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

Your Honour, the actual paragraph is 1238, paragraph 1238. It's 1238 to 1239, paragraphs 1238 to 1239. I'm sorry, your Honour, there has been a little bit of confusion about the renumbering of paragraphs.

Your Honour, regarding this point, the - there is absolutely no aspect of TF1-548's testimony as cited by the Defence that Charles Taylor, Foday Sankoh and Dr Manneh were three equal principals. Basically this is the language of the Defence, that these were three equal principals, there is nothing in the testimony of 548 to suggest this. What this witness says is that at a meeting in Ouagadougou in Burkina Faso between Taylor, Sankoh and Dr Manneh, the three agreed that they would assist Taylor to fight his war first in Liberia and then Taylor would in turn assist the others, and the witness goes on to say that this was, "Because at the time we were very powerless." And he continues again, because, "We were people who were powerless at that time in terms of human resources, in terms of money, we were not very powerful."

Your Honours, this sums up the inequality in the positions between Charles Taylor at the time Foday Sankoh and Dr Manneh, they were definitely not three equal principals.

Paragraph 1227 was originally 1241. Still 1241. Paragraph 1241. The Defence lay out what they consider to be the primary distinction between the parties in this case. They say that Taylor's involvement or his role in the invasion in Sierra Leone in 1991 - I mean, they basically lay out what they say was basic distinction, the difference between the parties and they state that what is in dispute is the - is the basis of the participation of - alleged participation of Taylor, the timing and to some extent the duration of his participation in the dispute in Sierra Leone, and what they have said is that relying on the testimony of - relying on Taylor's testimony, they say that the Defence - the - Taylor sent Liberians into Sierra Leone and this was only after - it was after the invasion and not before. And that this was pursuant to a mutual defence pact, but the Prosecution - the Prosecution position is that this is not true. They even relied on the testimony of Moses Blah where he says at a point where he meets Charles Taylor - Foday Sankoh after the attack, he calls - he says Foday Sankoh is not a small boy any more, referring to the title that he used to call Foday Sankoh in Libya.

Now, just the reference to small boy in itself is evidence that at some point in time, Foday Sankoh was in a lower position, a subservient position to Liberians, including Charles Taylor and Moses Blah.

I move on to a number of distortions in the evidence.

I'll start with a few and my colleague, Mr Koumjian, will continue with the rest but just one. The Defence - I'm referring to paragraph 808 of the brief. The Defence state that the NPFL trainers at Camp Naama, according to the evidence that the Prosecution led, were Mekunagbe, Anthony Mekunagbe and Oliver Varney, but this is not true. Both Prosecution and Defence witnesses who testified before this Court named at least five Liberian NPFL who were trainers at Camp Naama. Among the names that these witnesses give, we've got PI, we've got Gonkanu, we have got Sam Draper, we have got Sylvester Miller, we have got Patrick Draper [phon] and the Prosecution's final trial brief in paragraph 30, in fact, lays out this evidence. No, it's not definitely true that there were only two Liberian NPFL trainers at Camp Naama.

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