The transcripts of the trial of Charles Taylor, former President of Liberia. More…

I'm on paragraph 866. Also, regarding the same paragraph, 866, that is dealing with the alleged independent relationship that the Defence say Ibrahim Bah had with the RUF, a protected witness stated that when - that Foday Sankoh and Bah became friends in Liberia during the Liberian civil war, and that they were both assisting the NPFL, and this witness also goes on to say that during the first half of 1997, Bah told him that he, Bah, was an adviser to the - to Foday Sankoh and that he was also or he had also been one of Charles Taylor's military advisers. So it is not really true that the -- Ibrahim Bah had an independent relationship with the RUF. His relationship with the RUF was based on his relationship with Charles Taylor, which had started long before.

Also, still on paragraph 866, regarding Bah doubling as a member of the external delegation, that is the Defence make reference to that at page 2438 of this witness's testimony, the witness said that at the time Bah still acted as a liaison for Charles Taylor. This was during the Lome Accord - Lome peace meeting, and the witness further said that at one time Bah left Lome for Monrovia and came back with Memunata Deen. He came back with a sum of $20,000 from Taylor for Sankoh, in fact this was money that, according to this evidence, Taylor - sorry, Sankoh was completely unhappy about. He said it was small money, it was peanuts and compared to diamonds that he had been sending to Charles Taylor.

I'll move on to arms and ammunition shipments. The Defence, in this area, their evidence mirrors most of the other sections in the brief. What they seek to do is cite certain portions of the evidence in part and then they omit other parts and then they make erroneous conclusions based on only that part which they cite.

I give an example. In paragraphs 1076 to 1069 [sic], they try to describe the period, that is February 1998 to January 1999 when they say the RUF - the AFRC/RUF, they tried to identify the sources of arms and ammunition shipments to the AFRC/RUF and this is what they give. At paragraph 10 - your Honours, just ask your indulgence a moment, the paragraphs I'm about to quote were from the previous brief and we've had to reconcile them with the new renumbering of paragraphs. The paragraphs I was referring to, by way of example, is paragraph - is paragraph 169 - it's 1069 and it's numbered 1 to 4, the Defence lists as sources of - for arms and ammunition supplied to the RUF - AFRC/RUF as follows: One, overall - stockpiles of arms and ammunition held by the junta government. They said that was one source. Also, arms and ammunition captured from ECOMOG soldiers. They also mention arms and ammunition from countries in the region, and arms and ammunition from Liberia, that the AFRC/RUF junta had acquired through trade with ULIMO. And finally they mention arms came directly from Liberia, which they say was not from Taylor, but from intermediaries.

Now, these listings of sources obviously does not fully reflect the position in terms of the proper sources of arms and ammunition that the AFRC/RUF had during the - during the period that we are referring to, that is to say, February 1998 to January 1999. A proper and true reflection of the evidence points to the following sources: One, the stockpiles held by the junta government; 2, captured arms and ammunition from ECOMOG soldiers; 3, arms and ammunition from countries in the region, notably Burkina Faso, by the arrangement and coordination of Charles Taylor; 4, stockpiles of arms and ammunition from Monrovia through - from - through intermediaries working under Charles Taylor; and also finally, arms and ammunition that came from ULIMO fighters, through the arrangement and coordination of Charles Taylor.

Now, if you looked at the sources as listed by the Defence, they clearly and inaccurately present a picture which the redacted. But apart from that, could you refer us to the paragraph in any event of the confidential brief?

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