Good morning, Mr President, Your Honours, counsel opposite.

For the Defence today myself, Courtenay Griffiths, Queen's Counsel. And I am joined by my learned co-counsels Mr Terry Munyard, Mr Morris Anyah, Silas Chekera, and Ms Logan Hambrick. Also with us today is Ms Claire Carlton-Hanciles, the Principal Defender. And ...

Well, he can take mine.

Your Honour, Mr Taylor will be reading from a written document. I wonder if he might have the assistance of the lectern.

He does. He does, Your Honour.

Well, that of course is perfectly legitimate, but to use that tariff, if our submission, as, for example, a starting point, we submit would be illegitimate because it would not take into account the mode of liability in respect of which Mr Taylor is being convicted.

Well --

The short answer, Your Honour, is no. And I say no for this reason: That Mr Taylor stands in a completely different position vis-a-vis his liability for those crimes than the two examples provided to the Court. They was direct participants in the commission of those crimes, unlike Mr Taylor ...

Well, what we are submitting there, Your Honour, is the question of scale and duration, both factors which I sought to address, for example, by means of the diagram which we submitted before the Court. And it seems to us that it's perfectly legitimate for a Court in this ...

Of course, Your Honour, we are aware of the Trial Chamber's finding in that respect. We are aware of it. And we are not seeking at all to relitigate that issue. But I made it plain in introducing that particular topic that we remain consistent in our approach.

Now ...

Your Honours, sometimes looking at a diagram helps to focus the mind more clearly as to what the true issues are, and we can see here that the bulk of the offending occurs within this period in the middle of the diagram, and it basically covers a roughly 12-month period ...

Your Honours, to save time, could I hand out three copies, because I should be able to manage without it.

May it please Your Honours.

Again can I express my gratitude for the time allowed to consult with Mr Taylor. Equally, we are grateful for Your Honours's indication this morning as to when the final written judgement will become available. Although it's still a matter of concern to ...

I am most grateful for that indication, Mr President.

That would be more than adequate, Your Honour.

Well, We'd prefer it -- we would prefer it, Your Honours, before I addressed the Court.

Well, it would be useful to have a discussion with Mr Taylor before he commences.

I apologise to my learned friend. Your Honour, can I ask -- raise two matters, preliminary matters, regarding the timing of the proceedings today. I don't know whether Your Honours were considering have a mid-morning break at some stage, but it would perhaps assist us if that were to be ...

Good morning, Your Honours, counsel opposite.

For the Defence today, myself, Courtenay Griffiths, Queen's Counsel. With me, Mr Terry Munyard, Mr Morris Anyah, Ms Logan Hambrick, co-counsel. We are also joined by Ms Claire Carlton-Hanciles, who is the Principal Defender, and also our legal assistants Michael Herz, Szilvia Csevar ...

Good morning, Mr President, Your Honours. For the Defence today, myself, Courtenay Griffiths, Queen's Counsel, with me as co-counsel Mr Terry Munyard, Mr Morris Anyah, Mr Silas Chekera, and Ms Logan Hambrick. We are pleased to have join us our Case Manager Salla Moilanen and also our legal assistants ...

Well, I do apologise to the Court.

Madam President, your Honours, counsel opposite, can I use the remaining ten minutes to touch upon a couple of discrete topics, not in any particular order, and then to deal with a separate matter altogether?

Mr Koumjian's point this morning regarding the absence of proof as to meetings between ...

Oh, I failed to mention that. I apologise.

No, Mr Munyard.

This is dated the 22nd of December 1999. Third line, paragraph 1: "Talks between President Taylor and Obasanjo during President Obasanjo's stopover at the Roberts International Airport on Monday, the 21st of December 1999, the minister indicated that the talks centred on the question of the implementation of the ...

Your Honours will see from page 1 of the document that this is not from Downes-Thomas. He's just been copied in. It's from Miyet of the United Nations in New York. Now, I don't know whether in due course it's going to be suggested that Miyet ...

I'm grateful. Page 1, 15th of October 1998, at or about the time of contact with Bockarie by Charles Taylor, following the letter so we get the sequence, ECOWAS meeting July; Tiagen Wantee letter, 12 August; meeting Bockarie, this is now 15th of October so we are in the ...

Now, moving on, Madam President, and this is my sixth proposition, the RUF were to stay in the jungle until the AFRC coup on the 25th of May 1997.

We submit that there can be no credible suggestion that Charles Taylor had a hand in the coup, nor that the ...

I'm grateful. It's exhibit P-272. And, again, we would submit that this is an exhibit which bears fruitful, detailed analysis. Again, we see it's a handwritten letter dated the 4th of December. Pause there. 4th of December would be just after the signing of the Abidjan Peace ...

Very well, can we adopt the same procedure as the last time, then, your Honours?

Now, your Honours will see it's a handwritten letter headed, "Revolutionary United Front of Sierra Leone," and it's dated the 26th of June 1996. We see that it's from the leader, Foday S Sankoh. Now, let's just pause again there for a moment. Now, remember the ...

Yes. The background is this. We know that following the signing of the Abidjan Peace Accord, Sankoh supposedly for the purpose of, in effect, selling the agreement to the troops on the ground, was allowed to return to Sierra Leone by helicopter and visited a couple of the jungles which ...

Okay. I will do. Your Honour, it is exhibit D-15. Do your Honours have that document?

Now, at this point, at this point of weakness, when the RUF were at a low ebb, the more intelligent members of the movement realised by 1995 that the movement had reached a stalemate and decided to bring their message to the wider international community. An external delegation was formed ...

May it please your Honour, before we adjourned, I was dealing with our fifth proposition, describing the straitened conditions in which Foday Sankoh found himself following the breach between he and Charles Taylor.

And on that topic, had noted that at that critical stage, because of a lack of the ...

I can't do it in that short time.

Now, your Honours, what can we properly conclude from the evidence we've just considered? What does that withdrawal, what does that testimony we have just referred to tell us about what had happened to the relationship between Taylor and Sankoh in or about June of 1992 at the time ...

Yes, please.

Now, your Honours will see that at paragraph 405 and 406, 7 and 8, we deal with ideology training at Camp Naama. If I could just give your Honours a moment to cast your eye quickly over that, to get the import of what we are suggesting in those paragraphs ...

So as I was saying, so the fact remains that much of the Prosecution's case, the crucial part of its case, has been in large measure shrouded in secrecy. The public will never know the content of that important testimony. It's a matter of some concern.

Now, let ...

I'll pause there, your Honour, until it's fixed.

Now it's quite clear, Madam President, that those terrorising that individual in the clip were ECOMOG soldiers. And is it to be said that ECOMOG weren't also intending terror when they went into Sierra Leone? And indeed perhaps Liberia? Again, what springs to mind is the idea of ...

Well, the whole exhibit is confidential, Madam President. Although the film from which it's taken is available for public consumption. But in any event, out of an excess of caution, bearing in mind the rules, it seems to us that it ought to be played in closed session.

Very well. That's why I mentioned the fact, Madam President.

I have never suggested that. I am speaking from the vantage point of that man on the Clapham omnibus, that phrase much used in English common law, the independent observer looking on from the outside, recalling, of course, that justice should not only be done, it should be seen to ...

Any tribunal, Madam President.

It's the first paragraph on the left, your Honour, and for your Honour's assistance I'll repeat it:

"Liberia's President Charles Ghankay Taylor is sure that 'some powerful countries' are out to get him but he does not want to name them 'because they punish you the ...

Ah, here we are.

Can I inquire whether the problem has been solved, your Honour?

Also Mr Chekera. I think he's so close, I missed him. Now, bearing in mind the orders made by your Honours on Monday, we have divided our address into the following sections. I will address you today and at this point in time, I'm unsure as to how ...

Can I first of all announce a change in representation, please, Madam President? Mr Munyard and Ms Kimberley Punt are no longer with us and we've been joined by our two legal assistants, Michael Hertz and Kathryn Hovington. Your Honours --