Mr Taylor, yesterday afternoon when we adjourned we were looking at the Twenty-First Progress Report of the Secretary-General on the United Nations Observer Mission in Liberia, dated 29 January 1997, and we concluded by looking at some statistics at the back of that document, and you will be pleased to know that I have no intentions of going back to that today. But I wonder if we could now, please, look behind divider 5. This is MFI-63. Do you have it, Mr Taylor?

Yes, I do.

Now, Mr Taylor, you were asked about this document and I would like us now, please, to look in a little bit more detail at this document. You will see that it's dated 16 December 1998. Is that correct?

That is correct.

Now, this would then be shortly before the Freetown invasion in January 1999, yes?

That is correct.

And we see that it's the Third Progress Report of the Secretary-General on the United Nations Observer Mission in Sierra Leone. Do you see that?

Yes, I do.

Can we start, please, at paragraph 2:

"Since my second progress report, the Government of Sierra Leone has continued its efforts to consolidate its position, to restore the stability of the country and to improve relations with its neighbours."

Did that include you, Mr Taylor?

That is correct, yes.

And what were those efforts taken by the Government of Sierra Leone to improve relations?

Discussions with the President, meeting at different fora and holding discussions.

"The government has launched initiatives to strengthen the civil service and to fight corruption. Sierra Leone is also increasingly active in the regional and international arena.

On 30 October 1998, the government launched a nationwide consultative exercise, organised with the support of the United Nations Development Programme, aimed at enhancing the capacity of government ministries, other national institutions and civil society to take charge of the development process. The consultations exercise is expected to conclude on 14 December with the adoption of a national consensus on major policy issues, including national reconciliation."

Now this:

"The government has also pursued legal proceedings against both military and civilian supporters of the illegal coup of May 1997 by the Armed Forces Revolutionary Council. On 19 October 1998, after a court martial had sentenced 34 officers found guilty of treason to death, 24 of them were executed by firing squad. The executions took place despite appeals from the United Nations High Commissioner for Human Rights and others, including myself, for a stay of execution and the grant of the right of appeal."

Now, Mr Taylor, what was your position as a member of the Committee of Five and a President within ECOWAS on that decision to execute the 24 officers without a right of appeal?

I was opposed to it.

Why?

Because at that particular time in the very middle of the crisis to engage in such, I just felt it would just exacerbate the situation and just cause a continuation of the conflict.

Now, were you alone in those views amongst your colleagues in ECOWAS?

No.

Who else shared that view?

Most of ECOWAS. Of course the five members of the committee opposed it, and most other - I would say about two-thirds or more of the member states opposed the execution.

Now, did the Committee of Five make known to President Kabbah their opposition to this move?

On the individual level, yes.

"On 23 October 1998, a jury at the High Court in Freetown found Corporal Foday Sankoh, the leader of the Revolutionary United Front, guilty of treason and related offences and sentenced him to death by hanging. Corporal Sankoh, who had not been legally represented during his trial, has now selected legal advisers to undertake his appeal following efforts by the government, with UNOMSIL assistance, to secure legal representation for him."

Mr Taylor, what was your personal view regarding the trial of Foday Sankoh at that point in time in October 1998?

Not really. I felt that it was just the wrong - probably the right step at the wrong time, generally.

Let's take that in two stages then. Why the right step?

Well, if the Government of Sierra Leone had some problems with Sankoh that - in fact, most of these were all political-type problems. We felt that the government should have secured peace and then pursue whatever legitimate or legal concerns it had. That's what I mean. The right step would be to pursue legal points. The wrong time would be, you don't do that until you have secured the peace and stabilised the country.

Now, were you alone in those views on the Committee of Five?

No.

Who else shared that view?

All members of the committee and most other members of ECOWAS.

"At their summit meeting in Abuja on 30 and 31 October 1998, the Heads of State and Government of the Economic Community of West African States agreed to combine the strengthening of its monitoring group ECOMOG with efforts at dialogue to achieve lasting peace and national reconciliation in Sierra Leone."

Sorry, Mr Griffiths. Ms Hollis.

Thank you, Madam President. Madam President, I rise to find what this relates to in cross-examination. The Prosecution did refer to this document in cross-examination. Our records indicate we referred only to paragraph 15 of this document. It is an MFI that the Defence introduced, and I believe they read it almost in toto during their direct examination. So the Prosecution is not sure what part of cross-examination this part of the document is referring to.

Mr Griffiths, are you repeating yourself?

No, I am not. The point being this: This was a document included by the Prosecution in the bundle of documents served on us for the cross-examination of the defendant, and yes, paragraph 15 was referred to in cross-examination. But in our submission, to rely on one paragraph without placing that paragraph in context is totally misleading, and in our submission we are entitled in re-examination to correct that misleading position, and that's all I am seeking to do, and I am not repeating myself.

Yes, I think you are entitled to do that. I will overrule the objection.

Now, Mr Taylor, did you attend that meeting in October?

Yes.

Let's go now then to the next paragraph, paragraph 6:

"On 7 December 1998, the chairman of the Security Council Sanctions Committee and permanent representative of Sweden, Ambassador Hans Dahlgren, arrived in Freetown for a four-day assessment mission."

Let's go to the bottom of the paragraph. "Ambassador Dahlgren also visited Monrovia." Did you meet with him, Mr Taylor?

Yes, I did.

So this was in early December 1998, yes? 7 December 1998?

Yes, that is correct.

What did you discuss with him?

Oh, naturally, the peace process in Sierra Leone, the fighting and Liberia's own unique role, and urging us to continue to do everything that we could to continue to push the peace process.

Now, you were still on the Committee of Five --

Just one question on that, Mr Griffiths. Mr Taylor, you were asked - you asked him did he meet Mr Dahlgren, and then you went on to say this was on 7 December 1998. Well, if you look at that passage, Mr Dahlgren spent four days in Sierra Leone from 7 December 1998. So when was it that Mr Taylor met him?

Very well.

When was it?

After the trip to Sierra Leone.

After the trip to Sierra Leone. Can you now recall the date?

Well, that would be - naturally, four days later would be about [Microphone not activated].

Now, one other matter, Mr Taylor. When we look at paragraph 7, you will see that President Kabbah went to The Gambia on 9 December, so that's two days after Ambassador Dahlgren arrived, and accepted an offer from the President of The Gambia to mediate a peace agreement with the rebels. Now, help us with this: What was the role of the Committee of Five?

To do exactly that. That was the role of the committee, to mediate.

Was Gambia a member of the Committee of Five?

No, Gambia not a member of the Committee of Five.

Were you aware that President Kabbah had done this?

No, I was not aware that he had done that. But it would not have mattered, because the appointment to that committee is done by the Heads of State. So while the gesture is good on the part of The Gambia and his acceptance, it really did not have any weight because it would still have to go to the committee. And may I just add, it is more than likely - in fact, probable - that if such a submission had gone to the Heads of State, it would have been accepted, because you wouldn't turn a colleague down. But it really didn't have any weight.

The document goes on to deal with a meeting held in the United Kingdom. We will skip that and can we now go, please, to paragraph 12 so that we can place paragraph 15 in context. We see that this section of the report is entitled "Relations between Sierra Leone and its Neighbours", yes?

Yes.

Paragraph 12:

"On 12 November 1998, at the invitation of President Lansana Conte of Guinea, President Ahmad Tejan Kabbah of Sierra Leone and President Charles Taylor of Liberia participated in an extraordinary summit meeting of the Mano River Union in Conakry. The summit was also attended by the Reverend Jesse Jackson, the presidential special envoy for the promotion of democracy and human rights in Africa, as well as my special representative for Sierra Leone and my representative for Liberia, Mr Felix Downes-Thomas.

In a communique issued after the meeting, the three Heads of State announced their decision to rejuvenate the Mano River Union. They further pledged to ensure the strict observance of the 1986 Non-aggression and Security Cooperation Agreement between Liberia, Sierra Leone and Guinea that had been signed and ratified by the three member states."

Now, do you recall that, Mr Taylor?

Yes, I do.

And Non-aggression and Security Cooperation Agreement, what was the thrust of that agreement?

It had to do with, on the security side, that if any citizen of any of the member states were involved in subversive activities in their country and escaped and came over to the other country, that individual would be arrested and sent back to that country. Economically, the borders would be open to permit free trade.

"Three Heads of State agreed to work collectively to restore peace in Sierra Leone and maintain stability in the sub-region.

After the summit, in a meeting with President Kabbah in Freetown, Reverend Jackson stressed the advantage of negotiations over confrontation and called for a negotiated settlement to the conflict in Sierra Leone. A Liberian delegation, led by the Minister of National Security, concluded a two-day visit to Sierra Leone on 9 December."

Now, that delegation, Mr Taylor, who went on it? Can you recall?

Yes, it was led by retired General Philip Kamah, former chief of staff of the armed forces that was Minister of National Security in my government.

What was the purpose of that delegation going to Sierra Leone?

Again, trying to allay the fears and the rumours of possible attacks from Liberia and the movement of arms and manpower across the border, just to assure them that we needed to work together closely and that between and amongst the security agencies, such cooperation would enhance the ability of either government in determining what was factual and what was just based on speculation.

Now, you see then that it says:

"The Liberian government subsequently announced that President Kabbah had agreed with President Taylor's request for cooperation on joint border patrols."

Had he done that, Mr Taylor?

Yes.

Now, when you came to that agreement with him, Mr Taylor, about joint border patrols, did President Kabbah express any misgivings about that?

No, he didn't.

I ask for this reason: If we keep our hand in that page and just go behind divider 11 to remind ourselves of the contents of a letter written by President Kabbah to the Secretary-General on 5 January. Do you recall that letter?

Yes.

So keep one hand in divider 5 and let's open divider 11, yes?

Yes.

Remember this letter dated 5 January 1999? Last paragraph, do you see it?

That is correct.

Middle of the paragraph:

"However, we cannot allow ourselves to be swayed by denials and unworkable proposals about border surveillance and joint patrols."

Now, can you help us as to why it is that at the beginning of December President Kabbah agreed with you on joint border patrols, but by 5 January he was writing to the Secretary-General suggesting that these border patrols were unworkable? Can you help us?

Well, the only thing I can say is that he was not being sincere to me in December when he agreed to the proposal.

Now, let's go back to behind divider 5, shall we. And we are now at paragraph 15, which you were cross-examined about, yes:

"While reaffirming its commitment to end the ongoing rebel war as soon as possible, the government has expressed its readiness to address any grievances the rebels might have on condition that they first stop fighting, lay down their arms and surrender to ECOMOG or UNOMSIL. There has also been discussion in government circles of a possible offer to provide safe passage to five persons identified as leaders of the two factions comprising the rebel forces - Johnny Paul Koroma and SAJ Musa of the AFRC and Sam Bockarie, Dennis Mingo, and Eldred Collins of the RUF - to leave the country for a non-neighbouring country of their choice."

Now, Mr Taylor, did you know about this?

At the time, yes, we were aware - I was aware.

And what was the full nature of the proposals?

It was mostly for these individuals to contact governments outside that would add in some way to the promotion of peace in Sierra Leone.

Yes. And why these five named individuals?

Well, these were the important - in fact, this constituted almost the leadership of the important leaders in the two groups.

Now, did President Kabbah discuss this with you, Mr Taylor?

No, he did not discuss it with me.

Did he discuss it with any representative of the Committee of Five?

I can't say. But in terms of the general briefing, when I say he did not discuss it with me, Kabbah and I didn't talk about it. The information reached to Heads of State through our various Foreign Ministries that these individuals were individuals that were being discussed as the leaders that would be given permission to travel outside in the pursuit of peace.

And these individuals, Mr Taylor, at the time did you know of SAJ Musa?

No, I didn't. I didn't know the person SAJ Musa, no.

Now, by this stage, Mr Taylor, had you met Sam Bockarie?

This is 1998?

This is December 1998.

I had met Sam Bockarie.

Did you discuss with Bockarie at this stage, in late 1998, at or about the time of this report to the Security Council, the possibility of him moving to Liberia?

No. 1998? No. December 1998, no. It was about bringing about a cessation of hostilities in Sierra Leone and coming to the peace table.

Now, what about Dennis Mingo, did you know this man?

No, I didn't know Dennis. I understand he was Liberian, but I didn't know him at all.

And what was Eldred Collins?

No, I did not know him.

Now, on this same note of these men possibly leaving Sierra Leone, let's look at the next paragraph:

"In this context, UNOMSIL has cooperated closely with the government and with ECOMOG in following up indications that SAJ Musa, along with several of his supporters, might be prepared to surrender to UNOMSIL. Despite suspicions that this reported offer might be a feint, UNOMSIL has made provisional preparations to accept the surrender of individuals or groups of rebels if this can be arranged under proper security conditions. UNOMSIL has also been in contact with SAJ Musa to try to secure the release of a Catholic priest, Father Mario Guerra, who was kidnapped near Makeni on 17 November by elements of the AFRC."

Now, was the kidnapping of that priest brought to the attention of the Committee of Five, Mr Taylor?

I can't say if the others knew, but this was widely reported. But it was not a formal thing presented to the committee.

Now, in relation to SAJ Musa, who is mentioned in paragraphs 15 and 16, and we see from paragraph 15 that he is referred to as AFRC, let us look at paragraph 18 to 23:

"On the basis of the information received by UNOMSIL on the strength, organisation and activities of the rebels, there appear to be six rebel battalion-type formations comprising approximately 300 fighters each. Two of these are primarily AFRC and are based in the north. The other four, believed to be RUF with some AFRC elements, are deployed around Kailahun."

Now, Mr Taylor, at this time, as a member of the Committee of Five, were you following developments in Sierra Leone?

Yes, we were developing - excuse me, we were following the development across the border, not in the minute details, but there were reports of clashes here and there. We were.

Now, were you aware of this deployment of primarily AFRC battalions in the north and RUF battalions in the Kailahun District? Were you aware of that?

Not in this kind of detail, but we knew that there was a division between these groups and they were separated, okay. And the northern part of Sierra Leone as mentioned here, that would be the AFRC. And around Kailahun, Kailahun would be toward, I am not sure if it's the east, that would be the RUF. So we were aware that there were conflicts between these two groups and they were not getting along since the intervention.

And going on to paragraph 19: "In the north of the country" - so that's where the AFRC are located according to paragraph 18?

That is correct.

"... and especially in the northwest, rebel attacks against civilians have persisted and have recently intensified. In the first few days of December 1998, a large rebel force moving southwards and westwards launched coordinated and well-planned attacks on several locations near the road from Freetown to the Guinean border, including Mange, Lunsar and Masiaka, inflicting heavy casualties on civilians and property damage and causing thousands to flee and take refuge in the capital and surrounding districts. This rebel force is believed to be under the command of SAJ Musa.

There is much speculation concerning the motive behind these attacks, which have taken place at a time when Musa has publicly offered to surrender to UNOMSIL. These atrocities are taking place against the background of a rift which appears to have arisen between the AFRC remnants in the north and the RUF in the east. ECOMOG and the Civil Defence Forces have done much to disrupt the supply of arms and ammunition from Kailahun to the rebels in the north.

In the northeast, the rebel capacity to concentrate and coordinate their forces appears to have eroded since the time of their attack on Kabala in July. The rebel concentration in Koinadugu area was broken up by combined efforts of reconstituted battalions of former soldiers of the Republic of Sierra Leone military forces and ECOMOG, thus reducing the threat to Makeni and to the Koidu-Lunsar road. Repeated rebel attempts to gain control of the diamond-rich Koindu area have been unsuccessful. However, the situation remains unpredictable and the area is still in danger from rebel attacks.

In the southeast, rebel attacks during October and November 1998 seemed designed to surround and cut off Kenema both from Freetown and from the Liberian border by controlling the road that links Daru with Joru and Zimmi. UNOMSIL, in close collaboration with ECOMOG and CDF units based at Kenema, is standing by in case the rebels' failure to achieve their objective should lead some of them to open talks with the government.

The south and southwest of the country, including Freetown, have remained calm, though tension in the capital rose during December following a rebel attack on the road linking Masiaka and Rogberi."

Now, Mr Taylor, before moving from this document, were you at any stage in contact in any way with that AFRC element led by SAJ Musa which was based in the north of Sierra Leone at any time in 1998?

No, not at all. But I think there is something more interesting here, because if we look at paragraph 19, based on your question, it is very clear even from this report now as I am looking at it that the northern part of the country that was controlled by the AFRC and SAJ Musa and their movement - for me, there is no question in my mind that the activities that occurred as they moved against civilians must be attributed to them. So, in fact, I have no contact with the AFRC whatsoever and so I was neither in contact with the AFRC as an organisation, nor with SAJ Musa as the leader.

So all of this stuff that we see here coming down that we even see - because some of the towns here leading from the north are towns have been brought about throughout this case as where atrocities came about, so now we can see that it's actually a result of the AFRC. I have no contact with them at all.

At any stage in 1998, Mr Taylor, did you have any contact with the AFRC?

None. None whatsoever.

Do you accept, Mr Taylor, that in 1998 you had contact with the RUF?

Oh, yes. Oh, yes.

Now, you were aware, were you not, Mr Taylor, that at some stage following the coup in May 1997, the RUF had joined with the AFRC?

That is correct.

When you met with Bockarie in 1998, did you discuss with him his links, if any, with the AFRC?

Yes, we talked about it.

And what was the nature of that conversation?

Exactly what was going on, why was all this conflict and still fighting against the government. And what we said, if I recall correctly, was that the links had been really broken with the AFRC and that the AFRC were insulting them, calling them bush people, they were not trained soldiers. And the professional ones had - you know, had separated themselves from the RUF and there was in fact a division. That's what he told me.

Well, we can put that document away now. That's all I'll ask you about that. Now, Mr Taylor, I want to ask you about another document that was placed before you by the Prosecution during the course of your cross-examination, and it's MFI-316.

Can I inquire - this document, I had not included it in the original bundle through an oversight. Could I ask that it be put right at the end of the bundle behind the last divider, please? It's MFI-316.

Now, Mr Taylor, do you recall being asked questions about selected passages of this document?

Yes.

Now, we see, don't we, that the document is headed "Charles M Taylor", yes?

Yes.

And if we could just quickly, first of all, skim through the document, we see that we have pages 3, 4, 5, then 10, 11 and 12. So we are missing in this bundle disclosed for cross-examination purposes pages 2, 6, 7, 8 and 9. They are missing, yes?

Yes.

Now, it was suggested to you, Mr Taylor, that the contents of this document is what you told Ramsey Clark, your then lawyer, yes?

That is correct.

Now, remind us, who was Ramsey Clark?

Ramsey Clark - well, I don't now how to put the verb now, but - is/was former Attorney General of the United States. He served during the Johnson Administration and was secured as my Defence counsel in the case of extradition of my person to Liberia.

Now, in your dealings with him, Mr Taylor, did you consider him to be a corrupt, unscrupulous lawyer?

Ramsey? No, no, no.

Now, let's have a look at this document in a bit more detail, shall we. Going back to page 4 - the first page, I am sorry:

"This profile of Charles Taylor is based on information from court records in US v Charles M Taylor, Magistrate's Docket No. 84-1251R in the United States District Court for the District of Massachusetts and attorney files."

Now, Mr Taylor, which court records are they?

United States Court.

Yes. Do you know what's contained in those court records?

No. I did not get copies of the court records.

What about the attorney files which is mentioned, what are the contents of those files?

I didn't have access to Ramsey's files.

Now, let's read the sentence again: "This profile is based on court records and attorney files." Does it say it's based on information provided by you?

No.

"For additional information or inquiries, contact Ramsey Clark or Lawrence W Schilling, 36 East 12th Street, New York."

Now, it sets out what's contained in the document, so we might get an idea of what the missing pages contained:

"I. General background, studies and activities in the United States;

II. Charles Taylor's return to Liberia and service as a Cabinet member;

III. Charles Taylor's flight from Liberia and the fabrication of embezzlement charges against him;

IV. The attempted extradition of Charles Taylor and his escape to fight for the overthrow of General Doe."

Let's move to page 3. The top of the page is obviously talking about the - an organisation that you were a member of, Mr Taylor. Do you see?

Yes.

"It had 50,000 members in 1979." What was the name of the organisation?

The Union of Liberian Associations in the Americas.

"Mr Taylor was a very active chairman of the union and focused its activities on conditions in Liberia, primarily the absence of democratic institutions, the stagnant economy and political repression.

II. Charles Taylor's return to Liberia and service as a Cabinet Minister.

On January 8, 1980, Mr Taylor returned to Liberia with a widely published delegation from the Union of Liberian Associations to discuss democratisation, economic reforms and human rights with the Tolbert government.

At the time of his return to Liberia, Mr Taylor had never heard of Samuel K Doe, who was then a sergeant in the Liberian army. Whilst his delegation was in Monrovia, Sergeant Doe staged a coup d'etat and seized power."

The first sentence in that paragraph, Mr Taylor, "At the time of the his return to Liberia, Mr Taylor had never heard of Samuel Doe", is that right?

100 per cent. I had never heard of him.

When did you first come into contact with him?

After the coup in April 1980.

"Mr Taylor began immediately after the coup to try to stop the wave of executions that shocked the world." Is that true?

That is true.

"President Tolbert was killed in the Executive Mansion. His ministers were tied to poles and publicly executed on the beach front without trials. A son was dragged from the French embassy and killed in the streets.

Because of his long, outspoken opposition to the Tolbert government, his preeminence amongst Liberians in the United States, his organisational skills and his education in economics were well known, Charles Taylor was quickly recruited by the Doe military government. He was made director of the General Services Administration in June 1980, a position he held until August 1983.

While in the United States Mr Taylor had always planned to return to Liberia, hoping to help it establish democratic institutions and achieve economic progress under the rule of law. Because of his activities in the United States protesting the Tolbert government, it was not safe for him to return while it was in power. Even his trip with the Union of Liberian Associations involved personal physical risk."

Is that true?

That is true.

"When the coup d'état occurred, Mr Taylor felt a patriotic duty to remain in Liberia and help his people at a very difficult, dangerous, but hopeful time of change. He was appalled by the violence of the coup and acts in its aftermath. Like everyone living there, he was aware of the executions, disappearances, torture, arbitrary arrests and exile inflicted by the military government, but he chose to stay and try to help.

As Director of the GSA, a major a Cabinet-level position which conducted all government purchasing, Mr Taylor wielded significant power. He was one of only three Americo-Liberians in a top or middle level position."

Is that true?

Yes.

Who were the other two?

The Foreign Minister, the late G Bacchus Matthews, and I would have to think quickly about the third person, but there were about - we were about three.

"The Americo-Liberians, descendants of the American slaves, while less than 3 per cent of the population of the country, had dominated the country politically, economically and socially since the 1840s. Sergeant Doe executed most Americo-Liberian leadership that did not flee the country. Despite his known opposition to the Tolbert regime and his valuable skills, Mr Taylor remained in Liberia at great personal risk. His wife gave birth to their two children in the United States in the early 1980s for safety as well as health reasons."

Which wife was that, Mr Taylor?

Enid, E-N-I-D.

"As director of GSA, Mr Taylor became painfully aware not only of the violent lawlessness of the military government, which was general knowledge, but also of official corruption which he observed firsthand because purchases and investments were made through his office. He had close regular contacts with Doe, not only as a Cabinet Minister, but as the person through whom Doe made extravagant purchases and investments."

Is that true?

That is true.

"Mr Taylor was under suspicion as an Americo-Liberian. This prejudice grew because of his criticisms of purchases by Doe and his military colleagues and because of his well known positions on democracy, economic reform and human rights. In a well publicised - if not unusual - episode, in 1981 Mr Taylor was arrested in his office, stripped naked, paraded through the streets, beaten, and placed in a maximum security jail for allegedly spreading anti-revolutionary documents against the government."

Is that true?

Not all of it is correct. I was arrested, I was stripped, paraded, but I was not - well, "beaten". I was hit a few times, but "beaten" for me - I wouldn't say beaten, but I was struck a few times.

"While Mr Taylor denied publishing the documents, they were similar to what he had said in opposition to the Tolbert government. He was released on the intervention and order of General Thomas Quiwonkpa, among others, a close personal friend and relative of his wife."

Is that true?

That is correct.

That's - which wife is that?

Same Enid. There is a nickname, Tupee. Enid/Tupee.

"After three weeks of medical treatment for injuries, cuts and bruises, he was reinstated at GSA, through he required continuing medical care.

It was later discovered that Dhillon Brothers had transferred $100,000 from the $900,000 to an account maintained by Taylor in the United States to cover unrelated monies they had received from Taylor in Liberia for transfer to his account in New York. These monies" - we are now on page 10, you see, so we have moved from 5 to 10, pages 6 to 9 not having been served?

Yes, Ms Hollis.

I do want to correct the record on this. In fact, the Defence was served the entire document on 4 December and then your Honours gave us an order to provide to your Honours and the Defence the portions of documents we were going to use, marked portions, and so the portions we were actually going to refer to were again served on 11 December. So the Defence has had the entire document since 4 December and all of the entire documents are available for inspection. The Defence has made no request to inspect any document.

Mr Griffiths, is that correct?

I have not seen the whole document. I don't know if Mr Munyard has.

I don't think Ms Hollis would be mistaken in this regard.

It may have been an oversight, but I don't recall seeing the whole document.

Well, then this appears to be the record, what Ms Hollis has stated.

I am sure my learned friend wouldn't have made that statement if it was not correct.

Okay. Please proceed.

"It was later discovered that Dhillon Brothers had transferred $100,000 from the $900,000 to an account maintained by Taylor in the United States to cover unrelated monies they had received from Taylor in Liberia for transfer to his account in New York. These monies belonged to a number of people whom Taylor refused to identify because their lives would be endangered in Liberia if the government knew who they were and that they were transferring money out of the country through Taylor. Apparently Dhillon Brothers had retained the $100,000 received from Taylor in Liberia, or transferred it elsewhere, and replaced it with $100,000 from the $900,000 on the parts contract. The Government of Liberia never claimed the $100,000 was illegally transferred to Taylor. It claimed Taylor took the entire $900,000, a fact disproved by bank records."

Now, Mr Taylor, those bank records, who provided them?

The bank, Citibank.

Where?

In New York.

And what did those bank records show?

That in fact the monies as transferred by the National Bank of Liberia did in fact go to the account of Dhillon Brothers and Dhillon Brothers did receive the money.

Now, that sentence was not put to you in cross-examination, but, Mr Taylor, is it right that the bank records disproved the suggestion made by the Doe government that you had embezzled this money?

Oh, definitely. Definitely.

"In the extradition proceedings, Taylor urged the obvious; that the reason for the extradition was political and that he would be killed if returned to Liberia. Indeed, he specifically declined to seek release on bail for reasons of safety of himself and his family. He presented volumes of evidence including United States State Department country reports, Amnesty International reports, scores of newspaper clippings, letters, documents, video tapes and testimony including that of J Thomas Woweiyu, then chairman of the Union of Liberian Associations, to prove Head of State Doe would kill him if he were extradited to Liberia."

Now, Mr Taylor, help us. Does the United States of America, like the United Kingdom, refused to extradite on political grounds where the extraditee is likely to be killed?

Definitely, yes, they do.

"In contrast, the Government of Liberia presented only a handful of documents, bolstered later by bank records secured by the FBI in an unprecedented effort to assist the foreign government in an extradition proceedings."

Now, were the FBI so involved on behalf of the Government of Liberia, Mr Taylor?

Oh, yes.

"The importance of the extradition to Liberia was underlined by the presence in the back of the courtroom of its Justice Minister Scott Jenkins who did not participate in the proceedings."

Do you know this Scott Jenkins?

Jenkins, very well.

Where is he now?

He's in Monrovia.

Doing what?

Really, nothing. In fact, subsequent - during my administration, Jenkins Scott was employed by me.

To do what?

He was made ambassador to Saudi Arabia. A very good friend of mine. Right now he is very ill - he has - he is very ill right now.

"There can be no question that the motive for the extradition was to secure the return of a political enemy. There was no merit to the money claim. While Charles Taylor was in jail in the United States, Doe increased repression in Liberia. In August scores of protesting students were shot on the campus of the University of Liberia by Doe's soldiers."

Is that true, Mr Taylor?

This is what was reported. I was --

How many were shot?

They talked about maybe a dozen or two.

And this happened on the campus of the university?

That is correct.

What were the students doing at the time when this occurred?

Well, according to what I heard - at this particular time I am in incarcerated - is that they were demonstrating for rights in Liberia.

"Taylor was kept in jail in Plymouth, Massachusetts, for over six months while the extradition proceeding droned on. During this time he spoke by telephone with General Thomas Quiwonkpa who was in Aberdeen, Maryland."

Is that true?

That is correct.

"He was visited by scores of friends, supporters and family.

Before the United States District Court ruled on his petition, he escaped on September 15, 1985. The escape was almost surely accomplished through the efforts of United States intelligence agents. Neither the United States, which arrested Mr Taylor only on an extradition request for Head of State Doe, nor the Commonwealth of Massachusetts has ever charged Mr Taylor with any offence, including escape, to the knowledge of counsel."

Within months of his escape, Taylor was in West Africa assisting General Quiwonkpa in a major military effort to overthrow Doe" - were you in Africa, Mr Taylor?

For this, no. I was not in Africa at the time of this.

"... one of the most violent military dictators in recent African history. General Quiwonkpa appears to have actually seized key military positions including the government TV-radio station and the Doe executive headquarters when he was killed in a surprise attack. He was beheaded, castrated, his body cut into pieces and publicly eaten by Doe troops. A large force waiting to invade Liberia to consolidate his victory was disbanded when key leaders were assassinated. In the wake of this failure thousands of Gio and Mano Liberians were killed. Charles Taylor escaped, but continued efforts to overthrow Doe" - is that true, Mr Taylor?

That is correct.

"... which led four years later to his invasion of Liberia in December 1989 which seems destined to remove Samuel K Doe from power."

Now a couple of questions I would like to ask you, Mr Taylor. First of all, we see below the name, the typed name Ramsey Clark, the date July 27, 1990. Where were you on 27 July 1990?

I was in Gborplay, Nimba County, inside Liberia.

So were you present in New York with your lawyer, giving instructions for the completion of this document?

No. No, no, no. No.

And for what purpose was this document created, this legal document?

I have no idea. I had not spoken to Ramsey since I came out of the United States into Africa and so I do not know the reason for the creation of this document.

There is one other matter I want to ask you about before I move on. You were cross-examined about this document, Mr Taylor, on 11 January 2010, and I am looking at page 33131 of the transcript. I wonder if we could put that up, please. Do we have it?

Yes.

And we see you were asked this question by Ms Hollis:

"Q. So he, that being Ramsey Clark, just made this up out

of thin air then, it wasn't based on what you told him?

A. If you give me a chance I will answer your question.

And we have all the chances still in this trial to ask

Ramsey why he said this and who represented this to him,

because I was still in New York when General Quiwonkpa was

killed. I was still in the United States. After I reached

Africa I called my counsel and informed him and he said,

'Well, Mr Taylor, I will inform the United States

government that you are out of the United States.' So I

did not in 1990, when I'm already fighting a war in

Liberia - in 1990 I am already fighting a war in Liberia.

When Ramsey constructed this statement I want to say that

he probably made an error about this. This is constructed

long after. So I did not tell Ramsey this and at the time

he wrote this, which is when I'm already fighting in

Liberia, he probably construed that this is a continuation.

But I'll tell you, because you've raised this, I'll make

sure we get an affidavit from Ramsey Clark stating that I

did not represent this to him and I would not lie about

this and I'll make sure we do this.

Q. We suggest you did lie about it and whatever you get

from him will be to cover up your lie."

Now, Mr Taylor, were you suggesting that you were going to get a former Attorney General, a well respected lawyer in the United States, to lie on your behalf?

No, not at all. I mean, it was just outrageous for counsel on the other side to even suggest - because Ramsey is very, very, very well known and respected. I guess what I am trying to emphasise here is that a man like Ramsey would not lie; whatever he represented was not based on what I had told him or spoken to him about.

We can put that document away now. Now, Mr Taylor, I want to ask you now, Mr Taylor, about one or two specific matters that were put to you on Tuesday, 2 February; Thursday, 4 February; and Friday, 5 February of this year. Okay?

Yes.

And there are about - there are 14 topics which I would like to cover with you. The first is this - and it might be helpful - can we put up the transcript for 2 February 2010 at page 34548. Do you have it, Mr Taylor?

Yes, I do.

Now, you see at the top of that page - it actually begins on the previous page, but it matters not. But just to put it in context, you were asked on a previous page:

"Q. Mr Taylor, yesterday afternoon at the close of the proceedings we were talking about your relationship with General Robert Yerks. Do you recall that?"

And you replied in the affirmative, and then we come to the top of the page.

A. And we had talked about General Yerks's association

with ITC and, Mr Taylor, General Yerks was also associated

with LISCR, correct?

A. To the best of my knowledge, I would think so, yes.

Q. ...he was a senior official in LISCR...

A. ...yes.

Q. ...General Yerks was a business associate of yours,

wasn't he?

A. ...no.

Q. And you had common business interests...

A. No...

Q. General Yerks was working to advance your public

message...

A. No...

Q. Indeed, Mr Taylor, you, through your government, used

LISCR as a way to obtain arms, isn't that correct?

A. Never, ever used LISCR to obtain arms ever.

Q. Indeed, you had funds diverted from LISCR that should

have gone to the regular channels, through the banking

system in Liberia. You had those funds diverted as payment

for arms, didn't you?"

Now, Mr Taylor, General Yerks, what nationality was he?

He is American.

And a general. A general in which army?

The United States army. A former lieutenant general.

And when you got to know him, was he still a member of the armed forces of the United States?

No. He had retired.

And what was he doing?

General Yerks was working with the original registry, the International Registry Incorporated that changed to LISCR. He had been working with them before.

And just where he mind us, what does the acronym LISCR stand for?

Liberian International Shipping --

Don't worry. Where was it based?

In the United States, in Maryland.

In Maryland. And help us: Which laws governed its operation?

Laws of the United States.

Could LISCR then have been subject to investigation by, for example, the FBI, the Federal Bureau of Investigation?

Most definitely, yes.

And also by American police authorities?

Yes.

To your knowledge, Mr Taylor, has LISCR ever been so investigated by the American authorities?

No.

Has it ever been brought to your attention that such an investigation has taken place?

No.

Have any court proceedings ever been taken against LISCR, to your knowledge, for corruption, involvement in shady dealings, or anything like that?

No.

So help me: As far as you are aware, was General Yerks ever subjected to any such investigation?

No.

Now, Mr Taylor, what is being hinted on that page is that you were involved with a former United States general in buying arms which were surreptitiously imported into Liberia. Is there any truth in that suggestion?

None whatsoever. None. None whatsoever.

Mr Taylor, your government has been subjected to various inquiries by the Security Council of the United Nations, hasn't it?

Yes.

Tell me, on any occasion has it been suggested to you that you were involved with General Yerks and LISCR in illegal, illicit arms importations?

No. Not with General Yerks, no.

Let's go over the page, please, to page 34549. Do you have it, Mr Taylor?

Yes, I do.

Your attention was drawn on the penultimate line on that page to MFI-105, which is a letter to General Yerks from Susan Rice. You remember us introducing that document?

Yes, I do.

Can we go over to the next page, please. It is headed "United States Department of State, Assistant Secretary of State for Africa Affairs" and it is dated September - it looks like 8, September 1999. It says, Mr Taylor:

"Dear General Yerks: Thank you for your fax letter of August 14 and your observations about Liberia and the sub-region.

We are pleased that Liberia has friends who can help guide it in the right direction."

And then this question is asked:

"Q. So General Yerks was having some success working on

behalf of the Government of Liberia, correct?

A. That is correct. As a friend of Liberia, yes.

Q. And we note, of course, that this is a September 1999

letter. And if we look at the third paragraph from the

bottom beginning 'the International Monetary Fund', we see

part way down that paragraph, 'The IMF recommends action on

three key economic issues'. We see two, the rice monopoly,

the petroleum monopoly and then the third one 'compensation

of Mobil Oil for losses suffered in 1996'. So, Mr Taylor,

in this letter there is no mention of Mobil Oil losses in

1999, is there?"

Now, there is a couple of things I want to ask you about that passage of testimony. The first is this: Who is - who was Susan Rice?

At the time she was Assistant Secretary of State for African Affairs at the State Department.

In which government?

That was in the government of former President William Jefferson Clinton.

Now, Mr Taylor, given Susan Rice's position, you say she was what again? Remind me.

The Assistant Secretary of State For African Affairs.

As the holder of that position, did she ever inquire of you regarding General Yerks, to whom she was writing, involvement in illegal arms shipments?

No.

Did she?

No.

Can you help us as to why a member of the US government was writing to this alleged arms dealer? Can you help us?

Well, the way you put it, I would just say the reason why she never - by "she" I mean the assistant Secretary of State - did not ask is because there was nothing unique about friends of countries writing the State Department to inquire or to ask certain issues on behalf of certain governments. There was nothing unique about this.

Now, help us with this, Mr Taylor: As we see in the middle of that page, you were asked - it was suggested that General Yerks was having some success working on behalf of the Government of Liberia. Now, in light of a topic to which I will be coming to a moment, was General Yerks paid for his efforts on behalf of the Liberian government?

No. This is why I quickly interjected "as a friend of Liberia".

Now, I ask for this reason, Mr Taylor, you see. Because the next passage of cross-examination, beginning on page 34551, you were asked about various companies employed by the Liberian government for public relations purposes. Do you recall this?

Yes, I do.

The first such company at line 4 is Hill & Knowlton, yes?

That is correct.

At line five, Swidlers, yes?

That is correct.

At line 29, Cohen & Woods, yes?

That is correct, yes.

And I don't ask that we move there yet, but on page 34553 you were also asked about a fourth company, James Waterman International, yes?

That is correct.

And then on page 34555, about a fifth company called Valis Associates; do you recall that?

Yes, I do.

Now, first of all, Mr Taylor, can you help us with this: Did you employ those five firms?

Yes. The government did, yes.

Why?

For the purposes mentioned: Public relations; lobbying on behalf of my government. These were the reasons.

Now, Mr Taylor, did you consider that you had an image problem why you needed to embark on this?

Well, I will take "you" in the plural. Yes.

Well, I was going to come to your government in a minute, but I'm starting with you personally to begin with.

I would say yes. I would say yes.

Did you consider that your government had an image problem?

Yes.

And what was the purpose, then, of hiring these public relations companies?

To be able to put across the views of the government, straighten out some of the misconceptions about the governments and what was going on, policies, programmes, keeping us in touch with certain basic laws of the United States that affected the United States' own ability to doing certain things outside. For example, I did not know at the time of the so-called Brooke, that is B-R-O-O-K-E, late Senator Brooke of Massachusetts - during the early years there was a Brooke amendment that barred the United States from giving any specific assistance to the Government of Liberia unless certain things were met. And so what these firms do, they go in, they dig up what the laws are and how they affect certain things, find ways to correct them. So they are very essential.

But, Mr Taylor, you had an ambassador in the United States, didn't you?

Yes. The ambassador has a function to represent the views of the government - or the President to that particular President, but some of the other economic and other issues that you find between states, you really, for the United States and its powers throughout the world and how very busy they are dealing with things across the board, you need to have your interests sought after vigorously. It is not just as simple as having an ambassador. It's a little deeper than that.

Now, was Liberia unique in employing such assistance?

Oh, no, no. Even major European countries that are major European countries pay lobbyists in Washington. There are just certain things that you need them. No, this was not unique to - for Liberia.

And tell me, is it merely countries who employ such lobbyists or do other legal entities to your knowledge employ such lobbyists in Washington?

Yes.

Like who?

Corporations do. Mostly public corporations. Major private corporations do that because - and there could be laws that could be put into place that could affect the business interests of those corporations, so they also employ lobbyists too.

Now, are we still on page 34551? Now I want to take these firms in turn, Mr Taylor, and seek your assistance with various matters. First of all, do you recall now when your government first employed Hill & Knowlton?

My government? That would be after I come to office, I would put that in about '97, late, when I come to offers, when my government employs Knowlton.

We see from line 14 that it was put to you that the services of that firm costs some $55,000 US, yes?

Yes.

Now, Mr Taylor, when you came to power, the government coffers in Liberia were somewhat bare, weren't they?

That is correct.

So why were you spending this kind of money on a public relations firm?

We came to power - because it was very necessary. We came to power on the very first note being opposed by the United States government. Individuals that ran in the presidential campaign, the present President of Liberia was assisted by the United States government in violation of our election laws. I was the candidate that was not wanted. So we were going uphill from day one and what we sought to do was the smart thing, to invest - we call this an investment into the future of my government.

Now, the second firm we see at line 21 was Swidler, yes?

Yes.

And we see that some $680,000 were paid to them during your presidency?

Uh-huh.

Now, can I ask another question, Mr Taylor. Were these firms hired consecutively or were they working in parallel with each other?

Some of them were working in parallel and some consecutively. Depending on what administration is in power. So you will see this is why they keep changing. If there is a Democrat administration in Washington, certain lobbyists are stronger. If there is a Republican administration, some of them become weaker and others become stronger. So that's why you will see sometimes we went along consecutively and sometimes in parallel.

Now, the third firm we see on the bottom line is Cohen & Woods, yes?

Yes.

And if we go to the next page, please, that was a firm of which one of the partners was Herman Cohen, yes?

That is correct.

Former United States Assistant Secretary of State for Africa, lines 4 and 5, do you see that?

Yes, I do.

Now, we know that you had met Howard Cohen during the course of the Liberian war, hadn't you?

Well, I think you meant to say Herman.

Herman Cohen.

Yes, that is correct.

Herman Cohen, during the course of the Liberian war. Is that correct?

That is correct.

Did you become friends at that time, Mr Taylor?

No. In fact, he was in office and he was very - we felt that he was very hard unnecessarily on the NPFL.

So why employ his firm?

Well, this meeting, if we recollect correctly, is around, what, '90, '91?

Yes.

And this here is around I think - this is about '98 or so when we employ him, several years later. We felt that out of office, some of these officials having looked back, formed different opinions and were better suited to stating the facts after the fact. That in fact what we saw at the time, there is a different side to this. Some people are blinded by this when they are in office because of different pressures, so we saw him. After serving as Assistant Secretary of State For African Affairs and having developed certain expertise on Africa, who would best be suited to go back and begin to lobby for any African country than he who was in charge and probably was in place when most of the bad decisions were made anyway.

Now, we see from line 27 on that page that his firm - the contract with his firm was worth some $300,000, yes?

Yeah, he personally took care of that portfolio. He, Herman.

He personally took care of the portfolio, yes?

That is correct. Yes.

Can we go to the next page, please, quickly. Bottom line. The fourth firm employed was James Waterman International, yes?

Well, I'm not sure because the Waterman situation is a little different.

Why is it different?

Because Waterman worked, if I am not mistaken, for an individual, on behalf of the Government of Liberia, but he was not paid for by the Government of Liberia.

Can we go to the next page, please. We see that it's put to you at line 3, they weren't actually working for the Government of Liberia. Line 6, they were working instead for a company known as AmLib United, yes?

Yes.

So when we go to line 24, that payment of $750,000, yes?

Yes.

Was that paid by the Government of Liberia or was it paid by AmLib?

It was paid by AmLib.

AmLib is what?

American Liberian - there was something like a little consortium wanting to do business in Liberia.

What kind of business?

They were interested in rail, rail, rail movement. The building of rail links in Liberia and bringing in trains for the transport of heavy items throughout the country.

Now, was that business project ever initiated?

Yes, it was initiated.

So they paid the $750,000 sum, yes?

That is correct.

Then can we go over the page, please, to look at the last such company. That's line 13, Valis Associates, do you see it?

Yes.

Now, what's your recollection of this fifth company, Mr Taylor?

I still have tried to get into my head - wrap around my head Valis. I don't really remember what Valis was all about. In a case like this and probably the reason why I don't recall is because sometimes you get a good recommendation and I will just say, "Okay, well go ahead and get it done." But I didn't have any interaction with Valis and really can't recall what this was all about.

In any event, when we go to page 34557, we see at line 8 that they were paid some half a million dollars, it was put to you, by the Government of Liberia, yes?

Yes.

Now, do you have any basis to dispute that they were paid this money by the Government of Liberia, Mr Taylor?

None. None whatsoever.

And we see, beginning at line 22 through line 25 on that page that, having done the sums, somewhere in the region of $1.5 million was expended by the Liberian government during your presidency on public relations. Mr Taylor, did you consider that money well spent?

I would say yes, it was well spent. Very well spent, yes.

What do you say to the suggestion that why, as President of an impoverished country, spend $1.5 million on this which could have been spent on schools, roads and other such beneficial projects? Why?

Well, maybe if that is suggested the parties would not understand the workings of governments and what countries have to do to secure their interests. I look at this, like I said earlier, as an investment. And quite frankly had we not done this, there were just so many other things coming down the road. For example, the Clinton administration imposed a travel ban on certain Liberian government officials a few months before the United Nations Security Council did. And our understanding was, because of the rumours and all of these things circulating in Washington, that the Clinton administration had planned to carry out more extraneous measures against our government, and it is because of the constant lobbying and explaining that those actions were in a way stayed and in some cases diluted.

So these are worthwhile investments on the part of almost every government, no matter how impoverished you are, you either do this or you sink. So if it was not essential I think they would close it down in the United States. But I considered this an investment and the suggestion from the Prosecution that it could have been spent better I think is nonsense.

Now, when we go quickly to the next page, which is page 34558, you were reminded, the bottom of that page, beginning at or about line 22, that during the time of the NPFL you had also engaged such companies, hadn't you?

That is correct.

Why?

Again, we were fighting a war and we were busy trying to get the United States - once you get the United States to something, my dear - excuse me - it's okay. Once the United States understands, you have free sailing. That's the way it works. And so while we were fighting as the NPFL - if we go back, you know, the first statement that we made was to show the United States government that this was not one of those crazy people - you know, groups going about. It was important. The world's only superpower, it's important to get these things straight. So we started from the NPFL to keep informing them all the way along that: Look, we are not some wild forest bunch just shooting all over the place. Here our goals, here are our objectives. It's important to do that, and we did.

Well, I am going to put a blunt suggestion to you, Mr Taylor, in anticipation of a possible future argument. Is it the case that you employed these public relations companies in order to disguise your own corruption, your abuse of human rights, your links with the RUF, and your generally destabilising presence in West Africa; is that why you did it?

Oh, no, no. These - no. And it has to be no because, in fact, the individuals that run these firms are decent, honourable individuals. They are covered by American law, and these are people of value and would not - in fact, some firms, from what I have been told in the future, would turn down certain requests to represent, you know, a government or an individual if they felt that it was not in their best interest. So I would categorically say no. These are well known, well positioned firms with a long history of decency. I would disagree.

I am going to move on to a third topic now that I would like you to deal with. Can we go to page 34571, please. Do we have it?

Yes, we do.

Now, the point I want to deal with here, Mr Taylor, is encapsulated in a submission made by Ms Hollis on 2 February beginning at line 3:

"...lead to the point I am making, and that is the limitations on ECOMOG as of 5 June 1998 which meant that their movements were known by the government, their frequencies and other things were known by the government."

Do you see?

Yes, I do.

Mr Taylor, do you recall us yesterday going through three reports by the Secretary-General to the Security Council in January, March and June 1998 setting out ECOMOG troop numbers in Liberia and the extent of their deployment?

That is correct.

Do you remember us going through that?

Uh-huh, yes.

Now, help us with this, Mr Taylor: What limitations were placed on their ability to do their job?

None whatsoever.

Help us, Mr Taylor. What control did you, as President of Liberia, have over them?

None.

Could you have, for example, dictated to the force commander where they were to be deployed?

No.

Could you, for example, have dictated to the force commander what radio frequencies --

Yes, Ms Hollis, you are on your feet.

I apologise for interrupting, but it took me a time to find the documents that defense counsel is referring to. The January, March and June documents to which he was referring were 1997, not 1998.

My fault, and I am grateful to my learned friend, as ever, for the correction. 1997:

1998, Mr Taylor, my fault. In 1998, Mr Taylor - no, will let me start again and let me now go back to 1997.

Do you recall us looking at those three documents, Mr Taylor, relating to 1997, yes?

Yes.

The lead-up to the election?

The second - we looked at the second and third reports.

And we looked at January, March and June reports 1997 leading up to the elections, didn't we?

Well - it looks a little later to me though. Because we started from the third report and came to the second. The third report was about, I think, October-November, and then we came back down.

Well, Mr Taylor, I am not going to waste time now talking about the details of them. But in general terms --

I remember the reports.

-- do you remember us looking at some documents in that regard, yes?

Yes.

And remember you explaining to us that that situation obtained until the last quarter of 1997, do you remember, in terms of deployment, troop numbers, and so on, yes?

Yes.

Now, what happened in terms of troop numbers and deployment after October-November 1997? Let's start with troop numbers. Did they remain in the same in 1998?

No. If my recollection is correct, we are up to 11,000 for the elections. After that, by September, the date you are talking about, we are - beginning 1998, we are beginning to see the drawdown into Sierra Leone, so there is a - so the reduction starts.

Right. And when does the reduction start, Mr Taylor?

I would put it to about the - beginning the end of 1997 and progressing we begin to see some movement.

Yes. And by about the middle of 1998, Mr Taylor, what kind of troop strengths are we talking about with ECOMOG in Liberia? Can you assist?

Yes. I mean, it's - I can't give the exact number, but there are still a few battalions in Liberia.

Yes. And where are they located?

They are located in Monrovia, the environs, all major entries into the city limits. They are deployed, if I am not mistaken, still in the - along the Cape Mount-Sierra Leone border area. They are still that general area.

What about Roberts International Airport?

Oh, yes, they are at the airport. That's what I mean by the environs. The airport is just about 25 miles --

What about The Freeport in Monrovia?

They are in The Freeport. They are at Spriggs Payne Airport, the second airport in the city.

What about in Lofa?

At this time, by 19 - yes, we do have a few soldiers still there mostly on the Sierra Leonean border side; that is, Lofa, I mentioned, Cape Mount. Coming along that area there are some soldiers deployed there.

Now let's go back to my theme. What control did you have over them in 1998?

None. I did not have control over ECOMOG and could not order the commanding general of ECOMOG at all.

And tell me, Mr Taylor - and I hope that page 34571 is still up on the screen - before ECOMOG troops could move, did they have to inform you of such movement?

Yes. In some cases they would inform the Defence for coordinating purposes. Defence would be informed. Our Defence Ministry would be informed, not me personally. But I would say that's informing me. If the Defence Ministry is informed, we can assume that's informing me.

And just help us as to how that procedure would operate.

It would be - it would be - it's not a process of consent; it's a process of information. On this date we are moving for this, this, this. They don't have to - and sometimes it was announced at the very last minute. It's not like seeking permission. Would you please give me permission to go to X place or Y place? No. It was a process of informing, for the purposes of coordination, that security forces would not get mixed up.

Could you - did you have the power to say to them, if they so informed you: No, we are not going to allow you to go there?

Well, that's a little - I would say yes and no. And let me - you know, it sounds crazy, but it's yes and no. Did I have the power? Yes. But would that have been something that they would have listened to? No. So the power would not have meant anything, so I would have to say no.

Now, going back to that proposition that was put to the Court on that date, their frequency and other things were known by the government, were they?

The frequencies?

Line 5 and 6, their frequencies and other things were known by the government?

Yeah, the frequencies were known by the government.

How did that operate procedurally?

What the government would do - and I am glad they say frequencies - there would be about maybe 15, 20. They would submit and - that we will be operating on these frequencies and because these frequencies are - frequencies are given to server entities in the country. In order that you do not cross or lap over, you have to inform so the government would be able to say you can operate from this place to this place. That's different from trying to seek permission. No, it doesn't - it's for matter of control in terms of making sure there was no overlapping of frequencies, as you will do, for example, in like the air traffic controllers. You want to make sure that certain people know where they operate in certain limits that you do not cross over. So to the extent that the government would know, that's their knowledge of certain number of frequencies and it should not be construed as even monitoring. Just knowing that - let's say between - let's say - just five numbers. 70100, so you will be told you can operate from 70100 to 70125. Like, you have about 25 frequencies in that range, okay? That's - this is what they are referring to here.

Now, so we have this situation. They inform you of movement, yes?

Uh-huh, yes.

You have access to their frequencies?

Yes.

The blunt question I am going to ask you is this, Mr Taylor: Did you take advantage of that knowledge to facilitate the transfer of arms and ammunition to Sierra Leone?

No.

Do you follow me?

I follow you. No, not at all.

And help us. During what period did those arrangements operate; provision of information, sharing of frequencies?

This came about from the beginning of my government, but it had been in place from the Council of State. These frequencies were just a continuation of what had been approved by preceding Councils of State. So this is a long range thing.

And for the sake of the record and the Court, these are not scrambled frequencies. These are ordinary radio frequencies that anyone knowing can go into. So the suggestion that we could go out, anybody could monitor any frequency at anytime.

And can we go - I think I have enough time - quickly to page 34573, please. I want to finish this topic. Are we there?

Uh-huh.

On that page you will see at line 13 this proposition is put to you:

"Mr Taylor, the ability for ECOMOG to function independently was very restricted during its time in Liberia. Isn't this correct?"

Mr Taylor, you answer not correct. Mr Taylor, who commanded the ECOMOG troops in Liberia?

The forces commander of ECOMOG.

And to whom was the forces commander answerable?

I would say two persons: To the chairman of ECOWAS and his home President.

And the majority of ECOMOG troops in Liberia came from where?

Let me just - from Nigeria. All, except one, the first one. So major is even an understatement. All, except one.

How much time do I have, Madam President, can I inquire?

[Microphone not activated].

Two minutes.

[Microphone not activated].

One minute. Could I reserve the conclusion of this category, because I won't be able to conclude it in a minute, until after the break?

That's fair enough. We will take our mid-morning break and resume at 12 o'clock.

Mr Taylor, before the short adjournment we were considering ECOMOG, its role and independence in Liberia, yes?

That is correct.

Before we move on to another topic, Mr Taylor, can I ask you this: You told us a couple of days ago about being provided with, when you were on the council, a platoon of ECOMOG soldiers?

A company.

A company, yes?

That is correct.

Now, the soldiers in that company, where were they from?

Nigeria.

Apart from that assistance, did the Nigerians provide you with any other assistance?

Yes, they did.

What was that?

They also - this is following my election, in addition the Secret Service of Nigeria, President Abacha provided for me about 35 to 40 members of the Nigerian Secret Service to provide Secret Service close quarter security for my person.

And when was that?

As of 1997, August when I took the oath of office.

And for how long did they stay?

They remained there throughout 1998.

Now, the fourth topic arising from your cross-examination on 2, 4 and 5 February that I want to deal is this.

Madam Court Manager, could we please go to page 34573, transcript for 2 February. Now, Mr Taylor, the fourth topic I want to talk to you about is Sam Bockarie, okay?

Yes.

Now, if we look just below where we concluded just before the break at line 17, do you see that?

Yes.

"Mr Taylor, you talked to this Court about Sam Bockarie's presence in Liberia." Do you see that?

Yes, I did.

Then can we move to the next page, please, Madam Court Manager. You go on on the next page to deal with when Bockarie moved to Liberia. Do you see that?

Yes, I do.

And then a suggestion is put to you at line 6, Mr Taylor: "Sam Bockarie first comes to visit you in Liberia in February or early March 1998. Isn't that correct?" And you say, "We disagree." Yes?

That is correct.

Help us, Mr Taylor, when was the ECOMOG intervention?

The intervention was on the - from my knowledge, 14 February 1998 it ended.

And, Mr Taylor, as far as you're aware, what was happening in Sierra Leone in February and March 1998?

The intervention takes place, massive problems, a series of meetings. March, if I'm not mistaken, March, April, Kabbah returns. So there were a series of activities, conflict going on at the time.

Now, during that period of conflict, Mr Taylor, do you recall Bockarie coming to Liberia?

No.

Did he, for example, come to seek advice?

No.

Did you, for example, ask him to come to Liberia to provide him with information?

No.

At this stage in February or March, Mr Taylor, were you in contact with the RUF?

Not at all. Not at all.

What about by radio, say?

No.

Now, having put that suggestion, you were then asked this question starting at line 10, and I paraphrase: Whether Bockarie's movement to Liberia in December 1998 was with the knowledge of President Kabbah of Sierra Leone. Do you see that?

Yes.

And you answer that Kabbah knew?

Yes.

And then you go to say at line 17: "Kabbah was not consulted", yes?

That is correct.

Now help us, Mr Taylor. When you say that Kabbah knew, firstly, how do you know that?

Well, when Obasanjo came and the decision was taken, Obasanjo said that he was going to take upon himself to inform Kabbah, so I believe that he did. I know he did, I mean. He wouldn't lie about it.

Why didn't you tell him, given that he was coming to Liberia and not Nigeria?

Simply because again the powerful role of Nigeria in West Africa. Some of these matters when you have problems and accusations, sometimes it was better for Obasanjo, who was the powerhouse of the biggest West African country, to convey that - that a decision had been taken for this happen.

Now, the other word used in the two questions asked of you on this topic was "was Kabbah consulted". Was he consulted?

No, he was not.

Why not?

Kabbah - there was no need to - he was a party - Kabbah was a party to the conflict in Sierra Leone and his government, and when you are mediating and dealing with people, you don't go about going through all of these things - what was at stake at this particular time was the disarmament of the parties in Sierra Leone. A conflict had arisen. Sam Bockarie was immaterial, as far as all of us were concerned, because don't forget Foday Sankoh is on the ground. Foday Sankoh is the leader at this particular - excuse me. He is the leader, and so if you want - if you were dealing with Foday Sankoh, then fine, it would have been logical to talk to Kabbah. But this confusion between Sankoh and Sam Bockarie that lead to the decision to extract Sam Bockarie from the RUF where Foday Sankoh is present, I didn't see, neither did Obasanjo see, any need to inform him - I mean, to consult him. Because consultation, for me, would mean seeking his advice and/or acquiescence, and we didn't see it at that time as being necessary.

Yes. But, Mr Taylor, it might have avoided a lot of misunderstanding later if you had said to President Kabbah, "Look, we think it's in the best interests of peace to bring this obstacle to peace to Liberia", and that could have saved a lot of future misunderstanding between the two of you, couldn't it? So why didn't you do that?

Well, I could agree with your assumption there, but it was for Foday Sankoh, the Vice-President, to tell his President what action he had agreed with in line with other ECOWAS leaders to move one of his commanders. That's - for us, who was Sam Bockarie? Sam Bockarie was Foday Sankoh's commander. Foday Sankoh is the Vice-President. He's in this meeting when this decision is taken. So what is there again? It is Foday Sankoh's responsibility, if anything, to go back and his President and say well look, I have removed my - you know, we met, you know, with two West African leaders and the decision had been taken, and I agree, to move my commander to Liberia. So quite frankly, in the afterthought, of course anyone can sit now and say: Maybe you should have done it. Maybe we should have, but we didn't see it that way at the time.

Let's go back to that page, shall we, yes? Of course Kabbah knew, you say. And that he was in agreement with this, you were asked.

"A. Well, Kabbah was not consulted, they didn't take his

agreement. I said but he knew. But I would disagree that

it was done with his - his participation, where we're

leading, no, it did not take his agreement.

Q. Was he in agreement with Sam Bockarie coming to Liberia

with his men in December 1999?

A. I don't know. He was told that Sam Bockarie will be

moving. ECOWAS told and everybody else so I --

Excuse me, Mr Taylor, who told President

Taylor that Sam Bockarie was moving?

I told him. Obasanjo told him.

Q. When you told him this, you didn't ask for his response

to that?

A. We did not ask for his acquiescence. We told him what

the decision had been because he was a party to this - he

was a party to the conflict, and at that particular time

within the RUF, once it had been agreed by Sankoh and

ECOWAS, we told him what the decision was. We didn't ask.

I didn't ask his opinion. I told him that we had had a

meeting in Monrovia, that President Obasanjo had come over

and we had met and we had decided, in the presence United

Nations, a representative to Liberia, that the best way to

move forward with the peace was for Sam Bockarie to be

removed from Liberia and that's what I told him."

But that's an error. I misspoke there again.

What?

I said that's an error because I misspoke there in the records. It should have been "removed from Sierra Leone".

"Removed from Sierra Leone"?

Yes, it's an error in the record.

"Q. Mr Taylor, is it your testimony that while Sam

Bockarie was in Liberia, you kept President Kabbah apprised

of his presence in Liberia?

A. I didn't have to. No, I'm not - that's not my

testimony to this Court."

Now, Mr Taylor, let's pause there for a minute. So what you're saying there, putting it all together, firstly, Kabbah wasn't consulted in the first place, yes.

That is correct.

He's only informed after the event, yes?

Yes.

And, thirdly, it would appear you didn't keep him up to date as to what was happening with Bockarie whilst in Monrovia. Is that true?

Yes, that is true. I didn't report to him. I didn't keep him informed.

When, for example, Mr Taylor, Bockarie's men were granted Liberian citizenship and incorporated into the - recruited into the ATU, why didn't you tell Kabbah about that?

I didn't feel it necessary. And let me just straighten up what I just said earlier. To an extent, Kabbah was - we talked about the Bockarie situation because it was arranged for even Bockarie to speak to Kabbah. In fact, Sam Bockarie spoke to Kabbah from Liberia. That's a part of the evidence here before. So I did not report to him on a monthly or something basis, but from time to time we talked about it, and Kabbah and Bockarie spoke on the telephone from Liberia.

So, I can understand the questions, but to simplify it, we have to look at the process. Sam Bockarie - Foday Sankoh is in Freetown. Foday Sankoh gets permission from his President, who is aware of an internal conflict that's about to break the entire peace process. Sankoh comes to Liberia with the approval of Kabbah to hold discussions on what to do about Sam Bockarie and this was not the first trip. This is the second trip. So in a way it is Sankoh's responsibility with his President to keep him advised.

The thing that's so tense, where I invite Obasanjo to come down, Obasanjo comes down. We sit with Sankoh, Obasanjo. We discuss the problem. There's an impasse. Sam Bockarie is also in Liberia at this time. There is an impasse. The impasse is of such that we decide that, look, the best thing to move this peace process forward is for Sam Bockarie to be removed from the situation. Sankoh agrees. Obasanjo informs Kabbah and we move on. As far as we are concerned, that's the way the decision was taken at the particular time.

As a preface to the next point that I want to ask you about on this page, Mr Taylor, can I ask you this: Do you agree that after December 1999 Bockarie's presence in Liberia becomes a matter of international discussion and concern?

Yes, at some point.

Yes.

Yes.

Now, Mr Taylor, the question is: Surely, by the application of a little foresight, the involvement of Kabbah could have forestalled such future concerns. Do you follow me?

I follow you, but I don't quite agree.

Because thereafter you could say to the international community raising these concerns, "Look, it was all done with his approval, so what are you complaining about?" Do you follow?

I follow and you are correct. I follow very much, but I don't think it could have forestalled it because of most of these things were not coming from Kabbah himself. Well, let's not forget the record. The United States special envoy for Africa, Jesse Jackson, and the United States official delegations that come to Liberia, they meet with Bockarie, okay. They discuss with Bockarie. Bockarie in Liberia speaks to Kabbah. The issue is only coming from some level of propaganda after things begin to hot up a little bit, but I don't think it's even coming from Kabbah. But if Bockarie's situation was of such that it was not understood, why after the meeting with Jesse Jackson and Howard Jetter and all these senior United States government officials did they not say, "He's got no business being here," okay, and let him leave?

So this thing was just a matter of propaganda and people, you know, hotting things up at different points. Senior American officials know, the United Nations know, the decision to extract Sam Bockarie and bring him to Liberia is known. The United Nations representative is present. It's not - so there is very little I have to know in terms of informing Kabbah. I doubt if Kabbah could have made any difference anyway because the bulk of the controversy developing is not mostly from Kabbah. It's coming from these little external sources, "Oh, it's because of this." People are trying to whip up flames of discord in West Africa. So sufficient people knew. The United Nations knew. The United States government knew. Jesse Jackson, the special representative for Africa, met with Bockarie in Monrovia. What else could I have done?

Mr Taylor, would you agree with this at the very least though: That the propositions I've put to you, they do appear commonsense and obvious, don't they?

Commonsense, yeah.

And obvious?

Well, okay.

Let's go back to page 34575, line 17:

"Q. And, Mr Taylor, while Sam Bockarie was in Liberia,

the Government of Sierra Leone made requests that he be

returned to Sierra Leone, didn't it?

A. At some level, yes. My Foreign Minister did tell me

that - I think he had spoken to someone and President

Kabbah had said that he wanted Sam Bockarie returned to

Sierra Leone and the position of the Government of Liberia

was no.

Q. Actually, Mr Taylor, on 28 January 2001 you had a

telephone conversation with President Kabbah in which it

was discussed handing Sam Bockarie over to Sierra Leone.

Isn't that correct?"