Thank you, your Honours. I will attempt to address each of your Honours in sequence. With respect to Justice Sebutinde's observations, we certainly agree that the circumstances are different vis-a-vis the procedural circumstances, meaning that this is a 92 bis witness, meaning that you have afforded us the latitude to cross-examine, meaning that the accused are different.
All of that notwithstanding, and I do see reference to your Honour Justice Sebutinde saying that "I don't see how you can say that: Oh the judges' minds are fixed." I am not suggesting that your minds are fixed. I am merely reiterating that when these types of witnesses come before your Honours we have a standing objection and I still use the word "objection" and in this sense it could be translated and properly would mean an application for disqualification.
It's not a new application. I am counting on the fact that several months have passed since the primary application was made and I am alerting your Honours to the fact that it is a continuing application as in any and when these types of witnesses come before your Honours we seek to remind your Honours that there is this particular issue to which we have made application or, as some would say, taken an objection.
With respect, your Honour Justice Sebutinde, despite the procedural changes the import of the witness's evidence remains the same. What the Prosecution seeks to have your Honours distil from the witness's evidence are, generally speaking, crime base issues. But your Honours have found that particular evidence to be credible. You have relied on it to make findings for unlawful killings. You've relied on it to make findings for terrorism. You've relied on it to make findings for physical violence all in the context of the AFRC case.