Your Honour, with this evidence that there had been the training at Camp Naama and there is a place called Sokoto where this -- Foday Sankoh and his fighters were trained, and the - this witness, 532, referring to a plan having been made in Camp Naama was obviously referring to that period that the -- Sankoh and his men were in Sokoto. But before that there is also a wider strategic plan that had been laid even before Sokoto, and even before Naama, and there is evidence before this Court that, in fact, as far back as Burkina Faso and Libya, there had been a wider strategic plan to attack Sierra Leone. First Liberia, and then eventually Sierra Leone. So basically what happened in Voinjama was simply a plan to implement that strategic, overarching plan.
I move to paragraphs 815 and 818. The Defence incorrectly characterise the early skirmish which occurred in Sierra Leone as the timing of the attack. They say that this was an early skirmish, that this was not an unplanned attack, basically, they were saying. The Defence state that there is no evidence that an attack on Sierra Leone in March 1991 was a spontaneous one.
The evidence before this Court is that this was an accidental attack and as I've already pointed out, this was a trade deal that went wrong and as a result of that, there was this skirmish and at that point in time, the Taylor/Sankoh decided that this was - there was no reason to wait to launch the attack.
An unnamed witness, a protected witness, supports this and this is a witness who testified on 21st of January 2009. He stated that after the skirmish, it was quickly decided to start the war proper. Also, another protected witness, he is cited - he testified on 20th August 2008, at page 14097 to 102, this witness is cited by the Defence as having said that the attack was not planned, but this is not the case and in fact this is a wrong citation and it's an incorrect representation of the evidence. What this witness said was that, in fact, the two axis attack, that is the one on Kailahun and the one on Pujehun District were already in place by the time they were at Camp Naama.
Next, I move to paragraph 841, Operation Stop Election. The Defence does not dispute that this operation took place but relying on a protected witness, they again misstate the evidence. They say that this witness's testimony - in this witness's testimony he had said that Foday Sankoh did not give orders to commit atrocities during the operation, but, in fact, what this witness told this Court is that he, in fact, learned about the operation from Base Marine and that - he also told the Court that Foday Sankoh gave instructions to disrupt the elections but he was not aware - and that's the distinction - he was not aware of Foday Sankoh telling people to cut hands. Basically, what the Defence have said is that this witness testified that Foday Sankoh ordered his fighters not to commit these atrocities. That is not the case.
Also, regarding Operation Stop Elections, paragraph 842, to 843, the Defence state that it was striking, "striking, that Charles Taylor just happened to call". That is when Foday Sankoh was having a meeting, planning the operations to stop the elections, but this is not the case. In fact, there had been ongoing communications between Foday Sankoh and Charles Taylor, and it was definitely not striking that such a call came.
Paragraph - at paragraph 842 of the brief, that is the Defence brief, the witness - sorry, the Defence go on to make the point that, in fact, all of this was not true, the call, the fact that Taylor called Sankoh, but we have a witness who testified on 10th of March 2008, and he was at Zogoda and this is a protected witness - I'm sorry, this is TF1-532, he was at Zogoda when Foday Sankoh called a meeting, sorry, TF1-532 was at Zogoda, but a protected witness said that he was not at Zogoda and he's the one who is cited by the Defence as having said that, in fact, Foday Sankoh did not order the - his fighters to commit these atrocities but this witness said that he was not at Zogoda, he was in the jungle before the plan was discussed.
And this witness did also not say as alleged by the Defence that this was the first call that Charles Taylor had made since the border was cut off. This witness never said that. As a matter of fact, there had been ongoing communications between Taylor and Sankoh.
Invasion of Sierra Leone. Paragraph 866. The Defence asserts that Ibrahim Bah had an independent relationship with the RUF predating the Sierra Leone war. They cite TF1-338 at pages 15294 to 95. And they also cite DCT-172, that is the evidence of these witnesses. The paragraph gives other cites regarding Bah's association with the RUF. However, these cites do not show that Bah had an independent association with the RUF, except what DCT-172 testified to and we know that that witness's testimony is extremely unreliable to say the least.
In regard to 338, who is cited by the Defence, regarding this - the relationship that Bah allegedly had with the - with the RUF, which they say was independent, there is no reference to an independent relationship that they gave.
Now, the witness TF1-338 said that he knew Bah went back in to negotiate with JPK in Freetown, and that was - went back in to negotiate about arms for the AFRC when the AFRC was in power.