Clip number 3 is MFI-5. Clip number 1, just to remind your Honours, was a very short clip. It actually was the first one I showed which talked about Sierra Leone being a very poor country and depicted some of the scenery. That is MFI-6.
Clip number 2 - and again to remind your Honours that was the clip that was largely of Mr Fofana, a double amputee who was speaking about his experience and his family who were burnt to death in their homes - was MIF-7.
Clip number 5, which contained information and some scenes of artisanal mining and was largely an account by a young man - I am sorry, I don't recall his name, but it is given in the video - who was subjected to forced mining and talked about the murder of his friend, or his colleague. That is MIF-8.
The last clip shown, MFI-15, was clip number 6, which included - if your Honours need reminding, that included an account by several persons: an amputee, a woman who was sexually assaulted with a stick and another victim in that case. That was a woman whose husband's hands were amputated.
Your Honour, addressing all of these - thank you. First of all, counsel said some of these have to do with diamonds and some don't. Our position is all of these have to do with diamonds. This is what our case is about and this is why we brought Mr Smillie. A key link between Mr Smillie's expertise on diamonds and this case and the relevance to this case was in the last questions he answered on direct examination. He had told us about how artisanal mining is labour intensive, the diamonds can be moved over millions of years by rivers from a kimberlite and an area can be covered with those and that, in order to exploit those diamonds, it is very important for the person or group that wants to exploit them to control the population. If you don't, you get a situation like in 1955 when there were 75,000 miners - independent miners - coming to Kono illegally and in the present day there is 120,000. He gave an example of New Year's Day when there was a mad rush in Kono because someone had found a diamond and hundreds of thousands of people showed up shovelling dirt into the backs of cars to take it away.
So all of these clips in our view have to do with diamonds and, of the terrorism that is depicted very briefly in these clips, only three of the clips depict victims and talk about atrocities and those are clip number 2, clip number 5 and clip number 6.
Those do have slightly less than nine minutes - eight minutes and 53 seconds in total - that includes brief examples of the terror that was inflicted. I presume that the Defence is objecting to these nine minutes because it is distressing for your Honours and all of us to watch it, and I certainly believe for me it was distressing even though I have seen it many times before. But, your Honour, it gives us all an insight and gives your Honours an insight that, if we are distressed watching and hearing an account of an amputation, of a sexual assault, of being forced to mine for a year, we can imagine the terror of the people at the time. We can get a small hint, thousands of miles away and years away in the safety of this courtroom, of the terror of the population.
So this testimony, just like the brief victim testimony, illustrates the terror that is part of our case and these are true accounts. This is not a Hollywood movie. The man who was speaking with both arms amputated, this is not something that was done for special effects. He is living without his hands for the rest of his life.
The information about the diamonds is used as a visual aid in this trial just as we might use a diagram of kimberlite. It is simply in video form. It helps the Court to see how mining is actually done. The video diagram is simply the same as if we presented a series of diagrams showing how diamonds are formed in the earth, how they are spread out, how it is retailed, how it is sold and it just allows the Court in a very brief exhibit - the total exhibit of all six clips together is less than 20 minutes, slightly less than 19 minutes, and I believe all are relevant to our case and I would ask the Court to admit all of them.