Mr President, we submit that the witness has laid sufficient foundation for the introduction of this document. In our submission, the first principal of admissibility is relevance, relevance to an issue before the tribunal of fact.
Now, as far as this is concerned, the Prosecution have named Ibrahim Bah as a co-conspiracy in the JCE alleged in the indictment. Consequently, where there is material available emanating, as in this particular case, from the Prosecution themselves which throws light upon those issues, and I give that as but one example, it seems to me, where the accused has had an opportunity, as quite properly and rightfully he should in the circumstances, to examine that material, he should be at liberty, if, as he submits, it points to his innocence, to place that material before the Court. And in our submission, any attempt to exclude from the gaze of this Court such relevant material, in our submission, is an attempt, and I say this quite bluntly, to mislead the tribunal of fact and, consequently, we submit this material is admissible through Mr Taylor.