Right. Under the heading 5, that she is not an expert in the sense that she is not an impartial witness, I summarise that very baldly. I can put it in three ways and give you three specific bases on which we make that objection.
First of all, she works as an advocate of human rights issues. In a number of cases Courts both international and domestic have taken the view that advocacy is different from impartial expertise. Campaigning is different from expertise. Human Rights Watch is essentially - and indeed claims to be essentially - an advocacy organisation, and it is in her capacity as a Human Rights Watch researcher and author that a number of these reports are put forward.
Secondly, and very importantly, this particular witness worked for the Office of the Prosecutor in this case for a year between October 2002 and October 2003 doing a very wide range of things, including finding witnesses and interviewing witnesses, and we are aware from having looked at the statements that we have received from the Prosecution that she interviewed at least 18 witnesses who are going to be called before this Court to give evidence in this case. I say at least 18 for this reason. We know from the witness statements that something like 23 of those statements don't indicate who they were interviewed by, 23 statements that were taken during the year when Ms Dufka was working in that capacity for the Office of the Prosecutor, and so it is perfectly possible that she is the interviewer of more than 18 on whose name - I am sorry, on whose statements her name appears. That again adds to her lack of impartiality, in our submission.
And, thirdly, Ms Dufka has given a number of - a very large number of interviews and made public comments over the last number of years about the matters that this Court is considering. We submit that in some of the comments that she has made, no matter how discreet she has been, the message is very clear that she is putting forward and that is that this accused is guilty of the crimes of which he is accused.
In our submission, for those three reasons she is not to be regarded as an impartial witness.