Thank you, Madam President:

Mr Witness, I would like to revisit some of the issues we touched on yesterday. There are a few matters that we seek clarification about. I would like first to go back to the document in tab number 13, which delineates the meetings you had with the Office of the Prosecution before you took the witness stand.

Yesterday I asked you about your first meeting with the members of the Office of the Prosecutor and you described a meeting in Kailahun where you were met by Chuck Kolot, somebody you know as Magnus and somebody whom you later confirmed as being named Koroma. Do you remember saying that, Mr Witness?

Yes, sir.

Now, when you look at this chart the first dated meeting, or at least the meeting for which documents have been provided, indicates the date of 7 July 2006. Do you see that in row number 1?

Document provided by who?

By the Office of the Prosecutor that indicates dates on which they met with you. The first provided document says they first met with you on 7 July 2006. Do you see that in line number 1?

Yes, sir.

When you testified yesterday you made passing reference to being given transport and food. You said, "They gave me transport and food to go to Freetown." Do you recall saying that?

They gave me transport. That was money to be used as transport to travel to Freetown, yes.

That is what I was seeking to ascertain. Now, how much did they give you when you first met with them?

I think 120,000 leones.

120,000 leones?

Yes, sir.

You were not employed at that time, yes?

Not, I was not.

Can we go to tab 11, page 1. Mr Witness, the Office of the Prosecutor keeps records of amounts it gives to witnesses for various reasons and these records have a number that allow us to know that they pertain to you. There is a number written on these records, at the top left-hand corner, that indicates that these records pertain to you. It says TF1-516. Now, the first entry in this book pertains to the date of 7 July 2006. It indicates that the sum of 130,000 leones was given to you and the reason being travel to Freetown, issued by Chuck Kolot and the category being transport. Do you see that, Mr Witness?

Yes, sir.

Would it be fair to say, on the basis of these records, the amount you were given is more appropriately stated as 130,000 leones?

I was also given money to be used as - I mean for food. I stated that.

I didn't ask you that. You see an amount that differs from the one you just told us. Is it right that the total amount given to you on that day was 130,000 leones?

That was the total amount, but I was given 120 which they said was to be used as transport.

And the other - I am sorry, go ahead, Mr Witness.

And I told them, okay, I am travelling, but I cannot just move like that. I was given other money to be used on the road and they asked me how many days I was going to take on the road to travel. I told them just a day.

And what is the other amount they gave you in addition to the 120,000?

They were meeting me intermittently and so I cannot really recall the amount of money given to me at a particular date we met.

But you just recalled 120,000 on 7 July?

The very first day we met.

Exactly.

Yes.

And that would be a day you would not easily forget what happened, right?

I am a human being. I am liable to making a - I can forget the date.

Is it every day that three men plus someone else you know, Zedman, show up in a car and pick you up and take you somewhere else? It is every day that such events happen that you will forget?

No.

And you just told us you made a distinction between transport money and an additional amount given to you. We want to know what the additional amount is. Can you tell us, please?

For transport I was given 120,000 leones. For food I was given 10,000 and besides that they told me they had taken my time, I was given I think another 40,000 leones.

You were given a total of 170,000 leones on 7 July 2007 - 2006, right?

If we calculated 120,000 leones for transport, 10,000 leones for food and 40,000 leones which they said they have spent - they have taken my time talking to me, that means 120, plus 10, plus 40 is 170.

Well, we apparently do not have records of 170 and I would just respectfully seek some indication some time after the proceedings from my colleagues.

Mr Anyah, do bear in mind the witness has said each time, I think.

Yes, Madam President:

Witness, that was a lot of money when you received it, was it not?

I had received money greater than that before.

That was not my question. It's a simple question. Was that in your view at that time a significant amount of money?

To travel, yes.

What is the average cost of transportation from Kailahun to Freetown? Let's talk about today, first of all. If you were going from Kailahun to Freetown today, 11 April 2008, how much would it cost on average?

From where I am?

No, if someone in Kailahun was going to Freetown today, how much would it cost?

Travelling to Freetown you are talking about two different means. We had the vehicle and the motorbike. And during the rainy seasons in Kailahun the road network is so bad that you find it difficult to go through. In fact sometimes people spent two days in --

Mr Witness --

Yes, sir.

-- it might be a difficult trip, but we just need to know the amount. How much would it cost regardless of the degree of difficulty?

If you are taking a motorbike you talk about 70 or 80,000 leones, a motorbike from Kailahun to Kenema.

And if you are going by vehicle, is that the second option you said?

Kailahun, it would be - from Kailahun to Kenema by vehicle is negotiable. Sometimes 30,000, 35,000.

Wasn't the question from Kailahun to Freetown? Wasn't that the question you asked?

Yes, Justice Sebutinde.

So, Mr Witness, how would you get from Kailahun to Freetown if it's the rainy season, how would you get there?

I would travel by motorbike which is safer.

All the way to Freetown what would it cost you today?

If I am travelling by motorbike it is negotiable. You seem sometimes pay 70,000 or 75 to Kenema and from Kenema to Bo is 5,000. It was 5,000. And from Bo to Freetown 20,000, 25,000.

Let's take the lower figures and add them up. You said from Kailahun to Kenema between 70 and 80,000. Let us take 70,000 in that case. From Kenema to Bo you said about 5,000. That makes it 75,000. From Bo to Freetown you said either 20 or 25,000. Let's take 20,000. That makes it 100,000. Would it be fair to say that the average cost of transportation using a motorbike in the rainy season from Kailahun to Freetown today would be 100,000 leones, Mr Witness?

It is not anything fixed. It is negotiable. More especially travelling --

Mr Witness, we know it is negotiable, but you have given us ranges, possibly price ranges, and we have added them up and I am asking you if on the basis of the information you have provided it would be fair to say that the average cost going by motorbike during the rainy season from Kailahun to Freetown, the aggregate amount would be approximately 100,000 leones. Do you agree?

Approximate, yes, sir.

In 2006 would you agree that it was probably cheaper to go from Kailahun to Freetown?

No. In fact there had been some kind of a reduction regarding the - reduction in price regarding the road network. Before it was worse than now - than it is now.

So you are saying it was more expensive in 2006 than now to go from Kailahun to Freetown. Is that your evidence?

Yes, we almost had a cut off even.

What would the price have been on average from Kailahun to Freetown in July 2006?

I can remember travelling from Kailahun to Kenema paying the sum of 80,000 leones to a motorbike rider.

When you went from Kailahun to Freetown to meet with the Office of the Prosecutor on 7 July 2006 how much did you pay?

I was given 120,000 leones as transport and 10,000 leones as food and I used the money on the road to travel. That was what I was given.

How much did you pay for transport, Mr Witness? Not how much you were given. How much did you actually pay?

105,000.

And out of your transport money you were left with 15,000, right?

Yes.

And then you also had the additional 40,000 that was given to you, right?

Yes, sir.

Then you had your additional 10,000 for food, true?

Let me count. I have to be a little bit mathematical here. 105,000 for transport, then 12,000 leones was used on the road for food and water, because when we are travelling we buy mineral water and a bottle - two bottle of that, each was sold at the cost of 3,000 so I'm using 5,000 leones on the road. So, 85 - 80,000, 85,000, 105,000, plus 10. 115,000. I used 115,000. 115,000.

You used 115,000 out of 170,000, right?

No, the 40,000 leones which was given to me initially was not to be used as transport.

I am not asking you for what it was to be used. I am asking you how much you spent in total. We have established how much was given to you and you have just said you spent 105,000 on transport. First you said you spent 12,000 on something else, I think you said food?

Yes.

And water.

And water, which would bring the total to 117,000. You then changed that figure to 115,000. So we know now that you spent somewhere between 115 and 117,000 on transport, food and water. The total amount given to you, Mr Witness, was 170,000. If you deduct 170,000 from 117,000 you would get 53,000 left. Did you have about 53,000 left, Mr Witness?

The 53,000 is --

52,000, I see Justice Sebutinde --

You subtract 12,000 and the 40,000 leones was not given to me for travelling.

Yes, Mr Bangura?

Your Honours, a point of objection here. My learned friend has not established that the witness was given all of this money upfront to suggest now to the witness that after deducting the amount which the witness said he used he would be left with the balance that has been suggested to him.

There is some validity in that, Mr Anyah, because you yourself put to the witness that the records show he received 130,000.

He confirmed that amount and he did indicate that he also was given 40,000.

The 40,000 leones I spoke of that was given to me was not to be used as transport. In fact I made suggestion to them that --

Just pause, Mr Witness. We're talking about another issue.

I can ask a question and clarify if the Chamber wishes, but --

Perhaps in the circumstances.

If I could say, Mr Anyah, I think you were quite justified in your questions because this witness clearly said he was given that money. Nothing he said could lead to the inference that somebody else may have received the money on his behalf and surely if that were the case he is capable of saying so, instead of blankly telling you that he received the money. But, in any event, if you are going to put the issue beyond doubt, please go ahead.

Mr Witness, the 40,000 to which you have just referred, that was given to you, right?

Yes.

So the total amount given to you was 170,000 leones, yes?

Yes.

And you used 105 of that for transport, true?

Yes.

And you used between 10 and 12,000 for food and water, yes?

Yes.

That brings the total to somewhere between 115 and 117,000, true?

Yes.

When you minus 170,000 or when you minus 115,000 from 170,000 the balance would be 55,000, yes?

Yes.

And if you were to minus 117,000 from 170,000 the balance, as Justice Sebutinde noted, would be 52,000, yes?

No, 53,000.

Well, there is reasons why some of us are lawyers and not in other fields:

Mr Witness, let me ask you this: You were left with approximately 50,000 leones after you paid for transport, food and water. Would that be fair to say?

I don't work mathematics like that.

You are in the sciences, Mr Witness?

That is true.

Yes.

But to maintain accuracy, in fact before now I operated under a degree and that was SAD, S-A-D, it is one Security, Accuracy and Discipline. So it appears you are taking me away from that. I must be given ample time to do mathematical work - to do the figure work.

Do you suggest that when you are testifying in Court you apply these principles of SAD? Is that your suggestion?

I said before now, before this time. You are just calculating, adding numbers, subtracting numbers.

Mr Witness, you are a schoolteacher, right?

Yes.

You have told us you studied the sciences, right?

Yes.

And a few days ago you had something in front of you on which you were writing numbers, correct?

Yes.

Now, you like to write numbers - well, I withdraw that. The figures I am quoting to you are objective figures. There is nothing tricky about them, correct?

Those are not - they are objective?

Let's save a bit of time here. Mr Witness, how long do you want to go through the mathematics of deducting 117,000 from 170,000? How long would you like?

It will be 53. 53.

Thank you, Mr Witness. That was a lot of money that you had left over, wasn't it?

Yes.

Indeed, if we were to turn to page 5 of the same tab, tab 11 - Madam Court Officer, do not put these on the overhead. Thank you. Line number 17, the top of the page. Mr Witness, this is another entry of an amount that was given to you by the Office of the Prosecutor and it pertains to the date of Wednesday 28th. The witness is seeking some assistance.

Sorry, Mr Witness, did you --

The point he is reading, I want to see it.

Oh, I see. Please refer the witness again to the --

It is tab number 11, page 5, which is paginated at the bottom right-hand corner.

Mr Anyah, what objection do you have to this being displayed in public?

I am just treading carefully. I am not sure. I see some things are redacted, but so as not to take any chances, but let me look through and I am sure counsel opposite will correct me if there is anything here that - I don't see why these cannot be displayed, unless there is an objection from counsel opposite.

No, we do not see any reason why it cannot be, your Honour.

Thank you, Justice Sebutinde:

Mr Witness, we are now on page 5. At the top of the page is entry number 17 and it is the records for payments made to you on Wednesday, 28 November 2007. It says, "Reason: Lost wages for 12 days of prepping while in Freetown." The total amount, 120,000 leones. Do you see that, Mr Witness?

Yes, I do.

Did you receive that money on 28 November 2007, less than six months ago?

Yes.

The indication there was that for 12 days worth of work, the wages paid that you lost, 120,000 leones was sufficient to compensate you for that, yes?

That was --

Yes or no?

It was not sufficient, but it was something spelt out to me and I hadn't any objective to kick against it.

It was not sufficient. That is your evidence. I am putting it to you that you are lying when you say that, Mr Witness. What do you say?

When I came to Freetown the person who was dealing with the monetary issues stated that for every single day they would pay 10,000 leones as lost wages, but I stated, "Oh, when I am staying on my own I know best what to do." In fact, I decided not to come to that place any longer, because I had some other work to be done and even now I am seated here there is something which I am supposed to be doing at home. I am still here. That was what I received and they prepared the document and I had to sign it.

Are you saying that while you have been testifying here you have not received any compensation? Is that what you are saying? If you flip over to the last page, Mr Witness, it shows as recently as ten days ago, or last month, you were being given money.

Yes, sir, that was what I received as means to travel. They told me when you are travelling they give you what they call allowance. I have my own family. I cannot just leave them like that.

We are not asking you to leave your family like that, by no means. I am simply trying to establish - I am comparing the amounts on page 5, line 17, of 120,000 leones to what you received when you first met the Office of the Prosecutor, which is on page 1, line 1, and you have told us it now adds up to 170,000 leones. That money that you received in July of 2006 was an exceptionally large amount for you, was it not, Mr Witness?

It was not exceptionally large. I had received money more than that before.

But at the time you were not working and that money made a difference to you, did it not?

It never, because what made me state that I was not working, they asked me to state my present occupation at that time and I stated I was not working.

You are now saying that when they write, in tab number 1, "Just completed secondary school not doing any work" --

Yes.

-- you thought they were referring to your occupation. Is that what you are saying?

Yes, they asked me to state my occupation, what I was doing at that time. I said, "No, I just completed secondary school. I am not employed."

And it was the case, you have confirmed that this morning, you were not working, true?

Indeed I was not at that time we met.

And the issue deals with how important, or significant 170,000 leones was to you when they gave it to you. Do you still maintain that it was not a significant amount of money to you?

The 120 which they gave me was sufficient to facilitate my movement from Kailahun to Freetown.

How much would you make if you worked for 12 days, since you dispute the other amount I have read of 120,000?

I am not - I was not employed at that time. I was not employed. So there was no specific amount of money which I was getting on a daily basis. If I had told you I was getting 40,000 leones, or 50,000 leones per day, I may not be speaking the truth.

When you left Kailahun to go to Freetown, did you leave with the expectation that you would get more money once you got to Freetown?

Money was not my - to get money was not my intention travelling, otherwise I would have if demanded more than a million before travelling.

You told us yesterday, Mr Witness, that you met with the Office of the Prosecutor in three locations: In Bo, in Kailahun and in Freetown, yes?

Yes. First in Kailahun, the second was - Kailahun, Freetown and Bo.

Okay.

And later on Kailahun - I mean Freetown.

I asked you a question in response to an answer you had given about staying at the guesthouse and spending a week in Freetown. I asked you when that took place and you said during the later part of the year 2006. Do you recall saying that?

Really this date, date --

If you cannot recall you can say you can't recall.

Okay, I cannot recall the exact date.

Well, my question has to do with whether you recall saying something yesterday, which is you told us yesterday that the week period that you referred to as having spent in Freetown, meeting with the Office of the Prosecutor, took place in late 2000 and - well, you didn't give the year. Well, you said late 2006 if I recall, the same year you met them for the first time.

Yes.

Okay, thank you. If you look at the entries in tab 13, the one that delineates the dates of meetings with the Office of the Prosecutor, you see from lines 2 through 5 the dates 17 July, 18 July, 19 July and 20 July. Do you see those dates, Mr Witness?

Yes.

Those are four consecutive dates on which you met with the Office of the Prosecutor, right?

Yes.

If you open to tab 2, to the interview notes for those dates, at the top of the page, tab 2, page 1, we went through this yesterday, it says interview of you at OTP interview room by Kolot and Lamin. Do you see that, Mr Witness, at the top of the page? I am referring to tab 2 at the top of the page and this should not be displayed.

Yes, sir.

I am trying to hone in on the location of this interview. This tab contains records of interviews between you and the Office of the Prosecutor from the dates 17 July 2006 through 20 July 2006. The location of the interview, as is said by this page, page 1, is that it took place at the OTP interview room and it was conducted by Kolot and Lamin. Do you see that, Mr Witness?

Yes.

Do you agree with that, Mr Witness?

Yes, sir.

So for these four dates you met with the Office of the Prosecutor in Freetown, yes?

Yes.

It was during this period, this week period, that you were housed at a guesthouse, yes?

Yes.

Now, who paid for your stay at that guesthouse?

The Office of the Prosecutor.

Who paid for your transportation from the guesthouse to the Special Court premises?

The same people.

Do you know how much it cost on average to stay in that guesthouse for one night during the period when you stayed there?

I was only taken to the guesthouse.

So after you met them the first time, 7 July, and you get 170,000, the next time you meet them you spend about a week with them and you are housed at a guesthouse in Freetown, correct?

Yes.

And they pay for all the expenses, true?

Yes, that is true.

And you were not employed at this time, yes?

Yes.

Thank you, Mr Witness. One more thing to revisit from yesterday, that same MFI-17. Mr Witness, this is your operational book that we discussed yesterday. Now I first of all will draw your attention to the last page, the very last page of the book, and, Mr Witness, you can focus your attention to the back cover page where it has a multiplication - well, it has weights and measures. The ERN number for that page is 00019193, yes?

Yes.

Do you see at the bottom there it says, "Produced specially for Koussa Stores Monrovia, Liberia." Do you see that, Mr Witness, at the back of the book?

Yes.

Did you buy this book in Liberia? You have told us you were in Kailahun - in Buedu when some of the messages were entered into it. I want to know where you bought the book?

I was not buying books. I was only supplied books.

That's fair enough. Where did you get the book from?

These books --

Mr Witness - sorry, go ahead?

Books were supplied to us by the commanders.

Are you saying this book was supplied to you by the RUF commanders? Recall now you said --

Yes.

Recall now you told us you were sent away with nothing, no supplies, no paper, no pen. You recall that, Mr Witness?

I said at some time during the jungle we went without even papers, we went without pen. There was nowhere to buy these things except when conditions improved we had business taking place in Dawa Custom. At that time we were supplied with materials, exercise books.

You didn't say that in your direct examination. You didn't say things improved later on, did you?

I said sometimes we went out of stationery, even.

You said you had essentially no writing implements, Mr Witness. That's what you said?

I am coming from war and during the war the kind of situation we experienced is quite different from what we are seeing today.

I am not asking you to compare the war and now, because this book has nothing to do with being bought or given to you now. We are talking about the war period. You told us on direct examination you essentially were given no writing implements as a radio communicator or operator by the RUF and you had to fend for yourself. Now you are telling us today within the span of the same week that these supplies - this book was part of supplies that were given to you?

Not supplies. I said this was given to me by the commander. I reported to him that there was nothing in the station and that was his responsibility at that moment, otherwise there was not going to be any kind of operation.

Which commander gave you that book?

I cannot remember anyway.

Did he give it to you in Sierra Leone? Where were you when you got that book, Mr Witness?

Let me --

Two questions. One at a time, please, Mr Anyah. The first question, Mr Witness, is did he give it to you in Sierra Leone? Did you understand the question, Mr Witness?

Yes, let me just think quietly. I think this was in Sierra Leone.

He gave it to you in Sierra Leone?

In Sierra Leone.

And when did he give it to you? What year?

I cannot recall the exact year.

During examination-in-chief when Mr Bangura was asking you questions, that was when you mentioned this process of Rebecca transferring information from a prior operational book of yours into this book. Do you recall that, Mr Witness?

Yes.

And we went over that yesterday again, right?

Yes.

When you met with the Office of the Prosecution for the first ten times, starting on 17 July through October - 17 July 2006 through 9 October 2007, it's on tab 13, lines 1 through 10, you never mentioned Rebecca to them, did you?

I did not.

Mr Witness, indeed at no time - and Mr Bangura will correct me if I am wrong - have you explained to them or told them before you said it in Court today - I mean before you said it in Court this week - about the transfer of information from one book to another by someone named Rebecca; true or false?

About the communication note.

That's not my question. You told us a lady named Rebecca transferred information of yours from one book to this book and I am putting it to you at no time before you said that in Court did you tell the Office of the Prosecutor; true or false?

I was never asked to state the transfer of this signal note into any book.

They did not ask you. My question is you did not tell them; true or false?

I did not.

Thank you. And that is 20 meetings you never mentioned it, yes?

And I was not even asked to explain how this - I mean this note was recorded in this book. They asked me about this book. I said, "Yes, this book was mine." They said, "Do you have any idea about these messages?" I said, "Yes, I received these messages at a certain time and they were recorded and later on transferred to these pages they are." I explained there one to Kolot the very first day we met and to Chris in the Special Court in Freetown.

I am hesitant to make a comment about what is on the witness's table since I made a comment previously. I do see a clock and I am not sure if it is a permanent fixture there or what it is.

I think it has been there for a long time.

Okay.

Mr Bangura, I have noticed something from the rear which I thought might be a clock. Could you assist us?

Your Honour, it's a clock.

I can't see for certain what it is, but it looks like a clock, your Honour.

It has been there for months.

As Madam President has noted, it has been there for quite a while through the testimonies of several witnesses in this trial.

It's new to me. I usually sit elsewhere.

Madam President, it is a clock and it is the only thing I can see from where I am sitting in the witness stand.

I have noticed it for quite a long time. It is not causing you concern, Mr Anyah?

No, I found the object curious and I thought I would enquire further.

Please proceed, Mr Anyah.

Mr Witness, you had several opportunities to mention this issue about this book being transferred by Rebecca to the Office of the Prosecution, did you not?

Yes, I did.

Indeed, if we go to, the first place, tab 2, page 16, the ERN --

This is tab 2 of the Prosecution bundle?

I am sorry, Madam President, it is of the Defence bundle.

The Defence bundle?

Yes. Sorry, Justice Sebutinde:

The ERN number ends in 2029. An entire half of this page, or close to a half of it from where it says in the middle in bold letters "Refer to composition book made as exhibit and stamped on front page in red ink", from that portion all the way down deals with this book and you indicate what is on page 9181. You indicate that - well, let me read this part to you so we can be sure of it: "Witness acknowledges the notebook as his. He tore out some pages which he felt were unimportant."

Mr Anyah, perhaps we could avoid the names. Since we are all looking at the document we could avoid you repeating these names repeatedly.

I understand.

In view of the earlier problem.

Yes, thank you, Justice Sebutinde:

"He tore out some pages which he felt were unimportant just before he gave this notebook to", such and such, "in May. He calls it his operational book." Okay? Then you talk about the message from Yeaten to General Issa Sesay and you see there you say you received this message from Life, which is what you told us in Court yesterday. You say also there you were in Buedu and when I asked you yesterday to whom you relayed it to you hesitated and you said, "Well, Elevation was the commander, the signal commander, where Issa Sesay was", but here you say firmly you gave it to Elevation, you sent it to Elevation in Kono. Do you see that, Mr Witness?

Yes.

And then in the next line you say that the message which appears on the page ending in ERN 9182 - the second message by General Yeaten, is also an authentic message relayed by you from Buedu. Lastly you say - and I will read this because this is important and we will discuss this, Mr Witness, so do listen:

"Witness says the reason he was 'relaying' was because there were two codes involved. He had a code between Life and him and there was another code between Elevation and him."

Do you see that, Mr Witness?

Yes.

Okay. Now if we could let's go to tab 6, page 22. Mr Witness, are you there?

Yes.

If you go to the bottom of the page, page 22 at the bottom, the ERN number ends in 5033?

Yes.

At the bottom there are additional ERN numbers and these ERN numbers correspond to the book in question. You can look at the book, if you want. At the top page of the book is the ERN number 00019148 and it runs through the page ending in 9193. It says here in tab 6, page 22: "The witness recognised this exhibit as a photocopy of his personal notebook. He states that he gave the original notebook to Mr X. The notebook contains information concerning instructions for use of the radio from his time as an operator." Do you see that, Mr Witness?

Yes.

You said that this was a photocopy of your personal notebook. You did not explain that you had a prior book that Rebecca transferred information from, right?

Let me explain this part now. The original book that is in front of me now is not what was presented to me, but a photocopy of that book which was displayed in front of me was what I referred to and this is the statement you have here.

I am focusing now on the issue, Mr Witness, of the amount of opportunities you had before you appeared in Court this week to tell the Prosecutor, after 20 meetings, about the significant fact that a friend of yours named Rebecca copied information from one book into the book that General Benjamin Yeaten's information appears in.

Allow me to explain this particular part where I made mention of a photocopy. The original book was photocopied in the Court and which you have even around. It is here. Those books were photocopied many and that was what they produced to me, one of the copies, and that was what I explained about.

Why didn't you tell them, in 20 meetings, Rebecca copied information from one book to another?

Let us address this issue first. The number which was on the photocopied notebook that was presented to me and the information supplied about as a photocopy of the personal notebook, not the actual notebook itself. When the notebook was presented to Zedman and later on I saw it with Chuck Kolot and when I went to Freetown in the Court I saw a photocopied of that book.

Mr Witness, are you saying -- I am sorry.

Mr Witness, we are not talking about what you saw in the Office of the Prosecutor, or with Mr Kolot. The question is why did you not tell them that Rebecca had copied the information from one book to another? Why did you not mention Rebecca?

I was asked, in fact, at certain time during the interview, about the handwriting. In the first place that there is handwriting here different and the other handwriting. There I stated this was copied by another person.

And are you --

Sorry, please proceed. I won't interrupt.

I am telling you there is no indication of this in all the documents they have given to us. Are you saying they failed to write that down?

I did not tell them that it was - I did not tell them it was written by Rebecca.

You did not tell them?

No.

Okay, I see.

But I was asked to really state why this other handwriting in the beginning different and the other one different, and then I explained it was somebody else who wrote this one.

I see. I see. So when they failed to note that down, that someone else transferred information on your behalf from one book to another, that was an oversight or omission on their part, yes?

I haven't actually got an explanation, or I have not heard his explanation given to OTP for the different writing.

He did state, Madam President.

Do you think so? Oh, someone else wrote this one. Sorry, I withdraw that observation.

And in fact --

Mr Witness, let me repeat my question. I have told you that there is no notation, in any of the documents pertaining to your interviews, that you told the Prosecution that someone else transferred information from one book to another. My question is this: The failure of the Prosecution to note that information was a mistake or error on their part, yes?

I don't want to get into that because --

Well, they failed to put it down. Would you agree with that? If you tell somebody something and they fail to write it down, they have omitted to write down something you told them, yes, Mr Witness?

Yes.

And in this case they did not write what you told them. Do you agree?

I was asked --

Do you agree?

With what?

That they did not write down what you told them. You have said you told them something.

I was asked --

And I have put it to you - and Mr Bangura can correct me if I am wrong - that they did not write it down and I am asking you do you agree that they failed to write down what you told them?

What is difficult about that question, Mr Witness?

That is official matters. They were asking me questions and I was answering. I was asked who wrote - "Whose handwriting is this?", and I said it was another person who helped to copy the note regarding the operations of the radio and the procedures.

We know you told them that, but it is not written down anywhere and so somebody did not write it down and I am asking you if you agree with the fact that it is not written down anywhere.

You have documents. When I am talking, you are writing. I am talking. I have been talking. I have been explaining.

My question is not who has documents and who does not. I insist on an answer, Mr Witness. Do you agree that they did not write it down anywhere? Will you answer the question, Mr Witness.

I stated this one. If it is not written then it was not written.

You told us - and I am now referring to the Benjamin Yeaten messages, the two of them. Mr Witness, if you would please turn to the page ending in ERN number 9181, you should know it is the Benjamin Yeaten messages. There are two of them.

Is this on MFI-17?

Yes, Justice Sebutinde. I am sorry, I should make that indication. It is on MFI-17 and we saw them yesterday:

The first one, the one dated 30 September 2001, I have just read a paragraph from tab 2 where you said the message was transmitted to you by operator Life, right?

Yes.

Yesterday in court you said several times that operator Life transmitted that message, true?

Life transmitted the message to me. I received the message from operator Life. It was Life who was on set from Benjamin Yeaten's station at that time.

I noticed when you said that I was frantically trying to find the transcript from the previous day, because my notes said Sunlight transmitted the message. So let me quote to you from the record of the day before yesterday, as to what you said - who, or what you said regarding who transmitted this message.

Your Honours, I will be reading from the transcript of 9 April 2008. The relevant page in question is page 7112. I will start at line number 22 and it is not clear from this page that - well, the ERN number of the document does not appear on this page, but if the Chamber wishes, or if counsel opposite wishes, if you were to flip two pages before to page 7109 --

Madam Court Officer, can we have this on screen, please.

I will actually just start at page 7109 to give the context and this is where the discussion of this page begins. I will read the first three lines of page 7109 which says, line 1:

"Q. Can you turn to page number 00019181.

A. Yes, sir.

Q. What do are see on that page?

A. It is a message."

Line 5:

"Q. And that message is from whom?"

Line 6:

"A. This message was received from Base 1."

Now, if we flip two pages, and the discussion about this message continues for two pages, to page number 7112, starting at line 22, there is a question posed by Mr Bangura:

"Q. Mr Witness, have you read that message? Do you recall the context in which the supply of those materials was made?

A. Yes, sir.

Q. What was the context? In what situation?

A. The message was transmitted by Base 1. That was

Sunlight and it was to be relayed to General Issa's

station."

Mr Witness, you told us on Wednesday it was Sunlight who transmitted this message, right?

Let me explain.

Yes or no? I just read you a transcript. Do you agree that you said on Wednesday it was Sunlight who transmitted that message?

Base 1, operator Life. Base 1 was the name of the call sign, Base 1.

I know what the call sign was. We know it was Base 1 and we know it was Benjamin Yeaten's compound behind White Flower, in Congo Town, Liberia. I am trying to ascertain the name of the radio operator who transmitted the message. You said yesterday it was Life. On Wednesday you said it was Sunlight. Do you agree?

Before this time I had stated Life. It is on the document and I stated in one - in my testimony about Life, from call sign Base 1.

Are you saying you made a mistake on Wednesday?

If I had mentioned Sunlight, which you said is on the screen, then that was a mistake, but long before I had stated operator Life and Base 1 was the name of the radio station and I was asked, "From where did you get this information?" I said Base 1. That was the radio set, the name of the radio, the call sign from where this message was received. The name of the operator that transmitted the message was operator Life.

But names of operators are important, Mr Witness, are they are not? It is very important to get who transmitted a message correctly, yes?

Yes.

Because some operators are stationary operators as in they may be stationed, or work out of a fixed radio set, right, as opposed to a mobile radio set?

Yes.

Indeed, let us go to tab 2, page 10, for illustration.

Is that tab 2 of the --

Of the Defence bundle.

The Defence bundle.

I will try and indicate from now on. I am moving through many different documents:

The ERN number ends in 2023. Mr Witness, are you there?

Yes.

If you look at the bottom of the page there is a paragraph that starts with your name and it says, "Witness's only duty at this time was to be Yeaten's radio operator." Do you see that, Mr Witness?

Yes.

And I will read it to you. It says:

"Witness's only duty at this time was to be Yeaten's radio operator with respect to communicating with Sierra Leone. Yeaten also travelled with a Liberian radio operator called Life, but Yeaten also had two radio operators at Base 1 in Monrovia who were called Sunlight and Dew. Witness introduced them to the system of keeping on operational book with messages sent and received."

This is saying, Mr Witness, that Life always travelled with Yeaten and that the base operators at Base 1 were Sunlight and Dew, right?

Sunlight and Dew were assigned at call sign Base 1 in Monrovia.

Yes, they were the base operators. Life was always on the road, right?

Yes.

And you are telling us this message that you discussed yesterday was sent to you by Life from Base 1, after you have corrected yourself from having said Sunlight on Wednesday. Is that your evidence?

If I had mentioned Life - I am sorry, Sunlight, that was just a slip of the tongue. But all the long while I have been talking about the transmission of that message I had been making mention of operator Life.

Mr Witness, I am putting it to you that you are lying and I will tell you why. You told us yesterday - actually you told us on Tuesday the 8th that operator Sunlight had all the RUF codes. That's what you told us on Tuesday. Do you recall saying that, Mr Witness?

Yes.

Indeed you told us you took the RUF codes to operator Sunlight in Monrovia, yes?

Yes.

And the previous page I have just read - recently read - in the same tab 2, that was page 16, it had to do with the reason why this particular message was relayed and you told the Prosecution at that time that the reason the message was relayed was because you and Life had one set of codes and you and Elevation had another set of codes. Do you recall that?

Yes.

So that paragraph suggests that the operator in Monrovia, whether it be Life or Sunlight, did not have the same RUF codes for Issa Sesay's location. Do you agree with that?

I disagree. I will explain. In my testimony I stated that when a particular code chart became let's say suspicious of being exposed to insecurity, another code chart was then prepared immediately and that was to be distributed to the other stations.

Crossing from Liberia into Sierra Leone we had gone under attack in Foya and some other materials were left on the ground. We leave behind materials on the ground and those were captured. Crossing into Sierra Leone that had to be negotiated. Another code was immediately prepared and left with operator Life. Then I came back to Sierra Leone, okay, explaining to Elevation that the other code chart was left behind, captured in Foya. So we had to establish another code, meaning the one we had with operator Sunlight and of course the other operators who were on the side of Benjamin Yeaten, had to be nullified. We told them don't use this other code until another code is produced. So during that period whatever information they had was relayed to me since I had the other code with Elevation which I had to use to transmit. When I came into Buedu there was also another - there was another station in Buedu. They had their own code.

Why did they send it to you to relay as opposed to another radio operator?

The code in Liberia after the attack in Foya was left behind. So that was not to be used again.

Are you now saying that there were periods of times when the Liberian operators did not have the RUF codes? Is that your evidence, Mr Witness?

That is not what I'm saying, but before now I had stated that when there was a situation wherein we were not sure of the security of our code we had to make nullification of that code and ensure that another code was established.

Then that would mean that there were indeed periods of times when the Liberian operators did not have the RUF codes; true or false?

They had the code, because I was --

Witness --

I was an intermediary sort of leaving Liberia to Sierra Leone. Having the code I had with Life on that side and the other code which I was given to carry to Liberia and that became vulnerable and that was explained to them. So --

Mr Witness, I think we have to not speak over each other so that the record is clear.

Okay.

We have agreed that or you have suggested that the reason why you were relaying this message was because you had a unique code with Life, and we contest that it is Life because you have said previously Sunlight, but we leave it at that, but you and the Liberian operator had a unique code and you and Elevation in Kono had a unique code, yes?

Yes.

Now that means, does it not, that the Liberian operator as of the date of this message, 30 September 2001, did not have all of the RUF codes; true or false? True or false, Mr Witness?

False.

Well, then why could not the Liberian operator communicate directly with Elevation in Kono?

I was an operator, part of the operation, part of the signal unit, and we had no boundary. There was no boundary in communication between us. The only problem was left with the wave and we were operating on the same frequency, but in a situation in Liberia at a particular point where we were and that area went under attack, most of the items we had were captured, leaving the signal materials behind including the code chart. Okay, we came to Sierra Leone and had this one explained to operator Elevation and he said, "Okay, if that is the case now make use of the code you have with Agama. There is another code in Agama's room, use it, get the other message from Sunlight, decode it and transmit it to me."

So your evidence now is that there were no boundaries or no distinguishing factors when it came to who received messages for which RUF commander? Is that your evidence, Mr Witness?

That also --

Are you --

That also would be the sort of situation. If I am an operator, I am operating in a substation, I have been called to report to the headquarter's station, I am an operator, I can get in that station and it happens that message is on the air, I can receive that message and --

Mr Witness, why did not Life or Sunlight in Liberia send Issa Sesay his message directly?

I am saying that the code - the code I was using which was with Elevation and operator Life - the particular code I was using for that particular operation was left behind in Foya. So when I crossed into Sierra Leone that code - I told them, "Don't make use of that code any longer. I have left it behind. Don't use it." So there was another code which Sunlight and Dew had. I had a copy of that. The message was transmitted to me in that code. I had to decode the message, put it into the other code that was with Elevation and others and --

And that means that Sunlight did not have the other code that Elevation had, right?

The one I had there for the operation was not to be used again.

I will go back to my question. Forget the code you left at Foya. On the date of this message, 30 September 2001, it is the case, is it not, that Sunlight could not communicate directly with Elevation because he did not have the code, correct?

At that particular moment and --

Okay.

And a short while ago --

Mr Witness, answer yes or no.

Okay. Yes.

Okay. So he did not have the code. Do you agree we are at that point now?

Yes, because --

And that means if a Liberian operator did not have an RUF code at a particular point in time it means, does it not, Mr Witness, that on certain occasions the Liberian operators did not have the RUF codes, yes?

Yes.

Okay.

If that is the case, yes.

And in this particular case I want to know why of all the possible operators who could have relayed this message the people in Liberia chose you, Mr Witness. Please tell us why?

I was with Benjamin Yeaten. I had been operating with him throughout, okay?

And that is the reason, is it?

Yes, because there was a breach of security. There was a breach of security. Leaving that other code chart behind, there was no need using that particular code. And again let me make it known to you that we were using in fact a code for particular operations. Certain operations were set out with a particular code --

Mr Witness, the question is why they chose you to relay this message and you said, "I was with Benjamin Yeaten." Is that your answer?

I had been with him throughout, okay? Regarding that situation, let me make this part clear.

Mr Witness, we are clear about the code being lost. We are trying to work out why you, as one of several operators, was selected to relay the message. Am I correct in that paraphrase?

Yes, Madam President.

I was available on the air at that time. The way the operation was going out, it is quite different from the way you are looking at it.

Okay, thank you, Mr Witness. Let's --

Mr Anyah, before you leave MFI-17, this very message we are looking at on page 9181, I am just curious, Mr Witness, if you look at that page there is a second signature apart from yours. Whose signature is that?

This --

Don't mention --

The first one, this is not a signature.

Sorry, I saw a name there that I was afraid he would mention.

There is a name - there is a name Benjamin Yeaten and then something that looks like a signature on that side.

This is not a signature and this also is not.

Are we looking at the same page?

Which number?

The page ending 9181.

This one is not a signature.

I am not looking at that. I am looking at the - that one, the one you are pointing at.

Yes, this is a signature.

Whose signature is that?

"Signed for", that is mine.

Okay, don't say the name.

Well, I do see what Justice Sebutinde is pointing to and, Mr Witness, are you saying this is not a signature?

It is not. This is not a signature.

He says he signed for.

Signed for.

But there is also another signature on the left with Yeaten's - I see the "Signed for Yeaten" on the left of the page.

That is the very signature we are now discussing. He says it is not Yeaten's signature, it is the witness's signature. He signed for Benjamin Yeaten.

For.

I did understand that part, but on the right-hand side of the page after "transmitted by operator" is that the same signature, Mr Witness?

This is not a signature.

Then what is it?

No, writing this name we had an error and then this was brought down.

Okay. I see.

Do you mean it was scored out?

Yes, fine. That is not a signature.

Thank you, your Honours:

Incidentally you mentioned something in passing about a difference between the photocopy version of this book you saw in the Office of the Prosecutor during an interview and the original version. Do you recall saying that, Mr Witness?

Yes.

Was there a different between the two? Mr Witness, do you recall telling us you noted some differences of something, yes?

I did not say differences of anything.

Well --

Your Honours, I believe counsel may have misunderstood the witness on this point. My understanding was that there was - the difference he was trying to make was between what was the original and what they showed him which was a copy. That's my understanding.

I am entitled to clarify. That's not how I understood it.

This is the book that was presented to Sahr James. This was photocopied. So when I went to Special Court in Freetown the photocopy of this was what they showed me and this is what you had the information supplied about.

I am asking you if, on the basis of what you said before, as I understood it, there was a difference between the photocopy and the original. You just said a few minutes ago, and I heard it, you said in this courtroom, when you were trying to explain an answer, that there was something unusual about the photocopy of your book that you were shown. You didn't use the word unusual, but you used the word difference?

Excuse me, would counsel indicate the point in the transcript where he is referring to.

Yes, could we see the transcript. That would assist my understanding of the question also.

If I can find it, I will try.

I do have a note of it, Mr Anyah, but it is best we look at the transcript if you can locate it.

It is scrolling up very slowly, but I think I might soon get to it.

According to my note it follows after the reference to Rebecca.

I am told it is at transcript page 50, at line 20.

Thank you, your Honour, Justice Lussick. I might have a different - let me see.

[Microphone not activated] photocopy is line page 34, starting from line 9.

Thank you, Mr Bangura.

Sorry, page 33, line 15, photocopy.

Okay, no, that is not it. Okay, I think I have - let me ask. I will just read the question. I don't see exactly the reference I am looking for, but it does fit my recollection of where this discussion took place. I am reading from page 34, starting at line 13. The question was:

"Q. Why didn't you tell them, in 20 meetings, Rebecca

copied the information from one book to another?

A. Let us address this issue first. The number which was

on the photocopied notebook that was presented to me and

the information supplied about a photocopy of the personal

notebook, not the actual notebook itself. When the

notebook was presented to Mr X and later on I saw it with

Chuck Kolot and when I went to Freetown in the court, I saw

a photocopied of that book."

Mr Witness, I will ask you on the basis of this, was there a difference between the photocopied book Chuck Kolot showed you in the Office of the Prosecution and your book, as you remembered it when you gave it to the fellow you give it to in Kailahun?

It was a replica of the original copy.

When you say original, was it a replica of what you are looking at?

Of this. This is what I handed over to Sahr James and what they showed me in the court was something photocopied, so a replica of this. It was replicated.

Okay, we will accept your answer, but of course we will verify later on. Mr Witness, were you captured by the RUF in the dry or in the rainy season in 1991?

In the dry season.

[Microphone not activated] the first time.

In the dry season. In the dry season.

I was going to say I thought he was captured twice, but he has answered the question and therefore I will not interpose.

I can clarify:

Mr Witness --

Yes, sir.

-- your first encounter with the RUF, when I believe you told us a Liberian by the name of Rambo captured you and two others, was that in the rainy season or in the dry season --

It was in the dry season.

May I finish my question, Mr Witness, please. Was it in the rainy season or in the dry season of 1991?

In the dry season.

Have you previously told the Office of the Prosecutor that it could have been in the rainy season?

Whoever had written the rainy season must have understood my statement wrongly.

Well, I am telling you that in tab 1, your first meeting with them, page 1, they have it down written that you told them, "Captured by RUF in early 1991. Joined the RUF in the rainy season 1991." Do you care to look at tab 1, page 1, Mr Witness. The first page, four lines down, or three lines down.

I am seeing, "Captured by RUF in early 1991". If it is --

The line beneath that says what, Mr Witness?

"Captured by the RUF in early 1991."

The line beneath that says, "Joined the RUF in the rainy season 1991", right?

Yes.

Yes, Mr Witness?

That is what is stated, yes, because - and let me explain. That was the period of time I was sent to the front line, but I was captured in early 1991 and taken to the training base and spent some time on the training base. I was sent to the front line. On the front line that was RUF fighting.

It is not when you were sent to the front line, Mr Witness. The question is not when you were sent to the front line. You had to be captured first before being sent to the front line.

Yes.

I am putting to you you told them when you first met with them that you were captured during the rainy season, when you told us in court on Monday you were captured during the dry season?

It is stated here, "Captured by RUF in early 1991". Look at it at clearly written.

But below that what does it say? You just read it, Mr Witness.

"Joined the RUF in the rainy season." It was during the rainy season I was taken to the front line.

Mr Witness, you were captured in Kailahun Town, correct?

Yes, sir.

And you were captured in the company of two friends, right?

Yes, sir.

And you gave us their names. One was gave Ngevao Koroma, yes?

Yes.

And the other one was Sidikie Momoh, true?

Yes.

And you said the person who captured you was a Liberian, yes?

Yes.

Rambo, correct?

Yes.

At some point after about two weeks the three of you escaped, right?

Yes.

You were then recaptured again, yes?

Yes.

This time the two fellows you were captured with were also captured with you again, right?

Yes, but one was --

There was a third person?

Yes.

Gbassey Momoh, yes?

Gbassey.

Gbassey, G-B-A-S-S-E-Y, right?

Yes.

Momoh also last name, right?

Yes.

And he was also captured, right?

Yes.

The person who captured you the second time, was he a Liberian?

He was.

Some Junior Dolo, right.

No, the first person was not Junior Dolo, but Rambo.

I said that. Who captured you the second time? Was it Junior Dolo?

Yes, Junior Dolo the second time.

Yes. Also a Liberian?

Yes.

Did you know him to be a Special Forces or not?

He was a Special Force.

And what do you understand by Special Force?

They told me on the training base that they had certain group of RUF soldiers who were trained purely to come and liberate Sierra Leone, but that they had other forces that were trained by Charles Taylor and they were sent by Charles Taylor. They were referred to as Special Forces.

Was the person who captured you the first time, to your knowledge, I am referring to Rambo now, also a Special Force?

Yes.

Were all the Liberians that you met within the RUF around this time all Special Forces?

I did not go round to ask everybody to tell me, but that was what I heard from those who captured me.

Well, I am not asking you about just the two in question. I am asking you now about all the other Liberians that you encountered at the training base we will get to in Kailahun. You mentioned there were Liberians there. You specifically said you recognised them because of their accents. You referred to Junior Dolo and Rambo, and the other Liberians, on Monday and on Tuesday and I am asking you if, to your knowledge, all the other Liberians that you encountered during this period in the rainy season, as you say it, in 1991 were all, to your knowledge, Special Forces. What do you say, Mr Witness?

Those I spoke to, those I was able to talk to at that time, did tell me that they were Special Forces and indeed Liberians.

The question is were all of them said to be Special Forces?

Not all of them I was able to talk to.

There is a distinction between all Liberians you were able to talk to, or all fellow Sierra Leoneans, or RUF members you were able to talk to. I am not asking you about whether you spoke with the Liberians. I am asking you generally, to your knowledge, all the people you spoke to, would you say that all the Liberians present there in Kailahun during the rainy season were Special Forces?

I thought you had asked that question already and he had answered.

The question is asked and answered, your Honour, plus my learned friend is seeking to make a distinction from a position which he did not indicate initially. I think his question clearly initially was of those that the witness dealt with, or spoke to, whether they were all Special Forces. Then my learned friend now seeks to expand that category and make a distinction which was not there in the first place.

The Chamber says it is asked and answered and so I will move forward:

Mr Witness, you told us that the first training base you were taken to was a place called Ahmadiyya secondary school, right?

Yes.

The training base was housed in the secondary school. That would be fair to say, right?

The campus, the campus, the particular base was situated in that secondary school campus. There was an open field on that campus, I mean Ahmadiyya, Ahmadiyya secondary school. There we were taken to.

Had you ever used that word Ahmadiyya in all of your interviews with the Office of the Prosecutor before you testified in court this week? Have you ever given them that name before?

I stated that, that we were first taken to Ahmadiyya.

When did you tell them that?

I cannot recall the date anyway, but I can remember in one of my interviews stating that I was first taken to Ahmadiyya secondary school, I spent some time and in fact I met some friends on the base before getting there. And after some time at that particular training base we were then evacuated to another training base called national secondary school, Kailahun.

I see the Chamber is indicating the time.

Indeed. I think we have run out of time, Mr Anyah.

Mr Witness, we are now going to take the mid-morning break and we will start Court again at 12 o'clock. Please adjourn until 12.