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

  • Good morning, Mr Witness. I want us to go back to where we were on Wednesday afternoon. So if I could ask for the transcript of 12 May 2010 at page 40925 to be pulled up, please.

  • Madam Court Officer, which button should we press?

  • Your Honour, the courtroom button on the monitors.

  • Sir, I'm looking at line 2. There's a question by myself:

    "Q. Now, Mr Witness, are you aware that Elmer Glee Johnson

    has acknowledged that although around 30 per cent of the

    weapons used by the NPFL were captured, that the rest were

    arms that had been supplied to Mr Taylor? Are you aware of

    that?

    A. No. I was in hospital when I heard that Elmer Glee

    Johnson fell in an ambush and was killed. I was not in

    Liberia by then, so I don't know."

    Then later on, and this is the following pages at lines 23 and 24, you said, "I don't know Elmer Glee Johnson, no."

    Now, Mr Witness, you've referred to being in hospital and that you were not in Liberia. Where were you in hospital?

  • I was in hospital in Burkina Faso.

  • And when was that?

  • I think it was in April 1990. It was in April 1990 that I had the accident.

  • And what accident was that?

  • I fell off from a truck.

  • And what injury did you receive?

  • I fell off from a truck and I dropped down on the stock of my rifle, so I --

  • Your Honours, could the witness be asked to repeat that last bit.

  • Mr Witness, could you please repeat your last bit of the evidence. You said you dropped off from the truck and then what happened?

  • I had my arm slinged over me. And when I dropped from the truck, I fell over on the arm and then it touched my jaw and part of my jaw I thought was broken. So that was how I got the accident.

  • You told us you went to Burkina Faso for treatment. Why did you go to Burkina Faso?

  • I don't know. I was sick and Mr Taylor took me there for treatment. I went there for treatment because I was sick.

  • Well, why all the way to Burkina Faso?

  • I don't know. I was sick and Mr Taylor took me there for treatment.

  • Could I clarify, Ms Howarth, before you proceed? When the witness says, "I fell over on the arm," does he mean the arm of the rifle rather than his own arm?

  • Yes, Mr Zaymay, I think you heard the question from her Honour. Are you able to assist with that?

  • I had my own arm strapped over me. And when I fell from the truck, I dropped on the rifle and the stock of the arm hit me by my jaw.

  • The stock of the rifle? Did you say the stock of the rifle hit you on the jaw, Mr Witness?

  • Please proceed, Ms Howarth.

  • Just to perhaps clarify that matter a little further, what injury did you receive?

  • There was a combat medic in Gborplay. When they took me there the combat medic told me that my jawbone got cracked, so he referred me for me to be taken to an advanced hospital, so my tooth was removed as a result of the accident.

  • You said, this is at line 18, "I was sick and Mr Taylor took me there for treatment." When you say Mr Taylor took you there, did he travel with you?

  • Yes, he travelled along with me. And when I was admitted in the hospital, he left.

  • And from where to where did you travel?

  • From Liberia to Ivory Coast.

  • And from where in Liberia to where in Ivory Coast?

  • From Gborplay to Danane in Ivory Coast.

  • How did you travel there?

  • From Gborplay to Danane by car. And when we crossed the river, you'll go to the first town in Ivory Coast and you would take a car from there to Danane. From Danane we went to Man and we took the airplane. There was a private plane in Man and we took the plane from Man to Abidjan. From Abidjan we boarded a plane from Abidjan to Burkina.

  • How long after receiving your injury was it that you travelled to Burkina Faso?

  • Within five days I was there.

  • And when you were in Burkina Faso, what treatment did you receive?

  • I am not a doctor to know the scientific names of the drugs. It was the doctor who treated me, so that is all I know.

  • Mr Zaymay, I'm not asking you to give the names of the drugs, but can you tell us whether indeed you received any drugs or any other sort of treatment?

  • I was treated in the hospital.

  • My question is: How were you treated? Were you given drugs? Were you bandaged? Were you x-rayed? What happened?

  • They x-rayed my whole head and the doctor informed me that my jawbone was cracked. So they told me that I needed not to be talking too much. So my upper teeth and lower teeth, they brought it together and tightened it so I will not be shaking my mouth. And I could not eat. They only used to grind meat. They would prepare that - like Quaker Oats and I will suck that. That was how I was treated.

  • For how long were you in hospital?

  • I was in the hospital for two months, May and June.

  • And how did you return from Burkina Faso to Liberia?

  • I was there when Mr Taylor called and I told him that I had now recovered and I wanted to go back. So Elmer Glee Johnson and I were there together because when I went I met Elmer Glee Johnson there. So Elmer and I moved together from Burkina to Liberia. No, no, no, no. Please excuse me. I was there with Mr Taylor's wife Agnes Taylor. Agnes Taylor. And then Agnes Taylor said, "Okay, then you have to go." He said the war was getting tough. He said, "I have already reported to Mr Taylor that you are feeling all right now, so you have to go." So she put me on board the plane from Burkina to Abidjan. And from Abidjan I rode on a bus, Tram Cavalli [phon], that is the bus that runs from Abidjan to Danane. And from Danane to Liberia, Gborplay. That was in July.

  • Now, you've mentioned Elmer Glee Johnson. While you were in Burkina Faso in April, May, June, did you meet any other members of the NPFL?

  • No, I was there alone.

  • Your Honours, could the witness be asked to at least speak in the mic and then raise up his voice a little.

  • Mr Witness, the interpreter --

  • And repeat the last bit, please.

  • The interpreters cannot quite hear you clearly. If you could speak up a bit and repeat the last bit of your answer. You said you did not meet any other members of the NPFL and then you said something else. What did you say after that?

  • I said, no, I was the only NPFL man in Burkina at that time with Mrs Taylor, Agnes Taylor.

  • Madam President, might I just have one moment, please. I'm most grateful.

  • Mr Witness, you've just said, "I was the only NPFL man in Burkina at that time with Mrs Taylor, Agnes Taylor." But you also said previously that Elmer Glee Johnson was with you in Burkina Faso. Is he not a member of the NPFL?

  • No, it was a slip of tongue. When I went to Burkina at that time - it was when I went to Burkina that I heard about the death of Elmer Glee Johnson. He was not in Burkina at that time.

  • Thanks for the clarification. Ms Howarth.

  • I'm going to move to a different area. If I could ask for the transcript of 11 May 2010 at page 40703 to be pulled up, please.

    Madam President, I'm just trying to negotiate a suitable distance to the microphone so that I can be heard but away from the microphone so I don't have too much feedback, so if I become inaudible I would appreciate if it could be pointed out to me.

  • Your Honour, could counsel please repeat the page, because that page doesn't seem to be on that transcript?

  • I'm so sorry, it's 7 May rather than 11 May. You're quite right:

  • I'm looking at line 29, which is right at the bottom of the page. Mr Witness, you said this:

    "Immediately I had received my order in April 1990 I moved

    to Gbutuo. Within that same April 1990, Mr Taylor moved

    and was based in Gborplay, April 1990."

    Line 9:

    "Q. And did you remain in Gbutuo?

    A. Yes, at that time I was in my command in Gbutuo.

    Q. And for how long did you remain in Gbutuo?

    A. I remained in Gbutuo in command for one and a half

    months.

    Q. From Gbutuo did you go anywhere else?

    A. From Gbutuo the old man, Mr Taylor, called me to report

    at Gborplay for my supply."

    Now my question is this: When you said that Mr Taylor called me to report at Gborplay for my supply, how did he call you?

  • At that time there was no communication. We used - we sent messages by sending people, and he sent someone to tell me that I should report to Gborplay. There was no communication by then.

  • So when you reported to Gborplay are you saying that the instruction was directly from Mr Taylor to yourself?

  • Yes, at that time he was - yes.

  • So there was a conversation between you and Mr Taylor at that time in relation to that supply. Is that right?

  • If I could ask for - in fact it's the same transcript, but at page 40757.

  • Your Honour, could counsel please indicate the date? That page is not on that particular transcript. Indicate the date of the transcript. It's not on 7 May.

  • Sorry, that's 11 May.

  • We do have the transcript on the overhead.

  • I'm looking at line 26:

  • "Q. When you left Bomi where did you go?

    A. I was transferred to Maryland County.

    Q. And when exactly was it that you got to Maryland?

    A. It might have been in March or February 1992.

    Q. And very briefly, why were you transferred, if you

    know?

    A. Mr Taylor told me that there were certain things going

    on in Bomi and he did not want me to be killed. And he

    said he got information that I'm not part of it, so he said

    I should be transferred from there. Since there were too

    much of commandos at that one target, he said I should be

    transferred from there."

    Again, Mr Witness, we're in March or February 1992. How is Mr Taylor communicating to you at this time?

  • At that time there was signal communication system in the entire NPFL controlled areas.

  • Can you explain how that signal communication system operated, please?

  • I had a Yaesu radio. That was what I mean. I had Yaesu radio communications and the headquarters was in Bomi under my command. And that was where Mr Taylor used to send message for me and if there was a radio message from him he will tell the radio man to call me, the commander, so that he will get on to me and I will communicate with him through there at that time.

  • You've mentioned a radio man. What radio man are you referring to?

  • The communication man.

  • Are you referring to your own communication man?

  • The radio - there were people assigned and who were trained with those radio communication systems and they were assigned to the various units. So I had my own chief of communication who was assigned with me in the radio room in Bomi.

  • He was called Joseph Dehmie.

  • Was he known by any other names?

  • I have now forgotten his code name in communication but the name I recall is Joseph Dehmie.

  • What nationality was he?

  • A Gio from Nimba. He was a Liberian.

  • If you recall, what were the names of any other radio operators operating under your command at that time?

  • I don't remember, but he was the chief who was assigned with me straight by the office. He was the chief of signal.

  • I just want to look at the answer you gave at approximately line 21, although I have quite large type:

    "And that was where Mr Taylor used to send message for me and if there was a radio message from him he will tell the radio man to call me, the commander, so that he will get on to me and I will communicate with him through there at that time."

    So how exactly would you then communicate with Mr Taylor?

  • Sometimes when I went into the radio room there was also a radio operator assigned at the NPFL headquarters in Gbarnga. And that was assigned directly with Mr Taylor. They used to call that person Butterfly. That was the code name, Butterfly. So sometimes when I went and said, "Oh, I'm in the radio room," and if it was required for Mr Taylor himself to talk to me he will come to the radio room and give me instruction. But sometimes when Mr Taylor was busy he would ask Butterfly to pass the instruction over to me, so that was how it used to go.

  • When you say so "it was required for Mr Taylor himself to talk to me he will come to the radio room and give me instruction," do you mean there that you are talking - you and Mr Taylor are talking directly?

  • Yes.

  • And then you went on to say, "But sometimes when Mr Taylor was busy, he would ask Butterfly to pass the instruction over to me." So on those occasions where Mr Taylor was busy are you saying that Butterfly would talk directly to yourself?

  • Can you tell me what gender Butterfly was?

  • Butterfly was a lady.

  • Do you know how old this lady was?

  • At that time Butterfly was just a girl in the twenties.

  • Do you know whether Charles Taylor had a code name?

  • Yes, we used to call him Ebony.

  • I'm going to ask for - it's the same - it should be the same transcript, 11 May 2010, at page 40759. I'm moving on to a slightly different topic now. I'm at line 5. I'll put the question before that at line 3:

    "Q. My question is when ECOMOG entered did they remain in

    Liberia?

    A. When ECOMOG entered and pushed us back, they set up

    their defences and then later they deployed in Maryland in

    1992.

    Q. And when they were deployed in Maryland in 1992, did

    you have any dealings with ECOMOG?

    A. Yes, I was ordered to disarm ECOMOG.

    Q. Who ordered you to disarm ECOMOG?

    A. Mr Taylor."

    How was that order from Mr Taylor communicated to you?

  • At one time I was called to report to Gbarnga for my salary. So when I went, I met Mr Taylor himself. He told me that the ECOMOG - that the ECOMOG were planning to attack us, so he said he would want me to go back immediately and disarm the ECOMOG. I met him one on one and he gave me the orders. So that was how I got it.

  • I wanted actually to stay on that transcript but just to skip down a couple of pages. So to the bottom of 40761, please.

  • When the witness says, "I met him one on one," Mr Witness, do you mean you met Mr Taylor personally - in person, that is? You met Mr Taylor in person to get the directive?

  • Yes.

  • Line 26:

    "Q. Now, when you got the order from Mr Taylor to disarm

    ECOMOG, did you execute the order?

    A. Successfully.

    Q. And how did the disarmament process go?

    A. I was ordered that all the - for all the three counties

    where my battalions were assigned, ECOMOG was assigned

    there within the various battalions, so I should order all

    my battalion commanders to call the ECOMOG commander in the

    radio room in order to receive the instruction from

    Mr Taylor first."

    Again, how did you receive that order that you should order all of your battalion commanders to call the ECO commander in the radio room?

  • When I got at my base in Maryland.

  • So was that an instruction that you received over the radio?

  • The radio commander brought the radio message to me from Gbarnga, that here is the caption of the order that you should contact all your commanders.

  • Again, who was that radio commander with you in Maryland?

  • I do not recall.

  • Was it the same or different from the person you mentioned earlier?

  • No, that was a different person. I left Dehmie in Bomi. That was now a different person, but I do not recall that person's name now.

  • You said that the radio message had come from Gbarnga. Do you know who at that time was operating the radio in Gbarnga?

  • Where? In Gbarnga?

  • It was the same Butterfly.

  • I'm going to continue with that transcript, please. In the extract that I read you said, "I should order all my battalion commanders to call the ECOMOG commander in the radio room." When you said "all my battalion commanders", what do you mean?

  • I mean the various county commanders, the battalion commanders who were under my command. There was a battalion commander at Grand Gedeh, there was a battalion commander in Grand Kru and there was one at Sinoe.

  • Going back to that transcript, I'm going to repeat again line 3:

    "So I should order all my battalion commanders to call the

    ECOMOG commander in the radio room in order to receive the

    instruction from Mr Taylor first. If we rushed on them it

    would end up in firing and he didn't want any ECOMOG to be

    killed.

    Q. Who did not want any ECOMOG to be killed?

    A. Mr Taylor gave me the instruction.

    Q. Yes, and what was ECOMOG's reaction, if any, to the

    order to disarm?

    A. At first I was to deal with the commander that was with

    me, commander to commander. I called him in my office. I

    invited him to the radio room. I told him that there was a

    message from Mr Taylor for him to come and receive the

    message. We went, but he refused. Mr Taylor told him to

    wait and not to endanger the rest of the ECOMOG's lives."

    Now, Mr Zaymay, when you said, "We went, but he refused," what did you mean? What did he refuse?

  • He at first refused that he was not going to disarm.

  • And when you said, "Mr Taylor told him to wait and not to endanger the rest of the ECOMOG's lives," Mr Taylor told who?

  • He told the general commander for the ECOMOG. He told the general commander of the ECOMOG.

  • How did he tell him?

  • He told him that, "From where your position is, you don't know the terrain. From Maryland to Monrovia would take you for about two to three days. So for the safety of your own men, your own soldiers, I would not want you to put up resistance. So easily comply with the instruction and you will be brought to me in Gbarnga and I will send you to your headquarters in Monrovia," and he accepted it.

  • You told us what Mr Taylor said. Was he talking directly to the general commander of the ECOMOG when he said this? In other words, was it Mr Taylor talking to the general commander of the ECOMOG?

  • And this was taking place over the radio. Is that right?

  • Just going back to that transcript for the sake of completion. It continues:

    "We went, but he refused. Mr Taylor told him to wait and not to endanger the rest of the ECOMOG's lives. The distance that he was from Maryland to Monrovia, it will take him two days. So if he were to put up any violence, he wouldn't make it. He wouldn't make it. He didn't know the terrain. He didn't know where he was. So he told him to go and tell his commanders to disarm, to turn the arms over to Commander Zaymay."

    Mr Zaymay, is that what you were just explaining to us in terms of what Mr Taylor told the ECOMOG commander?

  • Yes.

  • Mr Zaymay, you've mentioned in your testimony somebody called One Man One. I don't think we need to go to the reference, but you had briefly said One Man One was Alpha Company commander. He was assigned at Tiene and Bo Waterside, the border between Sierra Leone and Liberia. What tribe did One Man One belong to?

  • One Man One was a Gio man from Nimba County.

  • And who was it that appointed One Man One to this position that you say is Alpha Company commander?

  • And can you tell me what happened to One Man One? Did he die?

  • Yes. I heard that One Man One died whilst I was in Maryland.

  • I heard it in '92.

  • Can you tell me One Man One, what was his real name, if you know?

  • No, I don't know his real name. It was his fighter name that I knew, his popular name.

  • Ms Howarth, you asked the witness what happened to One Man One and did he die. He answered one of your questions.

  • If you know, how did One Man One die?

  • Why is it that you don't know?

  • At that time I was no longer in command. I was far off in Maryland, which was a distance from Bomi. So I did not know how he died.

  • Was One Man One a Special Forces?

  • How did he come to join the NPFL?

  • When I took over the command in Bomi Hills, I met him there as one of the soldiers.

  • Do you know what other assignments One Man One had?

  • When I took over the command, he was at the headquarters.

  • Just skipping backwards before I go forwards, you had mentioned Butterfly earlier and you said that she was a young woman. Her name was Oretha Gweh, wasn't it?

  • I don't know, but I only knew her code name Butterfly because I was not based in Gbarnga.

  • Very well. And a final question on One Man One. He was well known in the NPFL, wasn't he?

  • And he was someone who was well known because he was a brave fighter, was he not?

  • Yes, he was a fighter.

  • Perhaps something was missed there, but the question was a brave fighter. He was well known as a brave fighter, wasn't he?

  • Yes.

  • Mr Zaymay, you had spoken about before the invasion of Liberia a rendezvous in Zongwe and you said that Charles Taylor gave a speech in Zongwe. That's right, isn't it?

  • He did not give a speech. He only came and dispatched us to go to our various targets. He did not give a speech.

  • Could I pull up the - ask can it be pulled up, the trial transcript of 7 May 2010 at 40654. Can we start at line 3. This is in the middle of your answer:

    "Zongwe was the rallying point. The group in Danane came

    to Zongwe. That was from Bin-Houye came to Zongwe. That

    was where we were when we met Mr Taylor. Then he started

    planning again. He and Prince, they started planning again

    how to finally enter into Liberia.

    Q. At this point did Prince have any position in the

    organisation?

    A. Yes, from the base Prince was the S3 planning and

    training.

    Q. And again maybe it would be easier if you refer to the

    base to refer to it by name so that the record is clear.

    By base you mean which base?

    A. Yes, at that time in Tajura where we trained Prince was

    one of the top brass for us. He was the planning and

    training officer. He was charged with planning.

    Q. Let's continue with the meeting in Zongwe where

    Mr Taylor was present.

    A. So when Mr Taylor came after the other groups had come

    and we were all together in Zongwe then Mr Taylor said,

    'Gentlemen take courage. The training that you've had will

    not go in vain. Now your brothers have entered. Your

    brothers have entered. You people would go now to attack.

    You people would go in in groups. Group A.'"

    So I'll stop there. Mr Zaymay, your testimony on 7 May is describing a rendezvous in Zongwe where you say that Mr Taylor addressed the men there, telling them to take courage. That's your evidence, isn't it, or are you changing it today?

  • You know he did not give a speech and you said he gave a speech. He was not giving a speech. He only spoke to us that we should be courageous. He said we - the training we underwent was too advanced for the ordinary AFL training, so he asked us to take courage but he did not actually give a speech. That was all he said.

  • I might come back to that. Could I ask that the transcript of 29 April 2010 at page 40319 be shown to the witness - sorry, be presented to the Court.

  • What was that date again, Ms Howarth?

  • I'm sorry. It's 29 April 2010 at page 40319.

  • This is the evidence of another witness in the case and I'm going to start at line 4:

    "Q. Let's start again, Mr Witness. You mentioned the town

    where you were divided into groups. What's the name of the

    town?

    A. They called it Zongwe. It's an Ivorian town."

    Then there is some discussion about the spelling:

    "Q. Did you eventually meet up with the other groups that

    came from Libya?

    A. Those of us that came from Libya and crossed those

    were - repeat that.

    Q. Yes, all the Liberians who trained in Libya, did you

    meet up in Zongwe?

    A. Yes, we all met here in Zongwe.

    Q. Was Mr Taylor in Zongwe at the time?

    A. No, he was never there from the beginning. It was

    Enoch Dogolea and Alfred --

  • Mr Chekera, the witness said something

    about Enoch.

  • That's what I'm trying to clarify.

    Q. Did you say Enoch Dogolea and Alfred?

    A. I said Enoch Dogolea and Isaac Musa."

    Then there is more discussion about the spelling of Dogolea:

    "Q. Mr Mineh, when I asked you the question was Mr Taylor

    there your answer was Mr Taylor was not there. Was Enoch

    Dogolea and Alfred Musa the ones who - sorry, Isaac Musa,

    were they the ones who were present?

    A. They were the leaders. They were strategising our

    plan."

    So, Mr Zaymay, yourself, you are explaining Mr Taylor as being in Zongwe and if not giving a speech, then at least addressing you in Zongwe. And another witness has come to Court and taken an oath and he has sworn that Mr Taylor was never in Zongwe. So please can you help us with this: Who is telling the truth? Is it you or the other witness?

  • My group - my group that entered Gbutuo, it was Mr Taylor who dispatched us in Zongwe. My group that attacked Gbutuo, it was Mr Taylor who briefed us, encouraged us to leave. He even escorted us to the border. He wanted to cross. He wanted to cross. But we told him, "No, you cannot enter with us in Liberia. You'll have to wait whilst we go and then establish a safe zone for you and then we'll call you to come in." But he wanted to enter with us but we told him no and he was at Zongwe. That was what I said.

  • But it wasn't just your group in Zongwe at that time, was it?

  • Some other groups had been dispatched. I did not see Edward Mineh. I did not see Varney. He told me that, "Your friends and the others have gone to their various targets. All of you will meet in Liberia. So you who are here, your target is Gbutuo so you have to move in." In the case of my group, Taylor of course came and briefed my group before we left. I'm not talking about other groups.

  • Perhaps I'll come back to that in a moment. Now I want to skip to the invasion of Monrovia. You said this was the initial invasion in July 1990. Is that correct?

  • Which, NPFL? NPFL entered Monrovia in July 1990.

  • I want to know if you'll agree with this: Your base was the City Hall, wasn't it?

  • And at this time Charles Taylor was based in the Coca-Cola factory, wasn't he?

  • He was not based at the Coca-Cola factory. In 1990 Charles Taylor was still in Gborplay. He only came to the front once in a while, but he was based in Gborplay.

  • During the invasion of Monrovia in 1990, Charles Taylor was at the Coca-Cola factory, wasn't he?

  • So are you saying that during the July 1990 invasion of Monrovia, Charles Taylor was never at the Coca-Cola factory?

  • During the time the NPFL entered Monrovia, Charles Taylor was not at the Coca-Cola factory. He was in Gborplay. He came to the Coca-Cola factory sometimes to talk to us.

  • When was that?

  • I remember that in July 1990 he came once at the Coca-Cola factory and the battlefield commander, Sam Larto, called us and told us that we should go to the Coca-Cola factory and that Mr Taylor was there who wanted to talk to us. So we went there. We met him there. He thanked us. He said, "I thank you people so much. Now we are in Monrovia. And you take good care of yourselves." He talked to us, he thanked us and he left and he went back.

  • When in July 1990 was this?

  • It was in July, but I do not recall the date.

  • What were you doing at this time in July 1990 at the time you visited Charles Taylor in the Coca-Cola factory?

  • What were we doing?

  • Yes, you, Mr Zaymay, what were you doing?

  • I was a commander. I deployed my men in the defensive waiting for a supply to move on to the mansion.

  • And where were you based at the time you went to visit Mr Taylor in the Coca-Cola factory?

  • City Hall.

  • Now, it's right, isn't it, that your group at City Hall came together with Isaac Musa and Sam Larto initially with the intention of carrying out the mission to clear the city?

  • Yes, we planned to do that.

  • And at this time Isaac Musa was the battle group commander and he had been based in Kakata. Is that right?

  • And Sam Larto, he was deputy to Isaac Musa and he was based on the front line at Duport Road. Is that right?

  • No. John Teah was a deputy to Isaac Musa. Sam Larto was the field commander.

  • What about where he is based? I mentioned Duport Road. That's where Sam Larto was based, wasn't it?

  • Sam Larto was based in Monrovia at Duport Road.

  • And it's right that Sam Larto in fact went to visit Charles Taylor in the Coca-Cola factory with the intention of obtaining arms and ammunition from Mr Taylor. That occurred at one point, didn't it?

  • Yes, we were in defensive --

  • Your Honours, can the witness be requested to repeat his answer slowly.

  • Mr Witness, please repeat your answer slowly. Please repeat your answer.

  • Yes. Commander Zaymay, deputy Zongoya [phon] and the other Special Forces were all in the defensive. We were awaiting supplies to move on to the mansion. We said we were tired of sitting here looking at the mansion. We cannot leave the jungle. Here is the seat of the President. We have to move on and take over at once. The battlefield commander was to go for the supply. It was at that time that he left. It was at that time that he called Mr Taylor and Mr Taylor said, "Okay, I will be there tomorrow. You wait for me. I am coming." It was at that time that he came to Coca-Cola factory.

  • So you agree that Sam Larto went to the Coca-Cola factory to see Charles Taylor with the intention of obtaining arms and ammunition?

  • And when Sam Larto returned, he brought an order from Charles Taylor, didn't he, that there should be a ceasefire? Is that correct?

  • If I could pull up a different transcript. This is 6 May 2010 at page 40596. I'm starting at line 14:

    "Q. Where was that that Godfather recruited you?

    A. Godfather recruited me in Zongwe.

    Q. Yes. And when he recruited you, did he tell you for

    what purpose he was recruiting you?

    A. We were already on stand-by expecting to come and wage

    war in Liberia. We were expecting anybody from Abidjan,

    like all our heads, to come and take us anywhere for

    training. So when Godfather came, I knew that he had come

    for training, that I was prepared for.

    Q. Do you know whether Godfather is known by any other

    name?

    A. Yes, they called him Alfred Mehn.

    Q. What happened when Godfather approached you?

    A. When - Zongwe is a big city where we lived, so we left.

    And when we came back they said our friends have gone,

    the first group has gone. Whilst we were waiting Godfather

    came and he said he had come for the second group. He

    said, 'Go and collect all your friends.'"

    Mr Zaymay, your evidence is that you were recruited by somebody called Godfather who you say is named Alfred Mehn and that he recruited you in Zongwe. Is that right?

  • Yes.

  • And this is something you are quite sure about, is it?

  • Yes, I was recruited in Zongwe.

  • Now, Mr Zaymay, you have previously told us that you had given evidence to the Truth and Reconciliation Commission. Is that correct?

  • And you gave that evidence on 4 February 2009, did you not?

  • And when you gave that evidence, that evidence was on oath, wasn't it?

  • Yes.

  • And you understood that because you were testifying on oath it was important that you told the truth?

  • And you told the truth to the Truth and Reconciliation Commission, didn't you?

  • You told the Truth and Reconciliation Commission that it was Mr Taylor who came and recruited you, didn't you?

  • Yes.

  • But you've told these judges that the Godfather, Edward Mineh, recruited you.

  • Please pause, Mr Witness. Yes, Mr Chekera?

  • Yes, Madam President, if counsel is faithful to the transcript and to the witness's evidence, the same transcript that counsel referred to, the earlier answer by the witness to the same question was that, "Mr Taylor recruited us." The same transcript of 6 May 2010, the preceding discussion before the reference to Godfather refers to Mr Taylor recruiting the witness. So if counsel is alleging any inconsistency, there is none.

  • What's the transcript reference to that?

  • The same transcript of 6 May 2010, page 40596. I remember this very well because I was chastised more than once for leading on that particular issue.

  • Could you give us a line, please?

  • Maybe you could start at line 3. Or maybe you could start at the preceding page, which is 40595. That's where the discussion started. But at line 3, it's very clear, that is how Mr Taylor came in. And then the discussion went further to discuss Godfather actually being the agent for Mr Taylor.

  • Ms Howarth, what is your response?

  • Well, it's not immediately clear to me from what my learned friend has referred me to. However, I simply submit that it's a matter that can be dealt with in re-examination.

  • But, in any event, the witness has given two - or has pointed to two different persons as having recruited him. And certainly I would like to know which of the two people, Godfather and Mr Taylor, which of the two people actually recruited him.

  • Mr Zaymay, you've agreed that you told the Truth and Reconciliation Commission that it was Mr Taylor who recruited you. Now, I've cited a transcript reference to you where you clearly tell this Court that it's the Godfather, Edward Mineh - Alfred Mehn. So sorry. The Godfather, Alfred Mehn, who recruited you. Mr Chekera says that you said it was Mr Taylor. Clearly you've at least told this Court that it was either Mr Taylor or it was the Godfather or it was both. What is your evidence on this?

  • As related to the recruitment I never saw Mr Taylor. It was Godfather who recruited us. When we entered at the base it was then that Mr Taylor came - Mr Taylor came in and said he was the one who had sent for us. Mr Taylor was the one who ordered Godfather to recruit. Mr Taylor never entered at the recruitment ground.

  • So you said, "When we entered at the base it was then that Mr Taylor came." Please help me with this: What base are you referring to?

  • Godfather came and recruited us. When we went to the base in Tajura, it was at that time that Mr Taylor came in. He said that he was the one that had sent for us.

  • So in Ivory Coast it's the Godfather, Alfred Mehn, who recruits you, correct?

  • And you don't meet Mr Taylor until you get to the base?

  • And that's the base in Tajura?

  • So your lawyer's got that one wrong, hasn't he?

  • Maybe I made the error from the statement that I gave, but Taylor never recruited us, but Godfather recruited us and turned us over to Mr Taylor. If I said Mr Taylor recruited us, it could be an error from me.

  • Now, you agreed with me that you told the Truth and Reconciliation Commission that it was Mr Taylor who recruited you in Ivory Coast. Why are you telling the Truth and Reconciliation Commission one thing and these judges something else?

  • What I said to the TRC was an error. It was an error. What I'm saying is that the recruitment was done by Godfather. It was a recruitment team that did the recruitment, not Taylor himself. Later on at the base the men who were recruited were handed over to Mr Taylor as the boss. So automatically whatever was going on in relation to recruitment was for Mr Taylor.

  • So you told the Truth and Reconciliation Commission the wrong thing. Is that what you're saying?

  • Yes. He was not in the recruiting team. It was an error.

  • So you told the Truth and Reconciliation Commission the wrong thing. Is that what you're saying?

  • Not wrong. It's an error. It's not wrong. Anybody can make a mistake and mistakes are allowed to be made.

  • So when you told the Truth and Reconciliation Commission that Charles Taylor recruited you from the Ivory Coast, you got that wrong, correct?

  • It is not wrong. It is an error. I'm repeating it. It's an error. It's a mistake.

  • So you're saying you made a mistake when giving evidence to the Truth and Reconciliation Commission?

  • But, Mr Zaymay, you were giving evidence on oath, weren't you?

  • Yes, I gave evidence on oath. A mistake is not a lie. A mistake is allowed to be made. Anybody can make a mistake. You take an oath to talk the truth, but you can make mistakes. It's not lying.

  • Aren't you careful when you give evidence on oath, Mr Zaymay?

  • But you are careful.

  • I want to refer to the first summary that was provided by the Defence in relation to this witness:

  • Mr Witness, to be fair to you I'm just going to explain that before you give your evidence the Defence lawyers provide us with a summary or summaries of the topics that you will discuss in your evidence. Now, the summary that we were given by the Defence - and I'm referring to the version 4 summary of 29 January 2010, however - this is the fourth summary for this witness that was filed. All four of them were the same. I'm referring to the first sentence. Mr Zaymay, it says this:

    "W" - which is witness - "was an AFL soldier in the Military Police in 1985, was exiled to the Ivory Coast where Charles Taylor took him and others to Libya to be trained as Special Forces."

    [Overlapping speakers] Mr Witness, if you could just wait for the question.

  • Mr Witness, could you wait for the question, please, to be asked first.

  • Why did you tell the Defence lawyers that Charles Taylor took you to Libya to be trained as Special Forces?

  • Ask your question again. I didn't get it clearly.

  • Why did you tell the Defence lawyers that Charles Taylor took you to Libya to be trained as Special Forces?

  • Yes, because he staged the revolution. He was the head of the revolution. He staged the revolution. He organised the movement and he arranged the base. So he was the boss who did everything. That's what I'm saying. He took me.

  • Did you tell the lawyers that Charles Taylor took you from the Ivory Coast, like you told the Truth and Reconciliation Commission?

  • Godfather was the one who recruited me and took me from Zongwe to Abidjan, from Abidjan to Burkina, from Burkina onward to Libya before I could see Charles Taylor.

  • You have met someone called Edward Mineh while you've been here in The Hague, haven't you?

  • Yes, I met Edward Mineh here.

  • Please remind me, when was it you arrived in The Hague?

  • I left Liberia on the 27th - no, I left Liberia on the 28th, on Wednesday, and I arrived here on the 29th, on Thursday.

  • And when you arrived here, Edward Mineh was also here, wasn't he?

  • And he was also a witness for the Defence, wasn't he?

  • And you were sharing accommodation with Edward Mineh, weren't you?

  • We were living in the same hotel.

  • Without naming any names, and please don't name any names, was there anyone - any other witnesses with you in that hotel at that time?

  • It was only Edward Mineh that I knew before --

  • Your Honours, can he kindly repeat the name of the person who came over.

  • Ms Howarth, do you wish him to repeat the name of the person who came over?

  • [Microphone not activated].

  • Mr Witness, you should not name any names. Just give an answer without naming any names, please.

  • And when you say you knew him before, what do you mean?

  • Who? Edward Mineh?

  • I knew Edward Mineh as one of the NPFL fighters, as commander for the 1st Battalion.

  • So he is an old acquaintance of yours, isn't he?

  • And an old friend of yours as well?

  • And you are both of the same tribe; I'm right about that, aren't I?

  • Yes.

  • And you speak the same language, correct?

  • How many days did you share the accommodation in the hotel with Edward Mineh for?

  • And did you speak with Mr Mineh during those six days?

  • Oh, yes. We used to talk. While we were in the video club, we used to talk.

  • What do you mean by the video club?

  • You know the place where we were staying, they have a video there. So when there was nothing to do, Edward having been here for long, he has had some friends, the Sierra Leonean group, so he used to go there to borrow video cassette discs and we would go and sit down and he would play it just to pass time.

  • So you passed time together and watched some videos. Did you also share meals together?

  • Yes, we used to eat in the same dining room.

  • And did you chat on those occasions too?

  • What occasion?

  • When you were eating in the dining room together?

  • When you are eating you don't talk, so what would we be discussing? I was concentrating on my mission here.

  • So you talked in the video room but not when you were eating food, correct?

  • Yes, when we were eating we don't talk. After I have finished eating I would go to the video club.

  • Could the transcript for 29 April 2010 at page 40303 be shown, please. I'm going to start from line 1. This is what Mr Mineh had to say:

    "Q. And what happened when you were in Danane?

    A. I was there; I built my house; I began to sell cassava.

    Q. For how long did you remain in Danane?

    A. I cannot remember, but I stayed too long there.

    Q. Did you leave Danane to go anywhere else after that?

    A. Yes. When I was in Danane, someone called for me and

    carried me elsewhere.

    Q. Who came for you?

    A. Godfather came for me and said, 'Let's go. There is

    a place that I want to carry you. There is someone that

    has come to be our saviour, so let's go.'

    Q. Godfather, did he have another name? Did you know him

    by another name?

    A. His name is Alfred Mehn."

    Then skipping to the next page at line 24:

    "Q. Mr Witness, when Alfred Mehn approached you what did

    he say to you?

    A. What he told me, then I agreed, he came for me and told

    me that because they are killing the Dan, to wherever you

    go there, I will go.

    Q. Did he say he was going to take you to any particular

    place?

    A. Yes.

    Q. Where he was going to take you?

    A. He took me and carried me to Abidjan. From Abidjan we

    went to Burkina Faso. Then we advanced to Libya.

    Q. Did he tell you why he was taking you to Libya?

    A. Yes.

    Q. Why was he taking you to Libya?

    A. He carried me to Libya for those who - for the Dan

    tribe to regroup and take training to fight Doe, so I

    agreed."

    So Mr Mineh is saying there that it's the Godfather Alfred Mehn who recruits him from Ivory Coast, isn't he?

  • Ms Howarth, I don't know what kind of question you want to put to the witness. Are you simply saying to him has he seen what the transcript says, or what is the question?

  • It's as simple as asking his agreement that what I've just read reflects the fact that Mr Mineh said that Alfred Mehn, the Godfather, recruited him from Ivory Coast:

  • That's right, isn't it, Mr Witness? That's what Mr Mineh is saying there, that the Godfather recruited him from Ivory Coast? Do you agree or disagree? Was that what he was saying?

  • Yes, I would agree with him because Godfather and Degbon were the recruiting team. They were recruiting us in the Ivory Coast, but I was not in Edward Mineh's group to know whether it was Godfather who took him along. I was not in his group.

  • I would like to refer to the updated summary that was provided by the Defence, and this was the first of two. This was provided on 5 May 2010. Mr Witness, this updated summary explains this:

    "Witness went into exile in the Ivory Coast where Charles Taylor's emissaries took him and others to Libya for military training with a view to topple Doe."

    Now, this is different from what is stated in the first summary we were provided with and it's different from what you told the Truth and Reconciliation Commission. My question is this: Did you and Mr Mineh put your heads together and discuss who it was who recruited you from the Ivory Coast? Did you discuss the Godfather - Godfather, Alfred Mehn?

  • Discuss - ask your question again. You said I discussed what with Edward Mineh or Godfather? I did not get your question clearly.

  • Did you discuss with Edward Mineh your recruitment in Ivory Coast by Edward Mineh, Godfather - Alfred Mehn, Godfather?

  • I discussed with Edward Mineh where?

  • While you've been sharing the hotel here in The Hague?

  • No. I was strongly advised that I should not discuss my testimony with anybody, so I never discussed anything with Edward Mineh.

  • So you are saying it's just a coincidence that you've changed your story from it being Charles Taylor who recruited you, which is what you told the TRC, to it being Alfred Mehn, Godfather?

  • I said any movement of the NPFL that was done for recruitment to attack Liberia was supervised Charles Taylor. Charles Taylor never came on the ground in Zongwe in Ivory Coast to recruit me. It was Godfather who recruited me. The recruitment team was Godfather and Degbon.

    When I was - I was recruited by Godfather and when I got to Tripoli, that was the time Mr Taylor came in as the overall boss for our organisation. So automatically he recruited. He sent for the people, but he never came on the ground to recruit me. I continue to say this.

  • I don't know if this is a convenient point, Madam President.

  • Yes, this is a convenient moment to take the midmorning break. We will reconvene at 12 o'clock.

  • [Break taken at 11.30 a.m.]

  • [Upon resuming 12.03 p.m.]

  • Right. Ms Howarth, please continue.

  • Now, Mr Witness, we have spoken about your appearance before the Truth and Reconciliation Commission and the fact that you gave evidence before them. When you did so, am I right in saying you gave evidence for about an hour and a half? Does that sound about right, or not?

  • I can't remember the exact time. I was not having a watch.

  • Does it sound like a reasonable estimate? It doesn't have to be exact.

  • Very well. You on that occasion told the Truth and Reconciliation Commission your story about what happened during the wars in Liberia, didn't you?

  • Yes.

  • And when you were telling them your story, you explained, as we have already mentioned this morning, that Charles Taylor came and recruited you from the Ivory Coast, and after that you told them about how you invaded Liberia and you entered with Prince Johnson in Gbutuo. That's correct, isn't it?

  • Yes.

  • You spent some time in your testimony to these judges in this Court talking about your training in Libya, correct?

  • But when you were relaying your story to the Truth and Reconciliation Commission, you didn't mention your training in Libya at all, did you?

  • Yes, I told them I was trained in Libya.

  • When it was the part of your testimony where you were relaying your story - not the part where you are being asked questions, but the chance you had to tell your version of events - you didn't mention Libya, did you?

  • I talked about Libya; that I was trained in Libya.

  • So you are saying when you told your story in your own words your events, you told the Truth and Reconciliation Commission about your training in Libya?

  • Yes. They asked me what had caused me to take arms against Samuel Kanyon Doe. I explained how I went to exile, how I left and went for training, the type of training I took, how I entered. I explained everything.

  • Now, the format of the hearing before the Truth and Reconciliation Commission was this: You had an opportunity to explain your story to the commissioners uninterrupted for some time, didn't you?

  • Yes.

  • And then after that the commissioners were able to ask you questions, weren't they?

  • And you very helpfully answered those questions, correct?

  • Now, in the part where you were telling the commissioners your story, your version of events, you didn't mention that you trained in Libya, did you?

  • I told them where I was trained and the type of training I undertook and how I entered Liberia. I explained to them. I did not jump from Ivory Coast to come to Liberia. I was trained, and I told them.

  • So you are saying that when you were giving your own version of events you told them about the Ivory Coast, and from the Ivory Coast you told them that you went to Libya to Tajura and was trained there by Charles Taylor? Is that what you are saying?

  • Mr Zaymay, that's not true, is it?

  • What is not true?

  • It's not true that you when you were narrating your story, your version of events, that you told those commissioners about Libya. You didn't mention Libya at all, did you?

  • Well, maybe they made a mistake. Then how did I leave Ivory Coast to come and fight in Liberia? Where was I trained? Then they made the mistake.

  • Mr Zaymay, you didn't mention Libya to them at all until you were asked the question directly by one of the commissioners. That's what happened, isn't it?

  • I explained where I was trained. If it is not mentioned there, then that is their error. They asked me what had caused me to join the NPFL, and I explained what had caused me to join the NPFL and where it was organised in Libya, and I explained where I was trained. If it was not there, then they may have made the mistake, not me.

  • So are you saying you spoke twice about Libya? You spoke once about Libya when you were relaying your story of events, and then again when you were asked questions. Is that what you are saying?

  • Your Honour - Madam President, I would like to refer the witness to his testimony before the Truth and Reconciliation Commission. It's in a bundle. A copy has been provided to the Defence previously, and there are bundles for your Honours.

    Yes, if Mr Zaymay could be shown the copy.

  • There are two bundles. Could counsel indicate which of the two.

  • It should be one bundle with two tabs, tab 1 and tab 2. It's in tab 1.

  • Mr Witness, can you read the document on the computer?

  • This one is not clear to me. My eyesights are not good.

  • It's not clear to me either and I am wearing glass. Perhaps the witness could be given the document directly, the paper copy for him to read.

  • Madam President, there should be copies of the bundles for your Honours. I don't know --

  • Yes, we do have copies. I was just concerned that the witness, you know, should be shown a copy that's legible.

  • Mr Witness, you have in your hands a copy of the testimony that you gave before the Truth and Reconciliation Commission and at the top it reads - the top of the first page it reads, "testimony before the Liberian Truth and Reconciliation Commission." Then it says, "Montserrado County, February 4, 2009, Mr Edward T Zaymay." If I could turn to page 3. I am going to start where it says "that". It's in the middle of the page. You said:

    "That was how the old ma gave me US $10 and I left with tears in my eyes and I said to myself, 'I will return to this country and revenge,' and that was what motivated some of us to have taken arms against this Doe government. While it was sweet to other people, it was bitter cola to some of us. And so I left and make my way into exile and while there I met some soldiers, Namibians, civilians and others in exile and decided that we should remain there and rally and buy single barrel and enter Liberia because we are all trained the same way. That was our plan but there was no leader. It was Prince Johnson, Isaac Musa and by then Podier was in Abidjan. We remained there and if it were Butterfly that came as a leader and said to us let go, we would have done it and we will take him to be God and remained committed to him like Taylor. So we were there until Taylor came and recruited us and we pull out. Those day people in Nimba making their farms, citizens, killing them, there must be a stop to it. We were trained and we entered. I entered with Prince Johnson in Gbutuo with two single barrels and five stalks."

    Mr Zaymay, where in what I just read does the word "Libya" occur?

  • Excuse me. This statement, at first I was called to the TRC head office in Sinkor in Monrovia. That was where they recorded me when I explained everything. My statement was taken down and they told me that they were taking it to the TRC office. So it may be the people's error when they did not mention Libya, but I did explain to the people where I took my training and the type of training I undertook and how I entered.

  • Madam President, may I just have a moment. I want to be fair to the witness and true to what he said to the truth commission. I just want to find a reference I wasn't intending to refer to.

    I am grateful for the time. I have been unable to find what I am looking for. If I can locate it I will certainly come back to it:

  • Mr Zaymay, this is not a copy of a witness statement. This is a copy of the testimony that you gave on 4 February 2009, isn't it?

  • I was recorded when I gave my statement and when I entered into the hall, I explained the same thing. If the people - the people were the ones who were taking the record. If they did not mention if here, then they would have made the error. It was not me. How could - where would NPFL have come from to enter Liberia? Where was NPFL organised? I explained where I had come from.

  • Mr Zaymay, if you look at the document, the first page, it says "presenter" and from then onwards there is the record of your evidence that you gave and that's pages 1, 2, 3, 4, 5, and of 6 and then at page 6 we see questions from the commissioners and then the remaining pages are indeed those questions. Not so?

  • Yes, they asked me questions and I answered to them.

  • So the format that it took was yourself giving your testimony, your story, followed by the commissioners asking their questions to you, correct?

  • Yes.

  • But in the statement that I read to you, when you were giving your version of events, you don't mention Libya, do you?

  • I could remember explaining where I was trained. Where I was trained.

  • You don't mention Tajura, do you?

  • I mentioned where I was trained. I was trained in Tajura in Libya. I mentioned it. That was where NPFL was organised. That was where I saw Taylor. I explained.

  • You didn't mention at all about Libya, Tajura, training as Special Forces, when it was your turn to give your version of events, did you?

  • I said I explained. It might be an error from the people, but not me.

  • Did you not mention Libya in your story because you were trying to protect Mr Taylor?

  • I was trying to protect Mr Taylor? By what means?

  • Well, Mr Taylor didn't want people to know about him training Special Forces in Libya, did he? Do you remember that?

  • Your Honours, can he repeat his answer slowly.

  • Mr Witness, whatever you said has not been captured by the interpreter. Please repeat your answer slowly.

  • I am repeating it. I said, if I intended to tell them in Liberia, then why could I come here in an international war crime court and admit it here? I protect him in Liberia and not in a war crime court?

  • There was a time, wasn't there, Mr Zaymay, when Mr Taylor didn't want people to know about training in Libya, wasn't there?

  • There was no time that I know of.

  • So you are saying Mr Taylor has always said, 'Oh, yes, I was training Special Forces in Libya'? He has always been open and honest about that, has he?

  • He never told me. I was not close to Mr Taylor, but I knew where I was trained. It's not a secret. When NPFL entered Liberia, everybody knew where NPFL had come from. It was not in secret.

  • Mr Zaymay, I am not sure that you have really answered my question so I am going to try again. Mr Taylor has not always been completely open and honest about training Special Forces in Libya, has he?

  • So when you failed to mention Libya to the Truth and Reconciliation Commission when you were telling your version of events, was that because you were trying to protect Mr Taylor?

  • No. I was not protecting Mr Taylor. When NPFL entered Liberia, everybody knew where NPFL had come from. If I was protecting Mr Taylor in a common country like Liberia, what about here in an international court here?

  • I want to be a hundred per cent complete in having listened to what you have said to turn to page 7 of the testimony from the Truth and Reconciliation Commission. About halfway down the page there is a question from Commissioner Konneh. He says:

    "Mr Witness, we want to thank you for coming to testify in

    what you know and what you did during the Liberian civil

    war. For your general testimony, we gathered that you were

    one of those who went to Libya for training. Is that

    right?

    Response: Yes."

    Mr Witness that's all you told the Truth and Reconciliation Commission about Libya, isn't it?

  • Yes. They asked me this question, where I was trained, and I toad them I was trained in Libya. If I did not mention Libya in my testimony, how would they have asked this question?

  • I would like the witness to stay here where he is for a moment, because I am going to come back to the testimony. But if it's possible for the transcript of 11 May 2010 at page 40790 to be put on the screen, I would be grateful. I am at line 15, Mr Zaymay. This is an extract from your testimony to this Court during your evidence-in-chief at line 15:

    "Q. Do you know anyone by the name Dr Manneh?

    A. I heard about Dr Manneh, but I never saw him. I did

    not even know what he looked like.

    Q. What did you hear about Dr Manneh?

    A. I heard from some of the Senegambians that was

    assigned to Mr Taylor that their leader was called

    Dr Manneh, but I never saw him."

    Now, I would like you to - if we could all turn towards the end of the TRC transcript. It's page 21, right at the bottom. This is during the questions that are being asked to you.

    "Question: What will you say about other mercenaries like

    Dr Manneh?

    Response: No, I don't know Dr Manneh.

    Question: Coko Samba Samel from the Gambia known in

    Liberia as Dr Manneh in the NPFL, you never heard about him

    and you don't know him?

    Response: When we entered I got my instruction and I went

    straight to the front."

    Mr Zaymay, why, when you gave testimony before the Truth and Reconciliation Commission, did you say, "No, I don't know Dr Manneh," but also on oath to these judges you explained that in fact you did know who Dr Manneh was because you had been told by the Gambians that he was their leader?

  • Knowing somebody by name is different from hearing. Knowing somebody is different from hearing about somebody, okay? You can tell me that this is my leader, meaning Dr Manneh. It does not mean that I saw him and I knew - I saw him in person and I knew him. The people from Senegambia told him that - tell me that he was their leader. I did not see him to even know him and how he looked. So knowing somebody is different from hearing about somebody.

  • Isn't it the case that you are telling one thing to the Truth and Reconciliation Commission and another thing to these judges?

  • The TRC asked me if I knew Dr Manneh and I said, "No, I don't know Dr Manneh." I did not even see him in person, but I heard about him. That was what I told the TRC, and that's the same thing I am saying here. I did not see Dr Manneh in person. I heard from some of the Gambian guys that Dr Manneh was their leader.

  • If I could - and again please stay where you are for the moment. If I could refer to the trial transcript again at 11 May, page 40785.

  • We have the transcript.

  • I am grateful. I will start from the top.

  • We are talking here about your testimony regarding the Roosevelt Johnson incident.

    "A. First in 1998 after the elections in 1997. When

    Charles Taylor was elected President, the first attack in

    1998 by Roosevelt Johnson on Camp Johnson Road, September

    18.

    Q. What was the attack about? And again, just be very

    brief in your description of the attack?

    A. Roosevelt Johnson from the ULIMO-J, where he was living

    at Camp Johnson Road was declared by him as the Executive

    Mansion for ULIMO-J. They established a roadblock there.

    Nobody could pass through. So Mr Taylor ordered the ECOMOG

    commander that was assigned with Mr Taylor to go and tell

    Roosevelt Johnson to come to him. Why should he put a

    roadblock in the city? Roosevelt Johnson refused, so his

    man opened fire on the ECOMOG. The ECOMOG executed the man

    who opened fire on Roosevelt Johnson - on ECOMOG from

    Roosevelt Johnson. Then Taylor ordered Roosevelt Johnson's

    arrest. That was what brought the war, September 18.

    Q. And how did that war end?

    A. We fought the war. From the arrest, it turned into a

    war and we fought the war. Roosevelt Johnson escaped into

    the American embassy. That was where the war ended.

    Q. And when you say 'we fought the war' were you involved

    in the fighting?

    A. Yes.

    Q. And which unit in the AFL were fighting under?

    A. We had a combined AFL now. I had taken over my

    military police unit. All of us joined. The entire AFL,

    we attacked Roosevelt Johnson."

    Mr Zaymay, are you satisfied that that's a correct recollection of what happened on September 18?

  • Yes.

  • If I could refer to page 6 of the testimony from the Truth and Reconciliation Commission. Mr Zaymay, I am going to read what you told the Truth and Reconciliation Commission about the September 18 incident. I am at page 6. I am going to start where it says "That was where the incident". It's just above the middle of the page:

    "That was the incident that brought September 18 when the chief of staff report to the President that when Roosevelt remain on Camp Johnson Road he will create problem for the army and the President ordered his arrest from Camp Johnson Road and that was what that brought, September 18. He called and asked me Zaymay, are you in BTC? Yes, sir, I answered. You will close the gate and nobody will enter and order the Light Alert Force to move to me to defence, and they exchanged fire and Roosevelt is on his way to BTC, entered by the way of PHP and there was a heavy force of artillery headed by ATU from the mansion came by the way of Redemption Street and entered at the back of BTC fence with BZT and by then Roosevelt and his men were on the football field and when the heavy force came they all ran towards PHP. ATU took complete control, they put me in control and they went to do house search and anybody we find will be consider enemy."

    First, Mr Zaymay, what's PHP?

  • BHP - PHP is an area - it's an area by the BTC. It is an area where people live.

  • You know what PHP stands for?

  • No, I don't know what it stands for.

  • Now, when you testified about this incident to the Truth and Reconciliation Commission, you said that the reason for - that Charles Taylor ordered the arrest of Prince Johnson was that he was going to cause a problem for the army, didn't you?

  • Yes, for the army and the entire Liberian people - the entire Monrovia people.

  • But when you have given evidence about this incident before their Honours you have given a different version of events, haven't you?

  • What's the difference? Roosevelt Johnson declared himself President and placed a roadblock in the city. That was what brought the problem. What different statement that - have I made?

  • The version that you have given to these judges is that there was a roadblock, first of all, something you didn't mention to the Truth and Reconciliation Commission, and because of this roadblock, Charles Taylor orders ECOMOG to tell Roosevelt Johnson to report to him. He refuses, and Roosevelt Johnson's men open fire on the ECOMOG, and it's only then that Charles Taylor orders his arrest. So it's as a result of Roosevelt Johnson's men opening fire on the ECOMOG that Charles Taylor orders the arrest. That's what you are telling these judges. But you told the TRC that it was because a problem would be caused for the army. So there is two different version of events there, aren't there, Mr Zaymay?

  • The issue of Roosevelt Johnson came about as a result of the roadblock at Camp Johnson Road. And when he declared himself President, he said no other person can pass through that area. That was what caused the problem. Roosevelt Johnson's issue came about as a result of the roadblock. That's what caused the problem.

  • When you gave your version of events to these judges, you spoke about the AFL, didn't you?

  • But when you gave your version of events to the Truth and Reconciliation Commission, you talked about a heavy force of artillery headed by the ATU from the mansion, didn't you?

  • That was during the fighting now. At that time Roosevelt Johnson had created the problem. It was during the fighting.

  • I don't believe that answers my question. When you talked about your version of events to the Truth and Reconciliation Commission, you talked about a heavy force of artillery headed by the ATU from the mansion, didn't you?

  • And you referred to them coming by way of Redemption Street and entering the back of BTC fence with BZT, didn't you?

  • Yes.

  • And you said that the heavy force came and they ran towards the PHP.

  • And that the ATU took complete control.

  • Of the barracks, yes.

  • Now, when you gave your version to the TRC, you also said, "They put me in control and they went to do house search and anybody we find we will consider enemy." You didn't mention that to this tribunal, did you?

  • If I did not mention it, then I forgot.

  • Mr Witness, you're again giving one version of events to this tribunal when you gave a different version of events to the Truth and Reconciliation Commission.

  • What different version?

  • We don't need to go round in circles. Mr Witness, if we could refer to the witness summary provided. It's the third summary that was given, which was the second updated summary on the same day.

  • Excuse me. I explained the September 18 incident. What caused the September 18 war, I explained. If I did not mention ATU, it means that I forgot.

  • Just returning for a second to the version of events you did give to the TRC, when you said, "They went to do house search and anybody we find will be considered enemy," what did you mean by that?

  • Because Roosevelt Johnson's first incident - Roosevelt Johnson escaped and went to BTC, the military barracks. He called upon all the AFL to support him, and the AFL supported him and we fought and he escaped. So during the second time, September 18, when he went to the barracks - at that time I was at the defence. He went to the barracks. It was at that time that the chief of staff called me and said Roosevelt Johnson had gone to the barracks to look for manpower, because Roosevelt Johnson was in a faction, he was a ULIMO-J from the army, he had gone to the barracks to ask the army to join him. That was the time I moved there.

    When they met me they said, "Okay, we are going to do a house to house search in the barracks. Any AFL man who is discovered in any of the houses, it would mean that he was in support of Roosevelt Johnson. Why has he not joined the AFL to fight and he is in a house?" That was the reason they said they were going to do a house to house search in the barracks against the AFL who never took part in the war.

  • Roosevelt Johnson was staying in a neighbourhood with many Krahn people, wasn't he?

  • Yes, at that time he was still in the barracks.

  • So it was the Krahn people who were considered the enemies, wasn't it?

  • Not all Krahn people. Those who were loyal to Roosevelt Johnson. There was ULIMO-J. It was not all Krahn people who were members of ULIMO-J. Roosevelt Johnson's own faction group was called the ULIMO-J. So you had few of the Krahn people who were committed to him. It was not all the Krahn people that were enemies.

  • I want to refer to the third summary that was provided by the Defence, which is in fact a second updated summary provided also on 5 May this year. Mr Zaymay, I am going to read the first line of an additional summary that was provided by the Defence about your expected testimony. It says this:

    "W" - which is witness - "was MP commander in the AFL during the Camp Johnson Road incident in Monrovia in 1997."

    Why did you tell the lawyers that the Camp Johnson Road incident occurred in 1997? It occurs in 1998, doesn't it?

  • The Camp Johnson Road incident occurred September 18, 1990 - '97.

  • Very well. I am moving now to a different area, so the witness can return to his usual seat, if he is more comfortable there.

  • He is sitting in his usual --

  • [Microphone not activated].

  • If I could pull up another transcript, please. It's from 7 May this time, page 40710. I am going to read at line 2:

    "Q. Do you remember exactly when it was that you were

    transferred to Bomi Hills?

    A. I was transferred to Bomi Hills in February. Almost

    the February ending.

    Q. And what was your assignment in Bomi Hills?

    A. To take over as the 6th Battalion commander in Bomi as

    battalion commander."

    I am going to skip a bit and go down to line 25, please:

    "Q. Mr Zaymay, when you retreated from Monrovia you went

    to Kakata. For how long did you stay in Kakata?

    A. I stayed in Kakata from August 1990 up to the time I

    was transferred in February 1991 to Bomi.

    Q. When you took over the command of the 6th Battalion in

    Bomi, who were you taking over from?"

    A. I was succeeded by Oliver Varney.

    And then skip a bit again to page 40714.

  • Ms Howarth, it says he succeeded Oliver Varney. He was not succeeded by Oliver Varney.

  • Thank you. I am most grateful:

    "Q. For how long did you remain in Bomi - sorry, in Cape

    Mount?

    A. On the fact-finding mission that we went on?

    Q. No, when you took over from Oliver Varney, for how long

    were you in that assignment as commander?

    A. I remained there for - I cannot remember the exact time

    that I spent in command, but I remained there for a

    while. I can't give the exact figure."

    So, Mr Zaymay, this is your testimony on 7 May and you are telling us that you were appointed 6th Battalion commander, that you get this appointment in February of 1991 and that you succeed Oliver Varney. Is that correct?

  • Come again. Come again with your question.

  • I will break them down. You were appointed the 6th Battalion commander, weren't you?

  • And you told us that you got this appointment in February 1991?

  • Which one? Which assignment?

  • The appointment as 6th Battalion commander in Bomi?

  • No. Bomi - you mean 2nd Battalion is in Kakata to Monrovia and Bomi is 2nd Battalion.

  • So you are saying today that when you were - the appointment you received in February 1991 was to take control of the 2nd Battalion in Bomi, or are you telling us you were appointed 6th Battalion commander but not in Bomi? Please help if you can.

  • I was assigned as commander to attack Monrovia in July 1990 in the 2nd Battalion. That is between Kakata to Monrovia. And almost at the end of February, I was transferred to Bomi Hills in '91 as the 6th Battalion commander. 2nd Battalion controlled Kakata to Monrovia and 6th Battalion was located in Bomi Hills. So I was transferred to Bomi Hills at the end of February in 1991 as the 6th Battalion commander.

  • So why a few minutes ago did you say, "Bomi - you mean the 2nd"?

  • No, in Bomi it was 6th Battalion and 2nd Battalion was Monrovia. Kakata to Monrovia. And Bomi Hills was 6th Battalion.

  • And when asked about the time period that you spent as the 6th Battalion commander, you initially said that you couldn't remember the exact time but you remained there for a while, but you couldn't give the exact figure, correct?

  • Please pause, Mr Witness. Pause. Mr Chekera?

  • If learned counsel is following up on the transcript that was read, the answer related to his assignment in Maryland, not in Bomi.

  • Ms Howarth, what's your comment?

  • Without taking a moment to look at the transcript I am unable to immediately say. I didn't understand that to be the position. I obviously thought that he was referring to his appointment in Bomi. But certainly I'm happy to go to page 40713 just prior to that to try and clarify it, or otherwise it can be raised by my learned friend in his re-examination.

  • Not to the extent that counsel is quoting the wrong provisions in the transcript. That can addressed in re-exam. What we are saying is counsel should remain faithful to the transcript and that's not an issue for re-exam.

  • Ms Howarth, you should quote the transcript accurately to the witness when asking him questions. And try to look at the transcript that you want to refer to him and quote accurately, please.

  • Yes. Well, perhaps the easiest thing is to go back to that transcript. I certainly - my understanding was that that did refer to Bomi because of the discussion that goes on before that at the previous page. So perhaps I can bring that page up and we can clarify this matter. So it's 7 May 2010, 40713. I can't find a convenient point at 40713, but I might try and do it by looking at 40714 and asking the witness what he was referring to himself:

  • So, again, the question is:

    "Q. For how long did you remain in Bomi - sorry, in Cape

    Mount?

    A. On the fact-finding mission that we went on?

    Q. No, when you took over from - when you took over from

    Oliver Varney, for how long were you in that assignment as

    commander?

    A. I remained there for - I cannot remember the exact time

    that I spent in command, but I remained there for awhile.

    I can't give the exact figure."

    Now, the question there says when you took over from Oliver Varney, for how long were you in that assignment as commander. When you took over from Oliver Varney, which position did you occupy?

  • I took over from him as battalion commander over the 6th Battalion.

  • And where was that?

  • Madam President, in relation to the earlier objection, I do believe that the question referred to his appointment to 6th Battalion commander in Bomi from Oliver Varney. So I don't believe there was any misquoting of the transcript on my part there, but I will continue with the answer that's given:

  • You were then asked:

    "Q. For how long were you in that assignment as commander?

    A. I remained there for - I cannot remember the exact time

    that I spent in command, but I remained there for a while.

    I can't give the exact figure."

    So, Mr Zaymay, when you were asked by your lawyer on 7 May how long you occupied that position as 6th Battalion commander taking over from Oliver Varney, you couldn't recall how long you were in that position for, could you?

  • Yes. I can't remember for how long I was in that position, but it was from February to the end of 1991.

  • February, which year?

  • February 1991 to the end of 1991.

  • If I could please refer to the transcript of 11 May 2010, page 40742. I am looking at line 8. This is a transcript on 11 May. You are still being asked questions by your lawyer at this point. The question here is:

    "Q. Now, when you were in Bomi, where were you based?

    A. My headquarters was in Tubmanburg, the capital of Bomi

    County.

    Q. For how long were you in Bomi?

    A. I was in Bomi from the end of February up to - I was in

    Bomi for a year up to the time ULIMO attacked.

    Q. Sorry, end of February of which year, if you can just

    remind us again?"

  • Mr Howarth, we don't seem to be reading from the same transcript.

  • Is it possible to pull the transcript back up so I can see what was on the screen, please. It should be the previous page, 40742. That's 40743. It should be line 8 I referred to, beginning with "now, when you were in Bomi". I am so sorry if I was rushing ahead there:

  • So I will go back to line 8:

    "Now, when you were in Bomi, as you said you took over

    command from Oliver Varney of the 6th Battalion, which

    areas were you in control of?

    A. The 6th Battalion that I served as commander for

    controlled lower Lofa now called Gbarpolu County, Bomi

    county and Cape Mount. Three counties.

    Q. Now, besides Bomi and Cape Mount, where you came from,

    was the NPFL in control of any other areas in Liberia?"

  • Yes. NPFL was in --

  • Mr Witness, this is not a question to you. Counsel is just reading a copy of the transcript. It's not a question.

  • Okay.

  • Yes, I think I have just discovered the problem that Madam President was alluding to earlier. If I could just have one moment to check my own transcript, I would be very grateful. Perhaps I could continue reading from the transcript as it was on the screen, please:

  • So I had got as far as line 18:

    "Q. Now, who was in control of Lofa?

    A. Lofa was controlled by Anthony Mekunagbe.

    Q. Now, when you were in Bomi, where were you based?

    A. My headquarters was in Tubmanburg, the capital of Bomi

    County.

    Q. For how long were you in Bomi?

    A. I was in Bomi from the end of February up to - I was in

    Bomi for a year up to the time ULIMO attacked.

    Q. Sorry, end of February of which year? If you can just

    remind us again.

    A. February 1991.

    Q. Now, you mentioned an attack by ULIMO. The time that

    you went to Bomi, was there any fighting going on in Bomi?

    A. No.

    Q. And you said when ULIMO attacked. Do you remember

    exactly when it was that ULIMO attacked?

    A. ULIMO attacked mid-May 1991."

    Now, Mr Witness, I am confused because earlier in answering questions today you said you were appointed in February 1991 up to the end of that year and in your testimony here you say you're appointed in February for a year, which would be till February 1992, and then again you say your appointment runs until ULIMO attacks, which you said is mid-May 1991. Mr Zaymay, you are not clear when you were appointed, for how long you were appointed 6th Battalion commander, are you?

  • What do you mean? I am not clear like how?

  • Well, you have given three different versions of how long you held that position for. Haven't you?

  • I was in Bomi for almost a year, almost a year. For almost a year. I cannot remember the exact month or the exact time, that I continue to say.

  • Could I refer to a Prosecution exhibit and this is P-386. Mr Zaymay, are you able to see the document?

  • Yes, I can see it.

  • Now, this is a diagram that is drawn by another Defence witness, somebody called Yanks Smythe. Do you know who he is?

  • I know Yanks, yes.

  • And how do you know him?

  • I know Yanks to be one of the Senegambians.

  • And when did you get to know him?

  • I got to know him in Liberia. They were all assigned with Mr Taylor as special bodyguards.

  • And when was it that you got to know him?

  • I got to know Yanks - I got to know Yanks after Taylor was elected President. I used to see him sometimes when he went to the mansion.

  • And you know, don't you, that he was later appointed ambassador to Libya?

  • Not at my level. I was in the army. I did not know about ambassadors.

  • I appreciate that, but you do know that he at one point held that position, don't you?

  • Very well. Let's look at the diagram. Now, he was asked if he could draw a diagram of the NPFL command structure, and that's written at the top left-hand corner, and just beneath that he has put the date and the date that is there is "March 1991". Do you agree?

  • Read that. What? What company structure? I do not understand the handwriting.

  • Okay. In the top left-hand corner is written "NPFL command structure, March 1991". Do you understand?

  • And there is a box in - it's really in the middle of the page where the various battalions are listed. Can you see that? There is 1st, 2nd, 6th?

  • Yes, I can see 1st Battalion.

  • Next to that there's 2nd Battalion and next to that there is 6th Battalion?

  • And underneath 6th Battalion he has written the name Oliver Varney?

  • And his evidence to this Court was that Oliver Varney was the 6th Battalion commander. Do you follow?

  • So Yanks Smythe doesn't mention you as 6th Battalion commander, does he?

  • Yes, he did not mention me as 6th Battalion commander, but I was 6th Battalion commander in '91, to the end of '91. He might not know.

  • Yanks Smythe has got this right, hasn't he? It was Oliver Varney who was the 6th Battalion commander in March 1991 in Bomi Hills, isn't it?

  • No. Oliver Varney was - in 1990 Oliver Varney was sent from Buchanan to go and attack Bomi Hills and when he attacked Bomi Hills in 1990, and I succeeded him in 1991. This is a 1990 break down that you see here.

  • Are you saying Yanks Smythe lied to the Court when he said that Oliver Varney was a 6th Battalion commander in March 1991?

  • This is a mistake. It was in 1990 that Oliver Varney was battalion commander. He might have forgotten. This is a mistake. But I succeeded him in 1991.

  • Who was Oliver Varney's deputy?

  • Morris Mayer.

  • So he has got that part right, hasn't he?

  • You mean the Morris Mayer?

  • I cannot see anything. I can't understand the handwriting.

  • Yes. If you just - where it says "6th Battalion, Oliver Varney, Bomi Hills" there is a line that's drawn down from where it says "Oliver Varney"?

  • It says "Deputy Morris Mayers".

  • If we could refer to another trial transcript. This is the 29 April 2010 at page 40343. This is the testimony of Mr Mineh that he gave to this Court earlier on. At line 2:

    "A. I was in Harbel in 1990, at the end of 1990, then 1991

    I went to Gbarnga.

    Q. Did you stay long in Gbarnga?

    A. Yes, I was there for a while, yes.

    Q. And from Gbarnga did you go anywhere else?

    A. After I left Gbarnga Mr Taylor sent me to Cape Mount

    County.

    Q. And if you recall, when were you sent to Cape Mount

    County?

    A. It was in '91 in the middle. I can't remember the day

    because there was no rating document. It was in '91

    ending. In fact, in the middle."

    Skipping down to line 24:

    "Q. And were you fighting under any battalion when you

    went to Cape Mount?

    A. The battalion I was was 6th Battalion.

    Q. And who was leading the 6th Battalion?

    A. The head was Degbon. He was the overall commander, but

    my control area is Cape Mount.

    Q. Was Degbon leading the 6th Battalion?

    A. He was the head. He was the head of the Special

    Forces.

    Q. And was he in command of the 6th Battalion in Bomi?

    A. Yes, he was the head of all of us."

    Then skipping down to line 27 on the same page:

    "Q. When you were fighting under the 6th Battalion in Cape

    Mount, what was your position?

    A. I was company commander. I got other people under me.

    All of us, our leader, the head, was Degbon.

    Q. And who else was above you beside Degbon?

    A. Anthony Mekunagbe.

    Q. Anyone else?

    A. Oliver Varney."

    And then skipping down on the same page to line 22:

    "Q. The question that I asked you and I want you to answer

    directly if you can: What was Anthony Mekunagbe's

    position?

    A. He was dividing food and ammunition. That's what he

    controls.

    Q. And was he superior to you?

    A. Yes. Yes, he was superior to me.

    Q. And what was Oliver Varney's position?

    A. Oliver Varney, he was one of the leaders, yes, there."

    So, Mr Mineh doesn't mention you, 6th Battalion commander, does he?

  • Mr Mineh, when I was there as commander Mr Mineh was not there. Mr Mineh went there when I had been transferred. The first commander who was in Cape Mount was Moses Mahn. He was a Special Forces. Moses Mahn. He was the company commander in Cape Mount County.

  • Mr Howarth, I note that the transcript is referring to Mineh as M-E-H-N, which is also the name of somebody else we have heard, but I think this Mehn is the one that testified before the current witness, spelt M-I-N-E-H.

  • Yes, your Honour is quite right:

  • Mr Witness, Mr Mineh said it was the middle of 1991 that he was in Cape Mount. That's when you were there too, isn't it?

  • Yes, I was in Cape Mount during the time for the ULIMO attack.

  • So he puts you there at the same time, doesn't he?

  • But he doesn't know anything about you being the 6th Battalion commander because he is talking about Oliver Varney, isn't he?

  • Oliver Varney came there and met me there. All of them came as reinforcement.

  • We can have a look a bit more at what Mr Mineh says if we could please pull up the transcript of 3 May 2010, 40430.

  • Your Honour, I have the text transcript. It will just take me one moment to get the PDF version. Thank you.

  • Starting from the top of that page. Again this is Mr Mineh's testimony:

    "Q. Mr Witness, when you were a company commander, you

    said it was in the 6th Battalion, who were you answerable

    to?

    A. I report to joint chief of staff, the head of the

    entire army.

    Q. And who was that person at that time?

    A. The joint chief of staff was John Teah.

    Q. Mr Witness, as a company commander you were within a

    battalion of other companies, correct? You said you were a

    company commander of the 6th Battalion, so you were within

    your one company amongst three other companies that made up

    that battalion, right? Correct?

    A. Yes, go ahead. Yes.

    Q. And your battalion was based in Bomi, the 6th

    Battalion, at the time you were company commander, wasn't

    it?

    A. Yes, in Bomi.

    Q. And you say who was the battalion commander at this

    time?

    A. Cape Mount? Our head was - the overall head was Degbon

    Q. Was Degbon the battalion commander of the 6th

    Battalion?

    A. He was the head of Cape Mount control area.

    Q. Mr Witness, you are very much familiar with the

    structure of battalions and companies. You have told this

    Court that you served as battalion commander, before you

    had served as a company commander, you had operated within

    the battalion as the combat officer. Now, if you were a

    company in the 6th Battalion then there would have been a

    battalion commander. Isn't that the case? Wouldn't it

    have been the case for the 6th Battalion?

    A. Yes, it has a commander.

    Q. So who was the battalion commander for the 6th

    Battalion?

    A. 6th Battalion commander was Oliver Varney, but Degbon

    was the overall chief.

    Q. So Oliver Varney was answerable to Degbon. Is that

    what you are telling this Court?

    A. Yes.

    Q. Was Degbon based also in Bomi?

    A. Yes. We all were there. They all were there. After

    the war was raging, then they came. Wangakor.

    Q. What was Degbon's position actually?

    A. Degbon was the head, he was the overall chief.

    Q. Did his position have a name, a title?

    A. Yes, he was the head.

    Q. Do you get the question right? You have talked

    about - we know of a company commander, a battalion

    commander, but Degbon's position as your overall chief have

    a title. If you don't know, say you don't know, but that's

    the question.

    A. Yes, I cannot remember. But all I know is that he was

    the head battalion commander.

    Q. So from what you have told this Court, Degbon had

    supervision over everybody within the 6th Battalion, right?

    A. Yeah, we were under him. Everything was being

    administered by him.

    Q. Now, what about Anthony Mekunagbe?

    A. Mekunagbe, he was there. He was one of the - he was

    the supply officer for the arms and ammunition. Oliver and

    Degbon. They were all the big brass."

    Mr Zaymay, you are not included by this witness as being in the big brass, are you?

  • In what he said he did not make mention of me but I was there. I succeeded Oliver Varney in '91. After Oliver Varney had gone to Maryland, I was sent there to serve as battalion commander for 6th Battalion when ULIMO attacked in Bomi.

  • Mr Howarth, do you have any further questions arising from that particular transcript?

  • No, I don't at this moment. Thank you.

  • Then, in view of the time, we will take the luncheon break and reconvene at 2.30.

  • [Lunch break taken at 1.31 p.m.]

  • [Upon resuming at 2.30 p.m.]

  • Good afternoon. Ms Howarth, you were continuing with your cross-examination.

  • I'm grateful, Madam President. If I could just announce a change of appearance in the Prosecution Bench. Mr Nicholas has left us and we're joined by Ms Brenda J Hollis:

  • Now, Mr Zaymay, whilst giving evidence you have mentioned that you had a number of face-to-face conversations between yourself and Mr Taylor. Without going into great detail about each of those conversations, can you remind us, please, of the occasions where you've spoken face-to-face with Mr Taylor?

  • Where? In Liberia?

  • The ones that you've spoken about in evidence here. So, yes, some in Liberia and I believe also too in Danane in Ivory Coast,

  • Not Danane; Zongwe. I said in Zongwe before I left for Liberia, I met Mr Taylor the last time when we retreated from Guinea - when we were deported from Guinea, he came to Zongwe. And the group that I was in - the group that I was in to attack Liberia, he came to Zongwe and encouraged us. He spoke to us and reinforced the SOP. He said Prince Johnson was to take the group and his target was Gbutuo. That was the last time I saw him before we entered Liberia.

  • Perhaps I need to short-circuit this, but other conversations you've had with Mr Taylor included a conversation that took place in Danane in April 1990. This is just after you left Prince Johnson's group and you explained you spoke to Mr Taylor and he was lamenting about the progress of the war. Do you recall telling the Court about that?

  • Yes. When we broke away - when we escaped from Prince, he sent for T Zaymay, John Teah and Oliver Varney in Danane. When we went, he thanked us for the efforts we've made. He said we were to continue. Prince Johnson was alone. NPFL is the mother unit. So, Zaymay, you were to go as commander to Gbutuo. This happened in Danane.

  • That conversation where he asked you to go as commander to Gbutuo, that happened the following day, did it not?

  • Yes. After he had talked to us, we left that same day.

  • And it was another conversation that you had with Mr Taylor in Gborplay in 1990 where he called for you to report for supply and following that you say you successfully captured Tappita. That's correct, isn't it?

  • And another example is a conversation you have with Mr Taylor when you take over as commander, as you say, from Oliver Varney. Is that correct?

  • It was a radio message to me that I should leave and transfer to Maryland.

  • And, again, was that a direct communication between yourself and Mr Taylor speaking on the radio, or via radio operators?

  • It was a radio communication. When I was in Maryland, we talked one to one and we had a direct contact on radio.

  • When you say, "We talked one to one and we had a direct contact on radio," what do you mean?

  • I went to the radio station, and he told me how I was to disarm ECOMOG. That was what I meant by one to one.

  • Very well. Now, you also explained earlier this morning that when you went to Burkina Faso, you travelled with Mr Taylor. I take it you also had a conversation - or perhaps several conversations with him on that occasion. Is that fair to say?

  • He took me to Burkina Faso. I cannot go alone because I had not been there. We travelled. I cannot go alone, so he took me there and handed me over to his wife and he went back to Liberia.

  • Yes, I understand that from before. My question was simply whether any conversation took place between you and Mr Taylor on that occasion.

  • Yes. I was moving with him, so we were talking.

  • So you are somebody who has had conversations, one to one, with Mr Taylor on a number of occasions. That's fair to say, isn't it?

  • Yes.

  • Now, before the break we were talking about your appointment as 6th Battalion commander. Do you recall?

  • And we looked at a chart drawn by a Defence witness, Mr Yanks Smythe, in which he identified in March 1991 Oliver Varney as being the 6th Battalion commander. Do you recall?

  • Yes, I saw it here.

  • And then we looked at the evidence of Edward Mineh, and he also identified Oliver Varney as being the 6th Battalion commander. Do you recall that?

  • Yes, I saw Edward's own.

  • Now, I just want us to refer to the evidence that Mr Taylor has given in the case about yourself, Mr Zaymay. If I could ask for a transcript to be brought up, please. It's the transcript of 20 January 2010, page 33697. Now, if I could just go down to line 18, please. The question is this, and this is a transcript from Mr Taylor giving evidence:

    "Q. Now, Mr Taylor, we've talked before about Benjamin

    Yeaten, we've talked about Joe Tuah. Who was Edward

    Zaymay?

    A. Edward Zaymay is an Armed Forces of Liberia officer.

    Q. And had he been a part of your NPFL previously?

    A. Yes, Zaymay was one of the Special Forces."

    Now, Mr Zaymay, in all of the weeks that Mr Taylor gave testimony, this is all he had to say about you. He doesn't mention you as 6th Battalion commander. Another Defence witness, Mr Yanks Smythe, doesn't mention you as 6th Battalion commander, and your old acquaintance and friend Mr Mineh, he didn't mention you as 6th Battalion commander. Were you really 6th Battalion commander?

  • Oh, I will not tell lies. I served as a 6th Battalion commander from '91 to the ending to November, almost to the end of '91 and I was transferred to Bomi Hills. I was in Bomi Hills when ULIMO - the first and second attack by ULIMO occurred. When ULIMO attacked Liberia, I was in command of the 6th Battalion in Bomi. Why should I tell lies?

  • Well, Mr Witness, this is yet again another end date to your appointment as 6th battalion commander. You've just told us from '91 to the ending to November. Where does November suddenly come from? Earlier on it was one year. Then it was May. Were you ever 6th Battalion commander or are you just confused about whether you were there or not?

  • I said - I am still repeating it - I was transferred from the 2nd Battalion to the 6th Battalion. From the 2nd Battalion to the 6th Battalion in Bomi Hills as commander for the 6th Battalion. I was in command of the 6th Battalion when ULIMO first attacked and when it attacked the second time. At the time that ULIMO attacked, I was transferred to Maryland. I was commander for the 6th Battalion from February '91 to the ending of '91 in November. I was commander.

  • 1991 doesn't end in November, does it? It ends in December.

  • I said almost one year, from 1991, February, I took over the command up to November 1991 ending. Almost to the end. That's why I said I cannot tell the exact time that I spent in command.

  • This would have been a significant appointment, wouldn't it, the appointment as 6th Battalion commander? Is that fair to say?

  • Yes, I was 6th Battalion commander.

  • Then can you tell me this: When giving your story to the Truth and Reconciliation Commission, why did you not mention your significant appointment as 6th Battalion commander?

  • The TRC wrote me a letter saying that - and when I went, they told me to explain what the cause was for Liberia's civil crisis. I was to explain the cause of Liberia's civil crisis and I explained what I knew, what the cause was. They did not tell me when I was a commander. TRC only asked me to explain what I knew about the Liberia war, what the cause was, what caused us to take arms against a constituted government. And I explained. They never asked me when I was a commander or when I was a commander or when I was a commander.

  • But you had the opportunity to tell your story to the Truth and Reconciliation Commission. Why wasn't this significant appointment part of your story?

  • The way they introduced the issue to me, the way they introduced it, they never asked me to explain where I had commanded. They only asked me to explain the root cause of the Liberian civil crisis. That was what they indicated in the letter they sent to me. And when I went, they explained to me that I should explain the cause of the Liberian war, and I explained the cause of the war. They never asked me when I was in command, who was a commander, where I was in command, no.

  • Did you not tell them because you never were 6th Battalion commander?

  • I was not a 6th Battalion commander? I served as the 6th Battalion commander.

  • Did you not ask them because you didn't want them to know that you were 6th Battalion commander? I'm sorry. Did you not tell them because you didn't want them to know you were 6th Battalion commander?

  • But if I were to tell them that I was the 6th Battalion commander, what would have been the crime there? Would it have been a crime? Would it have been a crime if I had said I was the 6th Battalion commander? Would I have been a failure?

  • Well, in their report they have recommended a number of people for Prosecution, haven't they? You're aware of that, aren't you?

  • Did you not tell them that you were a 6th Battalion commander so that they wouldn't consider you as one of the people for potential Prosecution?

  • Oh, I entered with war. I entered with war and I attacked the constituted President at that time. That cannot prosecute me, except ---

  • Your Honours, can the witness be kindly requested to repeat his answer slowly.

  • Mr Witness, you were running too quickly with your testimony. Please repeat your answer slowly.

  • Okay, I repeat: I entered in Liberia with war and attacked the Samuel Kanyon Doe constitutionally elected government. If I was a battalion commander, would I be court-martialled? To fight in --

  • Your Honours, the witness is still speaking very fast.

  • Mr Witness, you are still speaking too fast. I did ask you to slow down. Now, you're going to start again where you said, "If I was a battalion commander, would I be court-martialled?" Now, continue from there slowly, please.

  • The question was like I was afraid because - I was afraid if I had said I was the 6th Battalion commander, I would be court-martialled. So I said, what is the big deal there? What is the crime there? I invaded Liberia. I attacked the constituted President at that time. It's not anything big. But if I said I was 6th Battalion commander, if I said I was 6th Battalion commander, then it will be big for me to attack the Liberian government at that time. And to be 6th Battalion commander, which would be bigger?

  • Now, you told us last week about your meetings with Mr Gray in Liberia. You said you met for two days and met for several hours on each of those days and that later on you were cross-examined on your statement by Silas and Logan. Can you tell me, on any of those occasions in Monrovia, did you - you never mentioned, did you, that you were the 6th Battalion commander? That's correct, isn't it?

  • I can't remember.

  • Please try to remember. On any of the occasions when you were talking to the lawyers in Monrovia, did you mention that you were 6th Battalion commander?

  • Yes.

  • Are you sure about that?

  • It's in my testimony, yes. I told them.

  • Well, can you help me as to why it never appeared in a summary of your evidence given to us by the Defence?

  • I explained that I was 6th Battalion commander and there was a question about when and where I commanded. And I told them that - I told them wherever I had commanded, here and there, from 2nd Battalion to 6th Battalion, from 6th Battalion to Maryland.

  • And who asked that question?

  • Mr Silas asked me this question.

  • And where was he when he asked that question?

  • He asked me in Liberia and here.

  • Mr Zaymay, that's not true, is it? Because if you had said that to your lawyers, they would have put that in the summary for the Prosecution, wouldn't they?

  • Oh, it's not in my testimony? It's not in my statement? It's not there?

  • No. Now, let's move on to your position as 1st Battalion commander.

    Madam President, I don't know if it's possible, but my view of the witness is actually obscured at the moment because there's a sort of arm that's stuck up. I don't know if it's possible to adjust it so that I can see him better, please.

  • Is that better, Ms Howarth?

  • [Microphone not activated]:

  • Now, Mr Zaymay, you've also told this Court that you were appointed as 1st Battalion commander in 1990. When do you say you were given that appointment?

  • Early in 1990.

  • Can you assist with a month, please?

  • It might be April.

  • And who appointed you?

  • And for how long do you say you hold this position?

  • And during this April, what was the 1st Battalion's area of operation?

  • To deploy from Gborplay along the border line to Gbutuo.

  • Now, last week you were asked by the lawyer for the Defence to write down the command structure of the NPFL in 1990. And as was pointed out by Madam President, you did not write your own name down as 1st Battalion commander. Why was that?

  • You asked me to write down the structure from 1990 to 1991. From 1990 to 1991. So I did it in 1990 to 1991, because one month's assignment I did not consider it to be any assignment. So I started from 1990, 1st Battalion upwards.

  • This is your first assignment as a battalion commander, wasn't it?

  • You forgot to write it down on the piece of paper, didn't you?

  • I decided that a month's assignment is not anything, so I took it as a deployment. That was why I never wrote it down. I went to the 2nd Battalion in 1990.

  • This is your first significant appointment in the NPFL, isn't it?

  • Yes, that was my first assignment in the NPFL.

  • You say you were assigned to this position by Mr Taylor?

  • But you're saying it wasn't important enough to write down. Is that your evidence?

  • Yes, because the assignment only lasted for a month.

  • Well, let's have a look at what some other people say about the 1st Battalion commander. Again, if we could look at Mr Mineh's evidence. If I could please refer to the trial transcript of 29 April 2010 and the page is 40326.

    I'm sorry. May I just have a moment, because I don't think my papers are quite in order. So sorry. Now, in relation to your role as - I'm going to abandon that for the moment because I haven't got the correct reference, so I'll come back to that, if I am able to, later on.

    Mr Zaymay, we've already referred to what Charles Taylor had to say about you in this case. He never mentions you as 1st Battalion commander. Again, is that because you never held this position?

  • 1st Battalion? I took it as a deployment.

  • The witness has mentioned this word "deployment" before when you asked him was that his first assignment. I'm afraid the subtleties of an assignment and of deployment are somewhat lost on me.

  • Mr Witness, you've heard the question from her Honour. Can you explain the difference between a deployment and an assignment?

  • Yes. Deployment is to take a unit and put them in position. An assignment is when you assign and command the unit.

  • Thank you.

  • Mr Witness, so in that case who is assigned and who is deployed?

  • The instruction that was given to me to go to Gbutuo, and I went there, it took me about a month and I was called back to move to Tappita. So I took this assignment as a deployment. That was why I never mentioned my command as --

  • Mr Witness, you've lost the question. We are trying to understand the difference between assignment and deployment. You've explained to us some things and I'm asking you: Between the commander and the people he commands, who is assigned and who is deployed?

  • Deployment means the subordinate whom a commander takes and puts in a position. That is what we call deployment. Assignment is where a commander takes complete control of the men.

  • I think that's clearer now. Ms Howarth, please continue.

  • I'm grateful. I did manage to use that time to find the reference that I was attempting to refer to before, so perhaps we could go back to that. The date was correct. It's 29 April 2010. The page should be 40328.

  • We have the page in front of us.

  • I'm at line 15. This is - Mr Zaymay, this is from Mr Mineh's testimony on 29 April:

    "Q. And when you were sent to Bassa, were you fighting in

    any battalion?

    A. Yes. After I was sent to Bassa, the man called Titus

    was removed and I replaced him.

    Q. What's the name again? The name of the person you

    replaced.

    A. Titus Menlee.

    Q. Sorry, the name again. Titus who?

    A. Titus Menlee. It's a Dan tribal word."

    Then the spelling is given:

    "Q. And you replaced Titus Menlee as what?

    A. 1st Battalion commander.

    Q. And was this still in 1990?

    A. Yes."

    Now, Mr Zaymay, Mr Mineh never mentions you as 1st Battalion commander, does he?

  • No.

  • In this piece of testimony, Mr Mineh refers to his own appointment as battalion commander, correct?

  • And it was his name, Mr Mineh's name, that when you were asked to write down the name of battalion commanders, you wrote his name down as 1st Battalion commander, didn't you? You got that right.

  • I - Mineh served as 1st Battalion commander. When I had the accident and went to Burkina Faso, I returned in July. When I came back in July, there was an attack. It was only Monrovia that was to be attacked, so I took over the 2nd Battalion command to enter - to attack Monrovia with the men. Mineh was coming in as a 1st Battalion commander to enter into Monrovia.

  • But Mr Mineh says that he replaced Titus Menlee as 1st Battalion commander. He says that, doesn't he?

  • He said - yes, I understand him saying that he replaced Titus Menlee as 1st Battalion commander. I understand that. Meaning he took over as 1st Battalion commander.

  • So when you were asked to write down who was 1st Battalion commander in 1990, not only did you forget to write your own name down, but you also forgot to write the name of Titus Menlee down, didn't you?

  • If Titus Menlee took over the command as 1st Battalion commander, then at that time I was in hospital. Any time Mr Taylor can make changes. If Titus Menlee was serving as the 1st Battalion commander, then I was in hospital. But when I returned in July, from April - when I returned in July, Edward Mineh - I was told that two commanders would enter Monrovia, 1st and 2nd battalions. So if we entered Monrovia - so if Edward Mineh delayed then, the attack by the 1st Battalion of the AFL would continue their target. So if Titus was in command, then at that time I was in hospital. I didn't know because I did not know when Bassa was attacked. I was not involved in the Bassa attack. At that time I was in hospital.

  • So what you're saying is there may have been appointments by Mr Taylor that you are simply not aware of. Is that right?

  • Yes, when I was in hospital.

  • Now, again, in relation to what you say is your appointment as 1st Battalion commander, this isn't something that's mentioned by Mr Taylor. Was that because you never had this appointment?

  • Oh, I was the first that took up assignment ordered by him and it only lasted for a month, and I had an accident and went to hospital. So I don't know why he doesn't talk about it.

  • You never mentioned this to the Truth and Reconciliation Commission either, did you?

  • I can't tell whether I spoke about it or not.

  • Would you like to have a look through the testimony of your - the transcript of your testimony and see if you can find it? Do you think it might be there?

  • If it is there, then I talked about it. If it's not there, then I didn't talk about it.

  • You didn't talk about it, did you?

  • I can't be exact. I can't remember.

  • I'll ask again. Would you like to have a look through and see if you can see it?

  • It is not important to me. That's why I said if it is there, then I talked about it. If it is not there, then I didn't talk about it. No need for me to look at it.

  • This is your first significant appointment in the NPFL. What do you mean it's not important to you? It was important to you, wasn't it?

  • I was appointed 1st Battalion commander and it lasted for a month. So to me, I did not consider it important. I took it as a deployment. Just to go and put men in position and later on move. That was how I took it to be. That's why I didn't mention it here.

  • Now, you've also given evidence about being 2nd Battalion commander, haven't you?

  • Would it surprise you to learn that Mr Taylor doesn't mention that and neither have any other witnesses for the Defence who have come here?

  • Yes, it surprises me because from hospital I took over the command to move to Monrovia and I moved the troops to Monrovia, and Sam Larto served as a battlefront commander.

  • Would it surprise you to learn that you never mentioned this to the TRC either?

  • I told you that the TRC only asked me what the root cause of the war was that I know about and that was what I explained. They did not ask me how many units I commanded. How would I talk about it? What they asked me to talk about was what I talked about.

  • And when you met with Mr Gray for two days in Monrovia and when you met again with Silas and Logan in Monrovia, not only did you not mention that you were 6th Battalion commander; you didn't mention about being 2nd Battalion commander and you didn't mention about being 1st Battalion commander either, did you?

  • Please pause, Mr Witness.

    Yes, Mr Chekera.

  • I do not know where those allegations are coming from. I would like to know before I make further submissions on the matter.

  • I think counsel is quite entitled to put statements to the witness. I know that she doesn't have the statements of the witness, but she is quite entitled to put a proposal to the witness and we would like to hear what the witness has to say about it.

    Ms Howarth, perhaps you could repeat the question.

  • Mr Zaymay, when you met with Mr Gray for two days in Monrovia and when you met again with Silas and Logan in Monrovia, not only did you not mention that you were 6th Battalion commander; you didn't mention about being 2nd Battalion commander and you didn't mention about being 1st Battalion commander either, did you?

  • Oh, I explained everything. I explained everything and I was asked from this assignment where next did you go? From this assignment, where did you go next, and I explained.

  • Madam President, I would like to refer to the first summary that we were given by the Defence, please:

  • Mr Zaymay, when you were giving evidence on Wednesday, you explained that you met with Mr Gray in Monrovia for those two days last year and also initially with Silas and Logan. Was that also last year?

  • Yes, last year. I can remember.

  • Now, I'm going to actually read out the summary that was provided to us, and this was most recently on 29 January 2010. It says this about you:

    "W" - which is witness - "was an AFL soldier in the Military Police in 1985, was exiled to the Ivory Coast where Charles Taylor took him and others to Libya to be trained as Special Forces. W" - witness - "was involved in the invasion of Monrovia under Charles Taylor's instructions not to attack the City Hall until ECOMOG arrived. W" - witness - "will testify that it was not in the AFL or NPFL standard operation procedure, SOP, to cut off the limbs of civilians; only to attack enemy forces during the rebellion in Liberia. No NPFL soldiers cut off any limbs. Only one time a boy got his hands blown off by a grenade. W" - witness - "will testify that they captured arms from the Doe forces and also details, arms deals in Foya, as well as detailing acquisition of military supplies."

    Mr Witness, that's all there is. Nowhere in that is any mention made of your appointment as 6th Battalion commander, as 1st Battalion commander, as 2nd Battalion commander. You didn't tell that to the Defence team, did you?

  • If it is not there, then I forgot to talk about it. If it's not there. But I know that I took over - I was assigned 1st Battalion commander among the entire Special Forces when we were called to Danane. Mr Taylor told me that he wanted - since Prince Johnson has left the base, Prince Johnson might not be in position to fight his way to Monrovia. So he might intend to retreat to go to the Ivory Coast. So, Zaymay, you are going as a 1st Battalion commander. Organise your men. Go to the base and select your men and move to Gbutuo and deploy from Gborplay to Gbutuo along the riverbank and I did that.

    And later, when I had the accident, when I returned, I took over the 2nd Battalion to enter Monrovia. From 2nd Battalion I was transferred to the 6th Battalion and I succeeded Oliver Varney at the 6th Battalion. I remained there during the ULIMO first and second attacks before I was transferred to Maryland. It happened.

  • Mr Zaymay, you told us on Wednesday that you spent two days with Mr Gray, correct?

  • You told us that you were there at 10 and that you left at 2 each day.

  • You told us that they took a statement from you, correct?

  • You told us that they recorded you while they were taking that statement, correct?

  • Then you told us that when Silas and Logan came to Monrovia, they cross-examined you on two occasions about your statement?

  • So that's eight hours spent with Mr Gray, approximately.

  • And then several hours again spent with Silas and Logan, correct?

  • Yes.

  • And despite all of these hours, are you now telling us that you completely forgot to mention that you were either 6th Battalion commander, 2nd Battalion commander, or 1st Battalion commander?

  • Yes, I said I believe that I said it. Whatever is not there means I have - I forgot. This whole issue that came about --

  • Your Honours, can the witness be kindly requested to repeat his answer slowly.

  • Please pause, Mr Witness. You have to repeat your answer slowly. The interpreter didn't get a word that you said. So repeat your answer, please, slowly.

  • Okay. I said during my statement the command, the assignment and assignment that you are talking about that it is not in my statement, that means I forgot. This whole issue here, the movement of the NPFL over 15 years back, it's not a kind of school where people go to take down notes. This is, when they ask you question, you will say, yes, this for the 5th grade or it's for government exam, or it's for the 9th grade. It is something that you are doing off the record. It is hard to even remember everything. So if anything happened in time of combat, if you say it's not in my statement, then I forgot. But it really happened.

  • Now, another thing that you've told these judges about is being the Military Police providing security for Mr Taylor when he came to Tajura. Do you recall giving evidence about that?

  • And is that - that's something else, isn't it, that you forgot to tell your lawyers when you met with them in Monrovia?

  • It is not in my statement that on the base I served as a Military Police commander.

  • Mr Zaymay, I read out a moment ago what was in the summary that had been provided and it wasn't there, but if you would like me to re-read it, I'm happy to do so. Do you agree that it wasn't in the summary that I read?

  • I can't tell.

  • Well, perhaps it is best for me to re-read it at the risk of repeating things. Mr Zaymay, the summary again says this:

    "Witness was an AFL soldier in the Military Police. In 1985 was exiled to the Ivory Coast where Charles Taylor took him and others to Libya to be trained as Special Forces."

    Then explains how you were involved in the invasion of Monrovia. It then talks about standard operation procedures and it then talks about the capture of arms from Doe forces, arms deal, and about the acquisition of military supplies. So, Mr Zaymay, nowhere in that summary does it say that you were the Military Police responsible for Charles Taylor's security in Tajura, so I'll repeat the question: That's something that you failed to mention - another thing that you failed to mention to your lawyers in Monrovia, isn't it.

  • When the lawyer asked me, I never explained about my Military Police function in Tajura. But he asked me that when Taylor came to the base, does he talk to so many people? And I said no. And he asked me how I knew. And I said, because I was providing security as Military Police during the training - during the training on the base. That was how I knew that nobody could visit him in Tajura.

  • Mr Witness, the question was this: That's something you failed to mention to the lawyers when you were speaking to them in Monrovia, isn't it?

  • Yes, I never mentioned it.

  • And, again, it's something that you never mentioned to the Truth and Reconciliation Commission, isn't it?

  • For the TRC, I can't remember.

  • I'm sure if you did, then your lawyers will point it out later on. Would it surprise you that Mr Taylor never mentioned your role as Military Police commander either? That's at Tajura, just to be clear.

  • That happened during the training - during the training. It was not an important issue. It happened during the training. But I myself does not take it important, because when my lawyer asked me how I knew that when Taylor came to the base he did not interact with people, where did he normally go? That was how my providing security came about.

  • Your friend and acquaintance, Mr Mineh, he also gave evidence about Tajura and about the training there. He didn't mention you and your role there as Military Police providing security to Mr Taylor either. Is that because you never had this role?

  • I never had the position where?

  • As Military Police in charge of Mr Taylor's security at Tajura.

  • On the base I was Military Police commander. That was where Mr Taylor built confidence in me and said that, "You are a career Military Police. When we go to Liberia, when we succeed, I'll make you Military Police commander for the AFL." That was where my recommendation came from and that was where my assignment came from. That was how my assignment came about. I was Military Police commander on the base.

  • I just want to spend a moment taking about the 3rd Battalion. Again, when you were asked to jot down who had the roles as battalion commanders in 1990 and then later 1991, in relation to the 3rd Battalion you named somebody called George K Tokpah. Do you recall giving that evidence?

  • Yes.

  • If I could ask for the transcript of 11 May at page - I'll just get this right before I say it. Yes, I'm sorry. It's actually 29 April 2010, and it's 40327, the bottom of that page, please. I'm sorry for the confusion. This is evidence given by Mr Mineh, and I'm reading from line 27:

    "Q. When you were advancing, Mr Mineh - when you were

    advancing and you went as far as Yekepa, were you fighting

    under any battalion?

    A. I was in a battalion. I was in the 3rd Battalion. The

    commander was George Karsuo and there I was until I was

    called.

    Q. Could we have the name of the commander again, the

    commander of the 3rd Battalion?

    A. That's what I said, his name is George Karsuo."

    And then that's spelled K-A-R-S-U-O. Mr Zaymay, this is a completely different person from the George K Tokpah that you named as 3rd Battalion commander, isn't it?