Your Honour, may I reply for the Prosecution. Your Honour, the Prosecution notes, first of all, in the objection of last week Mr Anyah mentioned Rule 93 requiring that the evidence of other crimes be disclosed pursuant to Rule 66. In fact that has been done. The evidence that this witness is testifying about, these crimes that are outside of the indictment, are all contained in disclosures that were provided to the Defence, including the witness's prior testimony which was disclosed to the Defence.
In addition, your Honour, we wish to point out that this is a case that's unlike other cases at the Special Court. The accused in this case is not a commander on the ground. The evidence that we seek to admit of crimes outside the indictment is relevant for a number of reasons. First of all, the Defence in this case - it is an element in this case, in all of the charges of crimes against humanity, that there was a widespread and systematic attack on the civilian population during the period of the indictment, that there was a widespread and systematic attack. All of these crimes are relevant to that fundamental element to all of these charges.
Furthermore, because of the accused's position it's very important, it's a critical element in our case, to prove that the accused had notice of the atrocities that were going on and it is - I believe I've been saying another - Rule 93 I'm referring to regarding pattern evidence. It is our case that in fact the evidence shows that the atrocities that were going on in Sierra Leone were so widespread during the time of the indictment and also, critically for our case, prior to the indictment period, that throughout the indictment period the accused, Charles Taylor, was aware of atrocities occurring by the RUF.
Furthermore, I think your Honours have seen in the evidence that we have presented and we will continue to present, it is our case that the RUF, which later allied itself with the AFRC, was a terrorist army created by Charles Taylor, controlled by Charles Taylor, created exactly in the image of his forces in Liberia which committed a pattern of terrorists acts and that all of this is relevant to the fundamental element of the intent of the accused, his notice of the crimes and his, in fact, intent that atrocities and terror be carried out in Sierra Leone.
So for all of these reasons we ask that the evidence we admitted. I would note that your Honours are professional judges. The probative value of this evidence, which we believe is great, your Honours will consider and there's no lay jury here. Your Honours, obviously this evidence is not sufficient for any crime charged outside of the indictment. Any crime that is not one of those charged within the indictment can only be considered for the reasons that are probative and relevant and your Honours, as professional judges, will not consider them for inappropriate or prejudicial reasons. Thank you.