.

  • To your knowledge, where did Dopoe get the supplies at that time to attack Daru barracks?

  • Well, to my knowledge I think Foday Sankoh gave him supplies to attack Daru barracks, he and his men. That was what I understood, because he was the one who issued the orders to him to attack.

  • And how did you understand that at that time?

  • He said "to my knowledge I think" [overlapping speakers] he said "understood", so which one is it?

  • How did you learn about that, Mr Witness, at that time?

  • Because Foday Sankoh was in Pendembu at that time, whilst the attack was going on in Daru.

  • And you told us that there was an attack by Dopoe. What happened after that attack, to your knowledge?

  • Well, during that attack we understood that there was another Special Forces member who was called Rambo. He died during that attack over the Daru bridge and, if you go there, up to this moment there is a mark there that will show that he died there over the bridge and they were unable to get rid of the barracks because they almost went out of ammunition. So they were going around the barracks to see whether they could get more supplies from Foday Sankoh to enable them to overtake - overrun the barracks, but that particular Liberian Special Forces, who was called Rambo, died during that attack and they did not make it in overrunning the barracks.

  • Again, Mr Witness, you said that during that attack "we understood" that there was another Special Forces member who was called Rambo. What did you mean by that when you said "we understood"?

  • I did not say other forces, I said there was one of the Special Forces members who was called Rambo. They all went on that attack and he died during the attack and after his death we got the information that Rambo died during the attack on Daru.

  • Where did you get this information from, Mr Witness?

  • We were in Bunumbu. After the attack failed and when they returned to Pendembu, some of the men who were with us at Bunumbu target, some of the Liberian fighters who used to travel to go to Pendembu and come back, when they went to Pendembu they got the information there and when they returned to Bunumbu they explained to us that that was how the attack took place and that Rambo died during the attack.

  • Now about this Rambo, you told us that he was a Special Forces. What was his nationality?

  • He was a Liberian.

  • I would be grateful if the witness could be shown a document that is already in evidence and which is P-65. We have copies if necessary. Would your Honours like copies?

  • I would appreciate a copy and I'm sure my colleagues would also appreciate a copy, Mr Werner.

  • I have copies for my learned friend if needed.

  • Thank you, counsel. I believe I have mine somewhere here.

  • Mr Witness, during your time with the RUF did you see this document?

  • If you look at the bottom of the document there is a signature. Can you recognise that signature?

  • Yes, sir.

  • Whose signature is that?

  • It's Foday Sankoh's.

  • And there is something around the signature. Can you recognise that?

  • And what is that?

  • This is the stamp I was talking about that he used to stamp the letter that he sent to Morris Kallon. This is the type of stamp.

  • Now, if you look at the top of the document you can see, "His Excellency CIC Charles Ghankay Taylor". To your knowledge, what does CIC stand for?

  • Commander-in-chief, or commander in charge.

  • Now, could you just take some time to familiarise yourself with this document. Now if you look at the second paragraph which starts with the words, "I appreciate the five boxes of AK-47", if you look at the second sentence it reads, "But I have just received a radio message from General Dopoe that our men have encircled the Daru barracks and they are awaiting materials to do the final assault."

    Now the Daru barracks which are mentioned here, is it the same place that you talked about earlier?

  • Yes, sir.

  • And the assault which is mentioned here, is it the same event that the attack on Daru barracks you mentioned earlier?

  • Yes, sir, because General Dopoe - yes, sir, this is it. It could be the assault.

  • And why do you think that it could be the assault?

  • Because just like I have said when we were in Bunumbu, when the Liberian fighters were saying General Dopoe was going to attack Daru barracks today together with CO Fembeh, and when I've gone through this document, especially the second paragraph, he, General Dopoe, because where Foday Sankoh said he has received a radio message from General Dopoe that his men have encircled the Daru barracks, I believe that this was the assault.

  • Now, if you look at the next paragraph it reads:

    "Lastly today I am a common laugher because of lack of vehicle for my mobility. My only jeep is in the garage beyond repairs. I do ride on a Toyota truck for a long distance journey or beg for lift here in town."

    Now, you told us before about a Toyota van. Is it the same vehicle which is mentioned here?

  • I believe so, yes, sir. Yes, sir.

  • Thank you, your Honour. That will be all for this exhibit:

  • Now, Mr Witness, you told us that at the time you were in Bunumbu the number 2 in the RUF was Mohamed Tarawalli, whose nickname was Zino. Now at the time you were in target C with Morris Kallon, where was Mohamed Tarawalli based?

  • At that time he had captured Kono. That was where he was based. He was in Kono. In Kono District, in Kono Town.

  • And when was that? Which year was that that Mohamed Tarawalli was in Kono District?

  • It was towards the end of 1992 to 1993. 1992/1993, yes, sir.

  • Now who, if anyone, was at that time with Mohamed Tarawalli in Kono, Kono District?

  • He was with fighters - RUF fighters - with whom they were fighting in the Kono District.

  • And to your knowledge can you remember any group which was with Mohamed Tarawalli active in Kono at that time?

  • And what was the name of that group?

  • They called the group Action Force.

  • And who, if anyone, was in charge in Kono at that time of the Action Force group?

  • It was he, CO Mohamed.

  • Now what, if anything, did you learn about the Action Force group in Kono that time?

  • Well the Action Force at that time in Kono, when we were in Bunumbu, because at the time that Kono was captured when CO Mohamed captured Kono, Kono was the first big town that the RUF captured that was rich, that had a lot of property which other commanders could go and take. But it came to a time like even when we were in Bunumbu, those who were in Kuiva, Baiima, they were hiding away, the soldiers. They would hide from Baiima, or Kuiva, or Bunumbu, to go to Kono to go and get the property that they want, or to loot the properties that they want to loot, and so they would leave their grounds to go there. So the complaint accumulated so much that CO Mohamed started arresting them, whoever left his own target, because at that time we used to give passes to people when they were travelling from one point to the other. They will give you a written document to clear you that you've been authorised to travel from this point to the other point. So even if you came across a senior officer, or a senior security who asks you for your pass, if you take it out and show it to him that security would not do you anything, but it came to a time when our colleague commandos, junior commandos, went to Kono without passes because they want to go and loot in Kono.

    So CO Mohamed organised this action force at some strategic points in Kono. So when you entered Kono they would ask you for your pass. If you hadn't a pass they would take you to where he was, the CO Mohamed, the house where he was at the ground. You would be beaten mercilessly, you would be beaten mercilessly and sent back to your target where you had come from, because they were calling those soldiers AWOL soldiers, that was how they called them, AWOL soldiers. That was what I experienced that was happening in Kono.

  • Okay, so, Mr Witness, I want to come back to a few things here. First you made mention of a place called Kono Town. So, to be clear, what do you mean when you say Kono Town? What is Kono Town?

  • Well, the centre of the Koidu Town, because Kono is a broad name for the entire district. The centre of the town, Koidu, because the centre of the town is called Koidu. For instance, like when in Sierra Leone, if I say Kono Town you would understand that I am talking about Koidu Town, the heart of the town. That's what I mean.

  • Now, your Honour, the witness again made mention of Kuiva and we would like to give your Honours a spelling for Kuiva, which will be K-W-I-V-A [sic]. I will ask the witness then. Mr Witness, how would you spell Kuiva?

  • Well, how I used to spell Kuiva was K-U-I-V-A. K-U-I-V-A.

  • Very well. Now, Mr Witness, you mentioned the word AWOL. What to you mean when you say AWOL?

  • AWOL. It's A-W-O-L. Militarially it means absent without leave. When you absent yourself from the ground without permission that means you've gone AWOL. That's what I mean.

  • Now, to your knowledge, at that time, if anyone, who else was beaten up by the Action Force in Kono?

  • Well, they were beating up civilians because at the time that RUF took over Kono we were doing mining there, the RUF was doing mining there. They started mining activities there. When I say "we", I am talking about the RUF. I was not there, but it was the RUF. They were doing mining activities in Kono. So if they put some civilians together to go and do the mining and you tried to escape, if you are caught you would be beaten.

  • And again to be completely clear, what is AWOL soldiers, why were they beaten up by the Action Force?

  • Not to go away from their own ground to where they've been assigned. If you want to go away from your ground the commander who was in charge has to know that one or two soldiers have gone on passes, that they have gone to so and so place, but he will come back within a time frame. Because when you were given a pass they will give you a time frame of maybe three days or four days. So if the four days goes by then you will have to seek - give an explanation for those other days.

  • Thank you, Mr Witness. Now, Mr Witness, do you remember the month of April 1992?

  • And what, if anything that you can remember, happened in Sierra Leone in April 1992?

  • That was the time when we were in the jungle when we heard that the government soldiers, led by Strasser King, have overthrown the ex-President Momoh's government. They called themselves the NPRC. I can remember that incident.

  • And what you told us about the Action Force in Kono under CO Mohamed Tarawalli, did it happen before or after the NPRC coup in April 1992?

  • It was before the coup, the NPRC coup.

  • So what happened with the Action Force was before the NPRC coup, correct?

  • You said that the RUF was mining in Kono at that time, so before the NPRC coup what kind of mining was going on in Kono?

  • Well, they would put civilians together and take them to where the mining ground was where we suspected diamonds were. That was where they told them to mine by labour. They were using the labour force to mine.

  • And who was using a labour force to mine?

  • Now, around that time what was the situation in the border between Sierra Leone and Liberia?

  • Well, at the time that the RUF was in Kono when the mining was going on?

  • The border was still open. It was the NPFL that still engaged the border at Lofa County, between Sierra Leone and Liberia, that Lofa County. The NPFL forces were still there.

  • And what, if anything, happened in the border later, to your knowledge?

  • Well, later on, when NPRC took over, we lost Kono and they pushed us until we went back to the border, the Koindu border. At that time the ULIMO had taken over the border there. The ULIMO had been there.

  • And what is the ULIMO, Mr Witness?

  • Well, ULIMO was another rebel group fighting against Charles Taylor in Liberia. They were fighting against the NPFL, the Charles Taylor force, in Liberia.

  • Now, you talked about the Koindu border. What did you mean when you talked about the Koindu border?

  • The border that was in Koindu, that is between Koindu and Liberia, where Mendekoma was, the Sierra Leone border. When I say Koindu border that is what I mean. That is the border between Sierra Leone and Liberia that was behind Liberia.

  • And you said that at that time the ULIMO had taken over the border there, the ULIMO had been there. What, if anything, happened as a result of the fact that the ULIMO had taken the border?

  • Well, the ULIMOs were also a force that were fighting against Charles Taylor, the NPFL force of Charles Taylor in Liberia. I don't know if they understood that it was through those areas that we were getting supplies that has caused them to come and cut off that supply line from us, but it was that area that they first engaged at that time.

  • And when you said that you "don't know if they understood that it was through those areas that we were getting supplies", who are you talking about?

  • The ULIMO fighters.

  • And you say, "But it was that area that they first engaged at that time." Who are you talking about there?

  • The ULIMOs.

  • What, if anything, happened as a result of that fact, the fact that ULIMO was cutting the border?

  • Well, at that time, before the ULIMOs finally took care of that border, Morris Kallon entered Liberia with some manpower to bring ammunition, but he was still in Liberia when the ULIMOs took over the border. So they were in there together with NPFL, Morris Kallon and NPFL, and the other men who had gone with him, and they were helping to fight against the ULIMO for them to open the way to come to us.

  • And you said that they were helping to fight against the ULIMO, who are they helping to fight against the ULIMO?

  • Morris Kallon and our colleague RUF fighters who entered, they were helping the NPFL fighters to fight against ULIMO to push them off the border.

  • And why were they helping the NPFL to fight against the ULIMO?

  • Because, one, it was our supply route. That was where we passed to enter. It was the RUF supply route to enter Liberia and back. So he, Morris Kallon, had entered Liberia with some RUF fighters, so he was finding ways and means to come back with them to RUF territory.

  • Madam President, I apologise for interrupting. I would appreciate some time frame if possible, in respect, in particular, of when Kallon and RUF fighters were assisting NPFL fight ULIMO.

  • Yes, I think that is appropriate.

  • Mr Witness, you told us that Morris Kallon found himself in Liberia when the border was cut. To your knowledge when did that happen?

  • It was around 1993 then, 1993. They had been there from 1993 to 1994, but it was in 1993 that Morris Kallon and others were in Liberia when the fighting was going on.

  • I asked you why Morris Kallon and the other RUF were helping the NPFL and you answered that "it was our supply route". What did you mean by that?

  • It was through that path that the RUF passed to enter Liberia to collect arms and ammunition, or even manpower to assist RUF to fight in the RUF territory in Sierra Leone.

  • When you talk about manpower, which manpower are you talking about?

  • RUF manpower, or NPFL manpower. If RUF needed manpower from NPFL, then NPFL could send manpower from NPFL to come into Sierra Leone. That's what I mean by manpower. Manpower from both sides: The RUF and the NPFL.

  • Now, you told us that Morris Kallon was in Liberia fighting alongside NPFL against the ULIMO. To your knowledge, how long did Morris Kallon stay in Liberia fighting there?

  • Well, Morris Kallon stayed long a little. In fact, Morris Kallon and others were unable to open the route to come. RUF had to lose some RUF fighters in Liberia and later on Morris Kallon, we understood that he went through Guinea to enter RUF territory. He alone, we only saw him when he came, him, Morris Kallon.

  • And when you say that Morris Kallon and others were unable to open the route to come, which route are you talking about?

  • The route through Koindu from Foya, to come to Koindu at the Sierra Leone-Liberia border, to come through Koindu. They were unable to open it up.

  • And again, Mr Witness, you said that you understood that Morris Kallon went through Guinea to enter RUF territory. What do you mean when you say "we understood"?

  • Well, later on, after it had taken a very long time, we heard about Morris Kallon in Guinea, that he was trying to find a way to come into the RUF territory and indeed he crossed through the waterside between the Guinea and Sierra Leonean border, the RUF territory, the border we shared with Guinea, because there was a river there, the Moa River. He used the canoe and crossed into the RUF territory.

  • Who did you hear that from?

  • Well, that one, Morris Kallon's coming into RUF territory was news that spread around, because as soon as he entered, when he disappeared - when we heard about him in Liberia having been blocked and when he entered through Guinea that was news that spread around and he himself came to the jungle, because at that time we were living in the jungles, we were not in towns. We were in the bushes around that Koindu border, around the Kailahun jungle, that was where we were. So he himself entered there. Our colleagues saw him, civilians saw him. So the news was spreading around that Morris Kallon has returned. I myself saw him when he returned.

  • Now, to your knowledge, what was the reaction of the RUF high command when the border was cut off by the ULIMO?

  • Well, the RUF high command's reaction didn't go down well with the RUF because we knew that with such an exercise that had gone along the border, that was one of the ways that we've been trapped now, because we had no ways and means to get supplies, ammunition supplies, to fight the war. So that was at that time that the pressure was piled on the RUF along the border. So the reaction was not too good from the RUF high command.

  • And a final question about Morris Kallon, if you can help us with that: When did Morris Kallon return to Sierra Leone?

  • Well, Morris Kallon's return, at that time I was not around the Kailahun jungle. At that time we've gone into the jungles. We had gone into the jungle, but when he came we saw him, when he travelled to go along the other jungles where we were. But he stayed for quite a while before he came into the RUF territories.

  • And can you tell us what year Morris Kallon came back?

  • Roughly it could be around 1994/1995. 1994/1995, yes. It could be around that time that Morris Kallon returned.

  • Mr Werner, you asked the witness, "Now, to your knowledge, what was the reaction of the RUF high command when the border was cut off by the ULIMO?" All he's really told us was that the RUF high command's reaction was not too good, but what does that mean?

  • I will clarify that, your Honour:

  • So, Mr Witness, I asked you about the reaction of the RUF high command and you said that the reaction of the RUF high command was not too good. What did you mean when you said that?

  • Well, what I mean by that is that, for example, like you are going to a place to search for food every day and that place is locked before you got there, so that thus preventing you from getting that food, you will feel bad, you will starve and you will die at the end of the day, so you will feel bad. That was what I meant when I said the RUF high command did not feel good because they knew that their supply line has been cut off, they will be unable to get ammunition to fight and they will be conquered in no time. That was what I meant.

  • Now, Mr Witness, as a result of the NPRC coup and the fact that the border was cut off, what, if anything, happened in the RUF held territories?

  • The NPRC, what happened when they held RUF territories? I have not got that question clearly. Ask it once more.

  • Let me do that other ways. The last assignment you told us about was with Morris Kallon in the target C in Bunumbu, so what happened to you after that in terms of assignment? Where did you go after that?

  • Well, after that, when I left Bunumbu, I was now in Kailahun. I joined CO Mohamed, the second in command. I was now working with him. I joined the Action Force that was in Kailahun. It was in Kailahun that they were based. I joined them and we were all in Kailahun at the time.

  • And if you can help us with that, when did you go to the Kailahun jungle to join Mohamed Tarawalli and the Action Force?

  • During 1993. 1993.

  • And how long did you stay there?

  • Well, until we were dislodged from the Koindu border. I was with CO Mohamed until we were dislodged from the Koindu border.

  • Mr Werner, I thought I heard the witness saying "I was now working" and it's recorded as "not working".

  • So, again, tell us what happened to you when you went to the Kailahun jungle. What did you do there?

  • I was with CO Mohamed. I joined the Action Force. I was with the group, I was assisting his adjutant to put administrative matters in place. That was the group I was with. That was what I meant when I said I was working with CO Mohamed.

  • And how long did you stay in this Kailahun jungle with CO Mohamed?

  • Well, from 1993 we were there until NPRC pushed us out of Kailahun until we went to the Koidu jungle, where we were along the border to Liberia. I was with CO Mohamed.

  • What happened when the NPRC pushed you to the border? What happened to you at that time?

  • Well, at that time when we went to the border and we were ing the jungle, Foday Sankoh finally decided that it was now time for guerilla warfare. We had nowhere to go, so he had to divide the jungle. He, Foday Sankoh, he divided. He, Foday Sankoh, divided the jungles and divided and deployed commanders. It was at that time that he and Sam Bockarie moved to go to Zogoda in the Kenema area. He sent CO Mohamed to go to the north and then sent other commanders to go to other points. That was when we dispersed and everybody went to his own jungle.

  • Mr Werner, he still hasn't answered your question. You asked him, "How long did you stay in this Kailahun jungle with CO Mohamed?"

  • Mr Witness, if you can remember, how long did you stay with CO Mohamed in the Kailahun jungle?

  • From '93 until '94 because it was in 1994 that all of us went into the jungles. I was with him in '93 when I joined him in Kailahun up to '94 and in '94 we moved into the jungles.

  • And again, Mr Witness, can you explain why to your knowledge Foday Sankoh decided at that time to divide the RUF into jungles?

  • Well, for him to attract the enemy's attention from the back where they had come from. That was the reason why we went into - why he divided the jungles, so that we would have ways and means to fight the war and capture materials to fight the war because we hadn't any more ways to get ammunition.

  • And when you said - I believe you talked about to attract the enemy. Who were you talking about when you said "the enemy"?

  • The NPRC government that was in power at that time.

  • So what happened to you at that time? Where did you go after the Kailahun jungle?

  • Well, after the Kailahun jungle I was assigned to Peyama, the Tongo jungle. That was where I went. I want to use the bathroom, please.

  • We're almost up to the normal time to adjourn so it may be appropriate to adjourn these few minutes early.

    Mr Witness, I've heard what you said and also we take a break around this time so we will now take the break a few minutes early, allow you to go out and we will resume court at 12 o'clock. Please adjourn court until 12.

  • [Break taken at 11.28 a.m.]

  • [Upon resuming at 12.00 p.m.]

  • Mr Anyah, you are on your feet.

  • Yes, Madam President. Just an administrative issue. Ms Efeotor is not with us for this session. I just wish to advise the Chamber.

  • Unfortunately my line of vision is blocked by screens so I don't always notice, but thank you for that. I have noted it accordingly. Mr Werner, please proceed.

  • Thank you, Madam President:

  • Mr Witness, before we continue I just want to ask you a few things. You told us about a town called Pendembu, do you remember?

  • Yes, sir.

  • If you know, in what district is Pendembu located?

  • It is in the Kailahun District.

  • And you told us about Kailahun Town. In which district is Kailahun Town located?

  • It is in the Kailahun District.

  • And you told us about a place called Kuiva, do you remember?

  • Do you remember in what district is Kuiva located?

  • It is in the Kailahun District.

  • Now, if you know, which towns are located around Kuiva?

  • There are villages around Kuiva, not towns.

  • And, to your knowledge, what would be the closest town to Kuiva?

  • I think we have Jojoima, Malema, Jojoima. Jojoima is around Kuiva.

  • Mr Interpreter, did you say Jojoima?

  • That would be J-O-J-O-I-M-A, Jojoima.

  • Mr Werner, while you are on locations there is a place that the witness referred to as Baiima. I don't know if that is B-A-E-M-A or B-A-I-I-M-A as it is in the transcript. What would help is if you clarify the spelling and perhaps the chiefdom where this town is located.

  • Thank you, your Honour:

  • Would you be able, Mr Witness, to help us with the spelling of Baiima?

  • Well, the way I spell Baiima is B-A-I-M-A [sic].

  • And do you know in what district is Baiima located?

  • It is in the Kailahun District.

  • And the chiefdom?

  • It is in the Jawie chiefdom.

  • Would you be able to spell Jawie for us?

  • J-A-W-E-I [sic].

  • Thank you. Now, I would like to clarify one thing on the transcript. I am on font 16, which I believe now is the standard font. On page 56, line 23, Mr Witness, you said that from 1993 you were there, "until NPRC pushed us out of Kailahun until we went to the Koidu jungle, where we were along the border to Liberia", which jungle were you in when you were pushed out of Kailahun at that time?

  • In Kailahun Town. That was where we were.

  • And on our transcript you are quoted as saying Koidu jungle. Was it Koidu jungle?

  • Which jungle was it then?

  • It is the Kailahun township. That is where we were until we were pushed to the Koindu border with Liberia.

  • That will be Koindu with an "N", not Koidu:

  • Now, the last answer you gave to this court before we left off was about Peyama, do you remember?

  • You said that you went to Peyama?

  • Now, in what district is Peyama?

  • It is in the Kenema District.

  • Your Honour, our spelling would be P-E-Y-A-M-A, Peyama:

  • And you said that you were there with CO Papa?

  • Yes, sir.

  • And when did you arrive in the Peyama jungle, if you can remember?

  • And what did you do in the Peyama jungle?

  • Well, I was a fighter and at the same time I was assisting the adjutant who was dealing with administrative matters.

  • And, Mr Witness, CO Papa, who was CO Papa?

  • He was the commander who was in charge of the Peyama jungle when we were there.

  • And what was his nationality?

  • He was a Sierra Leonean.

  • And yesterday you told us about Special Forces vanguards and junior commandos. To your knowledge, to which group, if any, did CO Papa belong?

  • Junior commando.

  • And how long did you stay in this jungle?

  • I was in Peyama from 1994 to 1995.

  • And what, if anything, happened to you after that?

  • Well, towards the end of 1995 Foday Sankoh was in Zogoda when he called us to go - he changed our assignment from Peyama jungle to Kenema bypass. That was where we went.

  • And before going to Kenema bypass what, if anything, happened to you?

  • Well, we were in Peyama when Foday Sankoh called us and we went to Zogoda. From Zogoda he sent us to Camp Lion training base to take advanced training.

  • And when you say "we were in Peyama" and "we were called by Foday Sankoh", who are the "we"? Who are you talking about?

  • We, the junior commandos, the RUF fighters and some other officers with whom we were in Peyama, they called us - they called some of the officers from Peyama to go and take guerilla advanced training at Camp Lion at Joikoya.

  • Your Honour, our spelling for Joikoya will be J-O-I-K-U-Y-A.

  • Why is the witness shaking his head in disagreement, Mr Werner?

    THE WITNESS:

  • Mr Witness, how would you spell Joikoya?

  • J-O-I-K-O-Y-A. Not K-U. K-O-I - K-O-Y-A.

  • I also recall that I believe when TF1-362 testified this spelling was placed on the record.

  • I must say your recollection is quicker than mine, Mr Anyah, but we will note that. Thank you.

  • Now, Mr Witness, you said that you went to Zogoda first. How long did you stay in Zogoda before going to Joikoya?

  • How long did you spend in Zogoda?

  • We did not stay long there. We just went there and Foday Sankoh briefed us and sent us. We passed the night there and went to Joikoya for the advanced training.

  • And you talk about a Camp Lion. To be clear, where was Camp Lion situated?

  • It was in Joikoya Town.

  • And to your knowledge what is the distance between Joikoya Town and Zogoda?

  • Well, it was through the jungle. You would spend about - you would take about two to three hours walk, a normal walk, to Joikoya.

  • Now I believe you told us before that Zogoda was in the Kenema District. What about Joikoya, do you know in which district is Joikoya?

  • It too is in the Kenema District.

  • Now what happened to you when you arrived at Camp Lion?

  • Well, we underwent guerilla cadet training. We went there to be trained.

  • Now at that time when you undertook this training in Joikoya what was your rank?

  • I was a sergeant at that time.

  • Now again which kind of training was it at that time in Camp Lion in Joikoya?

  • Well, Foday Sankoh called it advanced guerilla cadet training.

  • And what did you learn there?

  • Well, we learnt a lot. He taught us official duties. The instructors who were at the base taught us official duties and then we learnt how to present ourselves as officers from the base. Those were some of the trainings we underwent.

  • Mr Werner, I am just a little uncertain as to the type of training he is describing. He says "advanced guerilla cadet". Is he saying "cadet", or something different?

  • Could you clarify that? Have you heard the observation? Could you clarify that. What did you mean cadet?

  • When we went to Zogoda Foday Sankoh told us that now we were going to train in advanced guerilla cadet training. That was when you graduate from the base.

  • Thank you, witness. I understand now. He is saying "cadet", C-A-D-E-T.

  • And, Mr Witness, again could you explain further what did you learn there in this training?

  • Well, we learnt about radio communications. They taught us how to use the radio in case you were a commander and you were at a station when your radio commander was not there how to receive a message and how to send a message, we were taught all of that, and also how to use the radio on the frequencies, the frequencies to tune. They taught us how to use the radio. They taught us also how to use a code and decoder.

  • And when you said that you learned how to receive a message, did you learn as well how to transcribe a message?

  • Transfer message.

  • What do you mean "transfer message"?

  • To send. You receive and send a message.

  • And how did you learn - what did you learn about that?

  • Well, they taught us - at the base they taught us how to receive a message. When a message comes in if your operator was not there, the way you should receive a message and the way such a message should be written down and if you too want to send a message, the way you should write it and how to send it and to whom you are going to send it and the steps you should take to send such a message. We were taught all of that.

  • And again who taught you that at that time in that training?

  • Well, it was Foday Sankoh himself who trained us how to use the radio, how to use the radio set.

  • And apart from Foday Sankoh who else were there as instructors in Camp Lion in Joikoya at that time?

  • Well, we had one woman who was called CO Monica. We also had Major Titus. We had another called Amuyepeh. Then we had another man called Junior Vandi and another called Pato-Pato, but there were many, those who were at the place, the instructors.

  • Some spelling, your Honours. Amuyepeh will be A-M-U-Y-E-P-A-Y:

  • Mr Witness, can you help us with the spelling of Amuyepeh?

  • It is A-M-U-Y-E-P-E-H.

  • Thank you, Mr Witness. So could you help us as well with the spelling of Pato-Pato?

  • P-A-T-O hyphen P-A-T-O.

  • And I believe that CO Monica is the correct spelling. The same for Junior Vandi.

  • And Titus? Was there a Titus? Regular Titus I presume.

  • Yes, could you spell for us Titus, Mr Witness?

  • Now concerning Monica, who was Monica, Mr Witness?

  • Well, we understood at the base that she was the training commander at the base at the time that we went there.

  • And later what, if anything, did you learn about CO Monica?

  • Well, until later she was still a commander at another training base in the Kailahun District.

  • Which training base?

  • Bunumbu Camp Lion training base.

  • And at what time was that?

  • Later during '98/'99.

  • Now you told us before about Special Forces, vanguards, junior commandos. To your knowledge to which group, if any, did CO Monica belong?

  • She was a vanguard.

  • Now you told us about a Junior Vandi. Who was Junior Vandi?

  • Junior Vandi was a Black Guard, but he was a junior commando.

  • Now you told us before about the distinction between directives and orders and instructions. What, if anything, did you learn in this advanced training about those words?

  • Well, it was from this advanced training that I understood the differences that a directive is a word that is the highest in command. Like the RUF where we were, Foday Sankoh was the highest in command. He used directives, but if he was not there CO Mohamed whom we called Zino, if Foday Sankoh was not there within the RUF territory, if it was CO Mohamed who had taken over as second in command he had the right to use directive. But apart from that all other commands were to used order or instructions.

  • Now, during this advanced training in Joikoya, Camp Lion, what if anything were you told about the way the RUF was structured militarily?

  • So what did you learn about that?

  • Well, they taught us about the military structure, how a brigade, battalions, companies, platoons, squad and a team - those were the set-ups that we were taught.

  • And at that time during that training what, if anything, did you learn about how many fighters would comprise a brigade?

  • Well, during that training I learnt that a brigade comprised 4,000 manpower. 4,000 guerilla manpower.

  • What, if anything, did you learn about how many battalions would form a brigade during that training?

  • I also learnt that four battalions make up a brigade.

  • And what did you learn about battalions? How were they organised?

  • Well, a battalion too comprised about 900 --

  • Your Honour, can he repeat the figure?

  • Pause, Mr Witness. Mr Interpreter?

  • Can he repeat the last answer that had to do with the figure.

  • Mr Witness, the interpreter needs you to repeat the figures you gave. You've said, "Well, a battalion too comprised about ..." and give us the figure clearly, please.

  • A battalion comprised 999, but they rounded it up to 1,000 manpower. That is why four battalions makes a brigade. In that case 4,000 men make a brigade, because it was rounded up.

  • Now what did you learn - what did you learn about companies?

  • The company too, there were four companies that make up a battalion and each company comprised of 250 manpower. That was what comprised a company. So four companies put together make a battalion.

  • And finally you told us about platoons. What did you learn about platoons in this advanced training?

  • A platoon too the instructors told us that 62 manpower, 62 guerilla manpower, make a platoon and four platoons make a company.

  • And you told us as well about squads. What did you learn about squads?

  • A squad too is a group that comprised 15 manpower. There are four squads that make a platoon.

  • Now, Mr Witness, during the time of your first training in Pendembu I asked you about any ideology training that you will have received at that time and you said that you didn't receive any ideology training, but you received the training later. What, if anything, were you learning about ideology in this advanced training in Joikoya in Camp Lion?

  • They taught us about ideology and at that time it was Major Titus, whom we called Major T, who was the one who taught us ideology. He taught us how you, as an officer, should comport yourself to your subordinates, or to civilians. That is you should not be rough, you should be gentle. They taught us the orders that the military carries. If they made you a leader, that you a leader - there were general orders that were in the ideology which they taught us, that you as a commander should not be too hard, or too soft. Those were some of the ideologies that we were taught at the base.

  • Now, Mr Witness, how long did this training last?

  • Well, this training lasted for about a month or so, yes.

  • And what happened to you after that training?

  • After the training, when we graduated I was promoted to second lieutenant and I was reassigned to the Kenema bypass. That was where I went as a fighter and also assisting as an adjutant.

  • And when you say Kenema bypass, where is Kenema bypass?

  • It is in the Kenema District.

  • How far is Kenema bypass from Zogoda, if you know?

  • Well, Kenema bypass too was around a two to three hours walk, normal walk, at your own time. You would get there within three hours, because it is in the jungle. It was not on the main road.

  • And to whom, if anyone, did you report when you went to Kenema bypass?

  • Well, I was reporting to my commander whom we called CO Weaver. Weaver-J. He was the commander who was there.

  • And would you be able to spell the name of that commander for us, Mr Witness?

  • W-E-A-V-E-R, Weaver-J.

  • And who was CO Weaver-J?

  • He was a junior commando.

  • And when did you arrive in Kenema bypass? Can you remember the year?

  • Can you remember the month?

  • And how long did you stay with CO Weaver-J in Kenema bypass?

  • Well, I stayed there for some time, maybe for some few months with CO Weaver.

  • Now, what happened to you, Mr Witness, after your time with CO Weaver-J in Kenema bypass?

  • Well, Foday Sankoh changed my assignment again. He sent me back to the Peyama jungle. That was where I went.

  • And you told us before that in the Peyama jungle CO Papa was in charge. Now, when you went back to the Peyama jungle who, if anyone, was in charge at that time?

  • When I went back to the Peyama jungle it was Sam Bockarie who was the commander in the Peyama jungle.

  • And when you arrived in the Peyama jungle back, what did you do there?

  • Well, I was there again as fighter and assisting at the same time as adjutant.

  • And assisting whom?

  • He is CO Mosquito, CO Sam Bockarie, Sam Bockarie's adjutant, the one whom I met at Peyama jungle. I was assisting him there.

  • Exactly who was he assisting? Mosquito, or Mosquito's adjutant?

  • Mr Witness, who were you assisting when you went back to Peyama?

  • Mosquito's adjutant. He was the one I was assisting, the adjutant who was in the jungle, because he was reporting to Mosquito.

  • Do you remember his name?

  • He had a nickname I have forgotten now, no.

  • Now, Mr Witness, by that time you told us that you had been acting as adjutant early on in Bunumbu under Morris Kallon and then you were helping in administrative affairs in the Kailahun jungle with CO Mohamed, and then you went to Peyama where you were helping in administrative affairs, and Kenema bypass where you were helping in administrative affairs, and now back in Peyama where you were helping in administrative affairs. By that time, which signatures did you see in the paper that you saw during all your time as assistant in administrative affairs?

  • Objection. The question is vague. We are not sure which of the various locations he is referring to and the various capacities as an adjutant or clerk and the administrative work and, second, it is a leading question in respect to the last location, his last return to Peyama.

  • I agree with that, Mr Werner. It is far too wide and misleading.

  • I will rephrase. I will rephrase:

  • Now, Mr Witness, when you were in Kailahun jungle with CO Mohamed, which signature, if any, did you see at that time in RUF documents?

  • That is equally vague. I mean what document are you talking about? Where did these documents come from?

  • I will rephrase, your Honours:

  • The time you were working with CO Mohamed in the Kailahun jungle, which document, if any, did you see during the time you were helping in administrative affairs there?

  • I used to see radio messages that CO Mohamed received and letters too that he received from Foday Sankoh.

  • And what, if anything, did you see on those messages?

  • Well, these were messages he gave to him. He gave him directives how he should go about things and if he needed to see him he should call him, maybe a message to report to his location, or how to go about things.

  • Now, when you were in Peyama, which document, if any, did you see during the time you were helping in administrative affairs? Peyama under CO Papa.

  • Radio messages. I saw radio messages that came from Foday Sankoh direct to Peyama jungle to him, then radio messages from the other jungles that they used to send to him, CO Papa. Those too I used to see.

  • And when you were in Kenema bypass working with CO Weaver-J, which document, if any, did you see at that time?

  • I saw letters from Foday Sankoh, as well as radio messages from Foday Sankoh, to CO Weaver-J at the Kenema bypass.

  • Now, after your training you said that you went to work with Sam Bockarie in Peyama. Now, during that time which document, if any, did you see when you were working helping in administrative affairs with Bockarie in Peyama?

  • Well, radio messages used to come to Sam Bockarie at Peyama. At that time Foday Sankoh was in Zogoda. When he will give him instructions/directives as to how he should go into offensive, because Peyama was near Tongo, we were near Tongo, how to go on offensives in that area, or if people were coming from his location he, Foday Sankoh, and they were coming towards Peyama location, he would send radio message to him, Sam Bockarie, that he should receive so and so people, that they were coming from his location and that they were coming to pass through maybe to go to Kailahun jungle, or to go to some other jungle. We received those messages.

  • During your time in Peyama what other documents, if anything, did you see?

  • Well, while we were at Peyama, at one time Foday Sankoh sent a message to Sam Bockarie that he should receive Captain Ben. Captain Ben and his troops they were coming from Zogoda and to come to him. They were on a mission to Kono jungle and when they came it was in Peyama that they stopped. That is where they reorg'ed and the following day they moved and they went on the jungle in Kono.

  • That is where they did what, Mr Interpreter?

  • Your Honour, the witness used "reorg'ed". I think it is a military term for reorganised.

  • Mr Witness, could you help us with that? Did you say that that is where they had to reorganise, the following day they moved? Is that what you said?

  • Exactly. That is what he said. That is what I meant by reorg'ed. They will stop at our place and they organised themselves and they will go.

  • Now, you told us earlier about a Captain Ben. Is he the same Captain Ben that you mentioned earlier?

  • And again, to your understanding, what was this mission to Kono at that time?

  • It was to go and capture Gaya and Yengema while I was in Peyama. The radio message that we received from Foday Sankoh - that Sam Bockarie received, he said Captain Ben was coming with manpower to go and capture, to go and attack Gaya and Yengema.

  • Now, Gaya, how would you spell Gaya, Mr Witness?

  • G-A-Y-A.

  • And where is Gaya?

  • It is in the Kono District.

  • When that happened, when did you receive that message?

  • When we were in the Peyama jungle after I had come from Kenema bypass, early 1996. That was the time.

  • Now what else, if anything, did you learn about the operation on Gaya with Captain Ben?

  • Well, when they came they organised themselves and some other manpower came from Kailahun and they left. They went and attacked Gaya and Yengema and later we heard that they had captured Gaya and Yengema, that's what we heard from them, and they were there for some time.

  • And when you say they had captured Gaya and Yengema, who are you talking about?

  • Captain Ben and the forces that went with him, the RUF that went with Captain Ben.

  • And what else, if anything, did you learn about that attack?

  • Well, while we were in Peyama again we saw heavy manpower coming from Kono again. They had materials, ammunition, bombs, weapons on their heads and they said those were the materials they had captured from Gaya and they came to Peyama and Peyama was a point in the jungle if you --

  • Your Honours, can the witness repeat this.

  • Pause, please, Mr Witness. The interpreter needs to catch up with you. Please repeat that part of you have your answer. You have said, "They came to Peyama and Peyama was a point in the jungle". Now continue from there, please.

  • Peyama was a point in the jungle and I will say it was a crossroad. If you come from the east you would have to come to Peyama before you would go wherever you want to go, or if you are coming from Kono you must have to pass through Peyama, or if you are going to Kailahun you must pass through there, or if you are going to Zogoda you must pass through there. That was the main junction for the jungles that were in there.

  • And what happened as a result of the fact that it was a main junction?

  • Because all the manpower that came from all the various jungles went through Peyama, we saw them. At times they would even pass the night there, they will rest there and in the morning - or maybe they will spend two days there. If they were going a far distance maybe they will spend two days. Like, for example, the north jungle that was a far distance. When they come from the Kailahun jungle they will spend two days at Peyama and then they will move, or from Kono they will pass the night and they will go to Zogoda. That was why I said that was the main junction.

  • Now, Mr Witness, again about those attacks against Gaya and Peyama, were these attacks successful?

  • Yes, sir, it was successful.

  • I think counsel meant Gaya and Yengema, not Peyama.

  • Sorry, I apologise. Gaya and Yengema.

  • So, Mr Witness, just to clarify that point, to your knowledge at that time which towns were attacked?

  • It was Gaya and Yengema. They went and attacked there.

  • And how did you learn that the attacks against Gaya and Yengema were successful?

  • After the attack the manpower that we saw returned with the captured materials, the ammunition, the rockets, the weapons, those heavy weapons. The manpower that brought them and a lot of other items, they themselves were the ones who said they had captured Gaya and Yengema and they were under complete control. They said RUF was now there.

  • And, Mr Witness, what, if anything, did these men tell you about what happened after the takeover of Gaya and Yengema, if anything?

  • Well, they told me, or they told us - the men who came told us that they had captured Gaya and Yengema and they had put them under complete control and they had burnt the entire town down. That was what they said.

  • And when you said they said they had burned the entire town down, which town are you talking about?

  • Gaya and Yengema where they attacked.

  • Mr Werner, I am sorry to interrupt at this stage, but this place Gaya, is it the same as Geiya that is referred to in the indictment, or are they different places?

  • I think the witness gave the spelling which is not the same spelling that I am seeing here.

  • I know there are sometimes different spellings, but I just want to establish if it is the one that is referred to in the indictment or not?

  • Let me consult. It is not the same place:

  • Now, Mr Witness, can you just - I just would observe for the record that the witness gave the spelling G-A-Y-A, Gaya. It had been spelt G-E-I-Y-A on the LiveNote. I am sure the witness would have corrected me if I had misspelled it.

  • With respect, I do recall this name being spelt before during the course of the proceedings. I just can't remember by which witness and I think the spelling was more cognizant with the one in the indictment, G-E-I-Y-A.

  • That is precisely why I asked, Mr Werner, and usually a witness is able to tell us if a place is capable of more than one spelling. My concern is purely with the words in the indictment, the locations in the indictment, and you have the opportunity.

  • Yes, your Honours, most of the time they are spelled phonetically and then as a result there are different spellings, but I will clarify with the witness if he is aware of any the other spelling for that place:

  • Mr Witness, this place that you have spelled G-A-Y-A, Gaya, to your knowledge are there other spellings for that location?

  • I am not sure. I am not sure, because I know that Gaya is G-A-Y-A. I am not sure if there is another spelling for it except if there is another town, or maybe they have similar pronunciation and maybe they can be spelt the same way, but that is how I saw it being spelt and that's the way I spell it, G-A-Y-A.

  • Perhaps a location like a chiefdom might help?

  • Yes, your Honour:

  • Now, Mr Witness, do you know - so you told us - again, in which district is Gaya situated/located?

  • It is in the Kono District.

  • And to your knowledge in which chiefdom is Gaya situated?

  • I don't know the name of the chiefdom.

  • Your Honour, I would like an exhibit at that stage to be placed in front of the witness. It is an exhibit which was not last week provided with the binders, but we gave copies I think at the end of last week and my understanding is that during the break it has been placed in your binders under tab 25 and I am sorry, your Honour, so we --

  • Is this a map binder, Mr Werner, because there is two --

  • No, it's not the map binders. It's not the map binders. It is in your binders of exhibits for the witness and the --

  • Is this the week 15 binder?

  • It is week 18, I am told.

  • Where in the evidence does this arise?

  • Sorry, it's my bad eyesight.

  • Mr Werner, where in the evidence does this arise?

  • Sorry, I did not understand your question.

  • Where in the evidence does this arise? I am trying to see where you have referred to this document before? Are you just showing the witness a document?

  • I would be grateful to know the exhibit number. I still don't know.

  • I am coming to that.

  • I think that's where the confusion arises, Mr Anyah. Mr Werner has referred to an exhibit. In fact the document has not been exhibited yet.

  • It's my mistake absolutely. It's my mistake. I apologise for that. I apologise for that.

    It is a document which would be in your binder, week 18 behind tab 25 and there is a P number. It is several pages, different pages. It goes from P00008220 to 00008225 and we will ask that the page P00008221 be shown to the witness.

  • Yes, Mr Anyah, you are on your feet.

  • I am looking at the document and if it is going to be published to the witness and then he is asked questions about it I suspect there is a procedural issue there. I mean the witness has to have - there has to be some foundation that the witness knows something about this document, rather than the document leading him as to its contents.

  • Mr Werner, your reply?

  • This witness has been telling us a lot of things. He told us that in the course of his duties as working in the administration of the RUF he saw messages and he saw messages coming from Foday Sankoh and again I am not sure we can have this conversation in front of the witness because --

  • All I will say is this: That having glanced - you are intending to put 8221 to the witness, is that correct?

  • Yes, your Honour, 8221.

  • Well, some of the names on that page have not been mentioned by the witness therefore there should be foundation for them.

  • Your Honour, I am only going to refer to the first - I am going to ask no questions except for the first five lines at the top of this exhibit. Nothing else.

  • Well, look at the date on it. I don't recall evidence relating to that year.

  • Yes, I recall evidence to these two places, to the two persons who are named in that message and to the content of that message. So there was evidence about everything, plus the fact that the witness was so during the time of his duties as administrative officer messages and format of messages. So he spoke at length about the content of this document and our submission would be that the content of this document will corroborate exactly what the witness has been saying so far.

  • Mr Anyah, you are on your feet.

  • I have looked at the document, I have looked at the section counsel has referred us to and I still register my objection. If you look at the date in the relevant portion counsel has referred us to, it is different from the date that the witness has given in evidence regarding the occurrence of these particular events. It also differs from the date or the period of time during which the witness claims to have been in this particular location significantly.

  • Look, the practical way to look at this thing is surely you were going to lay some foundation, weren't you, Mr Werner? Is that right, Mr Werner?

  • In our submission --