And my last point on that witness is just as he starts to talk about 032, so the Prosecution then start to lavish money and attention on 032. The link is obvious. The method is the same.
Now, I'm going to mover to a completely different witness now by way of further example, of the way in which money can impact on a witness's testimony, and this is a witness called Suwandi Camara, TF1-548. This is the witness who you may remember was engaged in heavy weapons training in Dr Manneh's bedroom. In the Mataba, which I think was in Tajura, a suburb of Tripoli about which we have been hearing a great deal in recent days. Suwandi Camara, of course, was called to bolster the Prosecution's argument that appeared to be live for quite a long time in the case that the whole joint criminal enterprise had started off in Libya. I think you'll search long and hard before you find that repeated or referred to at all in the Prosecution final trial brief, but they called evidence about Libya, as a result of which we had to call evidence in due course, and Suwandi Camara was called to say that he'd seen Foday Sankoh and Charles Taylor together at the Mataba.
No doubt in the intervals what he'd emerged from Dr Manneh's bedroom and left the heavy weapons behind. He is the man, uniquely, of the witnesses in this case, who purported to claim a connection between those two, Mr Taylor and Mr Sankoh, whilst in Libya. He was in regular receipt from the Prosecution of nice round sums of $100 a time, for his travel expenses. He told you, and we'll look at it in a moment, he told you how he used to hire a car to go and see the Prosecution, to be interviewed. And he'd get travel expenses. And the car turned out to be, in local currency, dalasis, turned out to vary, the car hire turned out to vary from anything between about 30 cents to just under a dollar.
Now, let's give him the benefit of the doubt. Let's assume when he told you about that that he was talking about one way only. Let's assume - let's take the higher sum because he said at a later stage the hire car cost went up. So let's assume he had to pay two whole dollars out of his hundred dollars. What's his profit? Well, he said that he was given a hundred dollars once for a list of items, including loss of wages, that he was adamant that he hadn't lost wages. He said, They regularly - they usually give me $100. And when we looked at the amounts that he was being given, sometimes the heading would be, "loss of wages and transportation" and so on, and sometimes it would be for "meals, transportation and communication". Now, when he was asked about $100 that he received for "meals, transportation and communication", he said he didn't know how much the phone calls, that's communication, he didn't know how much the phone calls that he had to make cost, he said he thought they were expensive. But why is it, again, I ask rhetorically, because you know the answer, I would suggest, you would hardly need me to tell you, why is it he's being given these handouts of $100 at a time? Because clearly in each and every case he's not just receiving his legitimate expenses, he's also being rewarded. This was the witness you may recall who constantly demanded that I should not use the expression "you were paid $100". In his culture, being paid had a different connotation from simply receiving or being given assistance, if that helps you to identify him in your minds.
In any event, he was given a similar amount of money under the heading, "Security." Well, he couldn't really work out what the security was that he was given the money for. He started off by saying to you, "I think it was because when people from the Prosecution came to see me, I took them on a cultural tour," and he seemed to be implying that that was what the $100 for security was all about. And then he said, "Well, actually, I did ask them for money to put a fence around my orchard."
When he was asked if he'd actually done it, if he'd put the fence around his orchard, he said, "Well, I'd started it by the time I left for The Hague." I mention that in case it's in your minds that the security that he needed putting a fence around his orchard, was somehow to protect his premises from potential people who would do him no good because of his cooperation with the Prosecution. But it's perfectly plain that it was nothing to do with that. He wanted a fence around his orchard, he hadn't even completed it by the time he left for The Hague, having had the money some good time before.
Now, that is an example of someone else who was paid handsomely for the evidence that he was going to come to court and give, evidence which, as I said, was unique in this case in that it put Mr Taylor and Mr Sankoh together, meeting together, in the Mataba in Libya. As it happens, that aspect of the case, that aspect of the Prosecution's case, appears to have fallen away over time, and you do not see it reflected in their final trial brief. But that isn't the point. My point is, another witness, who, we submit, very clearly and very obviously, has received financial incentives to tell stories that are favourable to the Prosecution.
And my final note on Suwandi Camara was this: When he was asked about receiving regular payments of nice round sums of a hundred dollars a time, he said it meant very little to him because, as he put it, "I'm used to being given far more than $200 by people, brothers" who he met presumably at home in the Gambia. That was actually his evidence to you. Oh, a hundred from the Prosecution to me is nothing. People give me far more than that all the time.
Clearly, someone you may think who is prepared to make it up as he goes along and presumably, because he's had the advantage of these rewards.
Now, I want to turn, then, to Isaac Mongor, Witness TF1-532. Now, this is a classic example, in our submission, of a witness who we say the Court should exercise such a degree of caution about as to completely disregard his testimony. From start to finish, Isaac Mongor is somebody who contradicted himself, who told obvious lies, who couldn't remember from one day to the next what he'd told you in the course of his testimony, and who, of course, was another one who was a beneficiary of the generous largesse of the Prosecution fund. He was somebody who we established at the outset had a good command of English. In 24 interviews, he only had an interpreter present on five occasions. He had had schooling in English, up to a late age. He attempted to answer my questions before I had finished asking them, and therefore before they had been fully translated. And answer my questions in English. And if you want an example of that, and it's a particularly appropriate date, it's the 1st of April 2008, April Fools' Day 2008. Mr Mongor started to answer my question in English before I'd even finished it, demonstrating his grasp of the language. And it's important to understand his grasp of English because there were so many contradictions in the course of his evidence as between what he was saying to you in court and what he'd said on up to 24 previous occasions when seen by the Prosecution.
He was a man who usually blamed the Prosecution investigators and, indeed, lawyers, who interviewed him, he was somebody who regularly - who claimed that every interview was read back to him and he was able to correct the interviews at the end, and yet he failed to correct any of the significant contradictions in interview when compared with his testimony. And I'm going to look at his testimony until a little detail.
He began by denying that he had any interest in receiving the letter of immunity from Prosecution that had been given to him at the time that he started being interviewed by the Prosecution. Interestingly, he was adamant at the beginning of his cross-examination that he had already indicated a willingness to be interviewed and had been interviewed on a couple of occasions before getting the letter of immunity, which I think, going from memory, was dated 12 September 2006, I might have that wrong. But in any event he was absolutely adamant that that letter came later. When it did arrive he said he had no fear of being prosecuted. He wasn't one of those who bore the greatest responsibility, and he had no concern about the Court, and the letter really, you may feel, he was telling you meant nothing to him.
That was what he said at the beginning of his cross-examination. It was pointed out to him, that Mr Koumjian had described him in his evidence-in-chief as one of the top senior commanders of the RUF, but he still pooh-poohed the idea that he was at any real risk of Prosecution under the ambit of this Court's jurisdiction. At the beginning of his cross-examination.
He began his evidence-in-chief on this very day three years ago.
Now, it then turn out, by the time he'd been cross-examined for a little while, it then turned out that he had received the letter of immunity from Prosecution before starting to be interviewed, on 7 April he admitted, finally, that he knew before he was interviewed that he would be getting the letter of immunity, and he said, on that date, the 7th of April, that even having received the letter of immunity, he still had a shaky heart. That was obviously his way of describing anxiety. He still had a shaky heart about the prospect that even though they'd given him the letter of immunity they might still prosecute him.
Compare and contrast those two different positions that he took in the course of cross-examination. It didn't matter a jot to me, I'd already started being interviewed, I wasn't one of the ones at risk of being prosecuted, and then, actually, I knew I was getting the letter before I started to cooperate with them, and nevertheless I still didn't even trust the letter, I was still very worried that I might be prosecuted before this Court.
Well, you make what you will of that, but in our submission, he can't have it both ways. And how can you resolve the inconsistencies in a witness of that sort? How can you say, we'll take this bit of his evidence and we'll accept it and we'll reject this bit of his evidence? Because, as we saw across the whole panoply of issues that he gave evidence about, he was constantly in testimony contradicting, baldly and at times shockingly, contradicting what he had earlier told the Prosecution, in some instances several times before.
Now, he - he couldn't even get his story straight about how he joined the NPFL. I should say that he is a Sierra Leonean with a Liberian mother, he told you, had done some of his - had grown up in Sierra Leone but had gone to Liberia. You heard evidence to that effect from a large number of witnesses. He was in Liberia at the time of the NPFL invasion, depending on which of his interview accounts you accept, if you could accept any of them. On one he says he joined the NPFL and on another he claims that he'd been captured by them, in early 1989. I repeat, early 1989. That was the account the interviewers wrote down that he'd given them. Well, you know that that's obviously nonsense because the NPFL don't invade until Christmas eve of 1989. He sought to correct that in his evidence and said that he'd never told the Prosecution interviewers that he was captured in early 1989.
He is somebody who had, in the mid-80s, spent two months as a soldier, a volunteer, he joined up, in the Armed Forces of Liberia, and he lasted just two months before he, as he put it, ran away. It wasn't for him. The military life didn't suit him. He went back to being a businessman. So he's got two months' training in the mid-1980s with the AFL, he's captured, let's do him the benefit of the doubt, he's either captured or joins the NPFL around Christmas of 1989, and he told you, in his testimony, that he was then sent to train the RUF, to be the training commander, at Camp Naama, of the RUF in March of 1990. And who was it who sent him? He couldn't wait to tell you that it was Mr Taylor who sent him, Isaac Mongor, with his wealth of military experience by that time, a total at best of five months spread over more than five years, it was him who Mr Taylor sent to train those RUF people at Camp Naama. He was the one who said that the RUF was Mr Taylor's organisation, Foday Sankoh was nothing more than a front man. And Mr Taylor sent him there to carry out that very important job.
Now, Mr Taylor, you may remember, pointed out in the course of his evidence, and of course he wasn't contradicted on this in cross-examination, he pointed out the very important fact that this same Prosecution called General John Tarnue in the RUF case to say that he was the one sent by Mr Taylor to train the RUF at Camp Naama. Well, how plausible is Mongor's account that with his two months' training in the AFL from which he ran away, and end of December to some unspecified date in March with the NPFL, he's the one who is appointed to go and train the combatants at Naama? Or was it General John Tarnue, the horse that the Prosecution backed in the RUF trial?
We have a concept, not just domestically but internationally, that the Prosecution is indivisible. The Prosecution, in our submission, cannot face two different ways. In the RUF trial, they called General Tarnue. In our trial, they call Isaac Mongor. Now, interestingly, when we looked at what Mr Mongor told the Prosecution when he was first interviewed, knowing he was safe with his letter of immunity on the way, who did he say recruited him to Camp Naama? Foday Sankoh.
"Foday Sankoh recruited me to Camp Naama. I was introduced to Foday Sankoh by John Kargbo, a former Sierra Leonean police officer now in the special security division in Liberia."
Oh, no, he said, that's completely wrong, they've got that wrong, the interviewers have misunderstood me, I didn't say that it was Foday Sankoh who recruited me. I've always said -