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

Thank you, your Honour. Madam President, your Honours continuing from where I left off, I will deal with Benjamin Yeaten.

Yeaten was also known as Unit 50 and he was Taylor's closest aide. Taylor and Yeaten's association began in Tajura Libya during Special Forces training when Yeaten was just 14 to 15 years old.

Under Taylor, Yeaten quickly rose through the ranks both in the NPFL and later when Taylor became President in 1997. Taylor appointed Yeaten to the pivotal position of Special Security Service director. Yeaten's position gave him enormous power, authority, influence and prestige. His duties included providing close security protection for Taylor, his family, and other VIPs. Yeaten had frequent access to the office of the presidency, having at least two official meetings a week. All of the chiefs of the armed forces and other militia were immediately answerable to Yeaten, as he was also Chairman of the Joint Chiefs of Staff. Literally, Yeaten was just a heartbeat away from Taylor, residing only a few hundred metres away from Taylor's residence, White Flower. Yeaten's position superseded the then-Vice-President, Moses Blah. Yeaten was answerable to no one in the republic but Taylor. Yeaten once boasted to a witness that only Charles Taylor was more senior than himself in Liberia.

Indeed, nobody but Taylor gave orders to Yeaten. At an Executive Mansion parade, Taylor was heard to say, "Benjamin Yeaten, whatever he sees, whatever he says, I, President Taylor, said it. When he sees something, I, President Taylor, sees that. When he hears anything, I, President Taylor, would hear that."

For the purposes of Taylor's connection to the AFRC/RUF, Yeaten was a linchpin who coordinated Taylor's links with the rebels in Sierra Leone. Yeaten used his SSS personnel, that is Jungle, Zigzag Marzah, Dopoe Menkarzon, to facilitate the arms/diamond traffic between Buedu and Monrovia. Yeaten also used his radio operator Sunlight to coordinate with and maintain a communications link with the AFRC/RUF. Yeaten also regularly facilitated direct satellite phone communications between Taylor and Bockarie. A call would come from the Executive Mansion or Yeaten's residence, requesting that Bockarie switch on the satellite phone which was commonly called the 2-1. Further, Yeaten coordinated visits by key players within the AFRC/RUF such as Bockarie, Sesay and JPK to see Taylor at either his Executive Mansion or White Flower.

Some other aspects of Yeaten's involvement with the AFRC/RUF on behalf of Taylor included, 1, coordinating operations including logistics for the AFRC/RUF's assistance to Taylor in fighting the insurgency in Liberia and later the attacks on Guinea. 2, passing reports to Taylor on the military situation in Sierra Leone, including AFRC/RUF operations based on his communications with Bockarie and later Sesay.

Yeaten was well-suited for Taylor's manipulative tendencies. By placing Yeaten in high office despite his lack of formal education, Taylor made sure he retained authority and control.

When Taylor needed to eliminate former associates or subordinates, Yeaten and his SSS team were the ones to get the job done. Yeaten coordinated several murders on Taylor's orders: Superman, Bockarie, Jungle, Sam Doki and former government ministers John Yormie and Isaac Vaye. Yeaten eliminated these people on behalf of his boss, Charles Taylor, in a devious effort to cover and protect Taylor's criminal conduct, including his links with rebels in Sierra Leone. Such was Taylor's special relationship with Yeaten that Taylor confirmed to this Court that he would accept Yeaten back in his government even today.

I will next turn to the relationship between Taylor and Daniel Tamba who was also known as Jungle. Taylor tried to distance himself from Jungle, his trusted liaison and runner to the RUF but the evidence shows that from the early 1990s Taylor was - Taylor used Jungle at his representative and his eyes on the RUF movement. Taylor also used Jungle to pass on instructions, advice and guidance on a variety of topics including mining operations in Kono District and military and strategic matters. Additionally, Jungle often delivered critical in-person reports to Bockarie from Taylor. In March 1997 when Sankoh was arrested Jungle communicated promotions to Bockarie and Sesay. More importantly, Jungle conveyed the message that they were to take instructions and command from Taylor until Sankoh's release. Following the intervention, Taylor quickly moved to ensure the continued unity of the AFRC/RUF. Taylor needed this unity to be maintained in order for the movement to achieve one of its primary objectives, the recapture of the entire diamond-rich Kono District. This message of unity was so important it was sent in person by his trusted liaison, who was Jungle. This message said that Taylor recognised the importance of the AFRC/RUF relationship, that the two groups should work hand in glove and should try to capture Kono, and the district's diamonds. Jungle also relayed instructions to construct an airstrip behind Buedu in Kailahun District. Finally, Jungle was often responsible for delivering parcels of diamonds from the RUF high command for, in the words of the RUF high command, "Our father across," meaning Taylor.

The last of these key figures that I would address your Lordships on is Ibrahim Bah, also known as Balde. Bah was a Senegalese who trained with the Gambian group at Tajura in Libya. He was known within the RUF as the RUF liaison officer but this innocuous title belied the true significance of his role. In reality, Bah acted as a liaison for the RUF in its dealings with Taylor and for Taylor in Taylor's effort to procure arms and ammunition for the movement. The evidence shows that indeed Bah, on behalf of the accused, arranged major shipments of arms and ammunition to the AFRC/RUF in exchange for diamonds through contacts made with third parties by the accused.

When the AFRC/RUF diamond production increased, Bah played an important role in moving diamonds out of Sierra Leone and onward to foreign buyers on behalf of Taylor. In relation to arms, Bah was the key player in two critical shipments of arms to the AFRC/RUF. The first shipment occurred during the junta period. Bah travelled to Freetown, held meetings with the junta and coordinated the 90-carat diamond deal paid to Taylor for the Magburaka arms shipment in November 1997. The second shipment occurred when Bah, in December 1998, travelled to Burkina Faso with Bockarie and others securing the shipment of arms used for the multi-axis offensive on Freetown in January 1999. In 1999, Bah's activities with the rebels in Sierra Leone also included, 1, bringing Bockarie's third satellite phone and also diggers and mining equipment; secondly, being part of the AFRC/RUF delegation team to Lome, including meeting with Taylor as his special guest and taking $20,000 to Sankoh from Taylor; and thirdly, accompanying Bockarie when he retreated into Liberia.

Throughout all of this time, Bah remained a trusted and loyal subordinate of the accused. However, in 2002, Bah fled Liberia on discovering he was about to suffer the same fate, elimination, later suffered by Taylor's other once-trusted subordinates.

I will now look at radio communications.

Throughout the evidence in this case, the Prosecution has highlighted the important role of VHF radio and satellite communications between Taylor and the AFRC/RUF. Both parties called radio operators during the currency of their respective cases. On the whole this area of evidence demonstrates a clear and regular line of communication between Taylor and the AFRC/RUF. In total, the Prosecution called seven radio operators during its case. All testified to having operated for the AFRC/RUF at various times, both prior to the indictment period and during the indictment period.

One of the operators, TF1-275 testified to operating a radio for the NPFL prior to joining the RUF, and another TF1-516 testified to operating a radio for the Government of Liberia during the period that Taylor was President. The Defence called three radio operators, all three testified to having acted as radio operators for the NPFL prior to Taylor becoming President in 1997. Two of the three testified to working as radio operators for the government of Liberia during the period while Taylor was President. Taylor himself also testified in various areas about both radio and satellite communications.

The communications evidence in this trial demonstrates much that I will shortly explore but above all these, the communications evidence shows that during Sierra Leone's worst moments, in places like Kono and Freetown, at the times when the AFRC was inflicting - AFRC/RUF was inflicting its greatest suffering, the one man with the greatest access in the world to communicate to the AFRC/RUF, its leader Sam Bockarie, at that time through both his extensive radio and satellite phone links was this accused, Charles Taylor.

Evidence was elicited by both parties about general radio communication protocols. In short the evidence clearly establishes the following. Firstly, that radio operators received a special degree of training in order to operate effectively on the radio. Secondly, that the radio networks employed coding systems, both in terms of frequencies, which operated like channels, and content that was coded and decoded by operators and passed to respective commanders. Third, that a third radio station could monitor communications between two stations and that if the respective radio operator had access to the respective frequency and content codes, he or she could monitor all communications. Fourth, that the radio stations used in both Sierra Leone and Liberia had the ability to utilise VHF, that's very high frequency, communications and could be employed long-range between Sierra Leone and Liberia. Next, that radios could operate either as fixed or mobile stations. Next, that both operators and stations employed a variety of call signs. Also, that the radio networks employed a communications hierarchy in which there was a headquarter station and various substations that fell within the ambit of the headquarter station. And finally, that certain messages were kept in a logbook - in logbooks while certain communications such as when commanders were talking directly to each other would not be recorded in logbooks. As regards the state of communications between Taylor and the RUF prior to the indictment period, the parties' evidence differ significantly.

The Prosecution's evidence is -- in totality establishes certain facts that are beyond dispute, and these include that during the NPFL's initial entry into Sierra Leone, NPFL forces were in radio communication with Taylor and his NPFL subordinates in Liberia; 2, that the NPFL set up the initial RUF radio network infrastructure, and from this point the NPFL and the RUF radio procedures and modalities largely mirrored each other in most respects; next that the two radio networks were linked and respective operators from each side with access to certain frequencies and content codes were able to monitor radio communications; also, that in the early years, while Taylor was the leader of the NPFL, certain call signs were used such as Toyota for Sankoh and Ebony for Taylor; and finally that after a large contingent of the NPFL forces withdrew from Sierra Leone in 1992, the RUF re-established and thereafter maintained a radio communication link with the accused and his NPFL radio network.

On the issue of communications between Taylor and the AFRC/RUF during the indictment period, the Prosecution evidence is largely consistent, especially in terms of timelines, time periods, lines, means, content and frequency of such communication. In addition to radio communications evidence, evidence was also elicited relating to satellite telephone communication. The evidence on the whole demonstrates that Taylor, both while leader of the NPFL and as President of Liberia maintained regular and frequent contact with the RUF and the AFRC through radio and satellite phone. The evidence also establishes the primary line of communication -- that the primary line of communication was between Buedu and Base 1, located within Yeaten's compound in the vicinity of White Flower. It also establishes that Bockarie maintained regular communications with Base 1 on a variety of topics including ammunition deliveries, other convoys, the warnings concerning ECOMOG jet sorties, the movements of individuals like Jungle and situation reports concerning Sierra Leone. Also the evidence establishes Bockarie - establishes that Bockarie and later Sesay maintained regular communications with Yeaten and sometimes Taylor himself via what was known as the 2-1 which as already stated is referring to the satellite phone. That was the radio parlance basically for a satellite phone.

The Prosecution also elicited evidence in relation to intra-AFRC/RUF communications. The Defence did not elicit any such evidence through their radio operators.

Intra-AFRC/RUF communications notably covers communications between the AFRC/RUF leadership at the headquarter bases and the front lines. On this issue, the Prosecution was able to present overwhelming evidence of communications from radio operators from various vantage points including the various headquarter stations, the front lines, and locations where crimes alleged in the indictment occurred. In sum, the evidence consistently demonstrates that the AFRC/RUF leadership was in constant communication with various front lines, that the AFRC/RUF leadership was issuing regular commands and operational orders to these front lines, and that operational activities and crimes resulting from those activities were regularly reported to the AFRC/RUF leadership and in some instances the AFRC/RUF leadership issued orders to the commanders on the front lines to commit crimes or sent messages that incited the commission of crimes.

I will now turn to the credibility of certain radio operator witnesses or those called -- specifically those called by the Defence.

DCT-228, Joseph Dehmie's testimony should be disregarded almost in its entirety. Dehmie was called to testify about his work as a radio operator at Bomi hill from September 1990 to September 1992 and later Gbarnga up to 1997. His testimony is not credible on many levels. One, in particular, is that the witness testified categorically that there was no radio communication between Taylor's radio stations and RUF stations in Sierra Leone during the period August 1991 to May 1992. And yet, this is perhaps the only area that the Prosecution and the Defence agree on, as Taylor himself testified to these radio communications. When confronted in cross-examination with Taylor's testimony on this point, Dehmie's response was that he was not convinced the transcript was Taylor's testimony.

Furthermore, portions of Dehmie's testimony in other areas show unreliability in the following ways. The witness said that VHF radio can only go ten kilometres and not even from Gborplay to Monrovia, and VHF radios, that's supposed to be very high frequency radios. The witness stated he did not know who Sankoh was and was not aware of any call sign Toyota. The witness did not know of any group called Black Gaddafa. The witness said that while in Bomi Hill, he had no knowledge of the NPFL and RUF fighting together. The witness's explanation of logbook recordings in terms of their connection to commander's directives is completely at odds with the weight of the evidence in relation to logbooks. The witness did not know what the term "situation report" meant. And finally, the witness's explanation of alphabet code was simply the military alphabet and not actually coding, and his further explanation of coding was simply incoherent and at odds with all other evidence before this Chamber. Given that this witness did not have any relevant observations concerning radio communications from 1997 onwards, and that his testimony on the 1991-1992 time frame is so at odds with the weight of the evidence in this trial, his testimony should be discounted.

Next I turn to DCT-179, Yanks Smythe. This operator, again, did not operate a radio during the indictment period but only up until 1993 or 1994. Again, this radio operator made assertions that are simply inconsistent with the larger body of the evidence before the Trial Chamber and notably at odds with Taylor's own testimony and other Defence evidence. For instance, the witness asserts that during the entire time he was with Mr Taylor as an operator, neither he himself nor anyone else associated with communication for Taylor ever had communication with anyone in Sierra Leone. Further, the witness does not recall any call sign Toyota which Taylor and other Prosecution witnesses clearly recall. Smythe also asserts that the communication devices at the Executive Mansion and at White Flower did not have the ability to operate long range. Taylor himself testified that the SSS director, that is Benjamin Yeaten, had radio at his house that had frequency across the country. Smythe also demonstrated a lack of knowledge of how basic radio communication worked, leaving the impression that if he did operate a radio at all, it was very infrequently. Examples that demonstrate this witness's lack of knowledge about radio operations include: 1, his explanation of frequencies not being able to recall if there was frequency coding; 2, not knowing what a grid reference is; and 3, not being able to recall how to code messages.

I'll finally deal with DCT-008. The evidence of DCT-008 elicited towards the end of the Defence case can be viewed as a desperate measure to explain away the undeniable regular communication that existed between the AFRC/RUF in Buedu and Benjamin Yeaten's radio station located behind White Flower known as Base 1. This witness's testimony conceded that indeed radio communications between these stations did exist and that also, these communications occurred in relation to the shipment of ammunition from White Flower to Buedu on the instructions of Benjamin Yeaten. There are points of agreement between the Prosecution and Defence concerning DCT-008's evidence. First, he operated a radio for Taylor. Unlike Smythe and Dehmie, DCT-008 did demonstrate some degree of knowledge of radio operations and corroborated the Prosecution witnesses in several technical areas, including, 1, that SSB radios, that is single-side band radios can operate as long-range radios as they can operate at a high frequency and that, 2, codes were assigned to frequencies and also used for content messages.

DCT-008 also corroborated the Prosecution in substantive evidential areas including the following: That Base 1 functioned as the radio station behind or within the vicinity of White Flower in 1998 to 2001 and was operating under the direct control of Benjamin Yeaten; 2, that Benjamin Yeaten was overseeing the provision of ammunitions to Sam Bockarie and the RUF in the middle to latter portion of 1998 prior to the late 1998 offensive on Freetown; 3, that Sunlight was in radio communication on a periodic basis with Sellay, an RUF radio operator in Buedu in 1998 and 1999; and finally that Sunlight was also extensively familiar with the call signs of several other RUF operators. This extensive familiarity with RUF radio operators supports the Prosecution's evidence as to how close the relationship was between the RUF radio operators and Sunlight's radio station, Base 1, in Monrovia. While DCT-008 differs in terms of the extent and purposes of the contact, he corroborates the general lines and substance of communications between AFRC/RUF radios in Buedu and Base 1 in Monrovia with one major caveat. DCT-008 characterises the whole episode as some type of secret renegade operation of which Taylor had no knowledge or awareness. This is entirely implausible and the evidence in the aggregate clearly establishes that Taylor knew, was aware, and was actively involved in authorising and directing Benjamin Yeaten's activities vis-a-vis Sam Bockarie and the AFRC/RUF. Several areas of the evidence support the assertion that Taylor must have been and was aware of Yeaten's relationship with Bockarie. These are outlined in various sections of the brief and to this presentation.

In terms of radio communications, DCT-008's story about Taylor's lack of knowledge is simply implausible for other additional reasons.

1, it is implausible that a series of radio communications stretching over weeks or months, involving many operators from the AFRC/RUF and which were capable of being monitored by other stations that had both frequency and content codes could have taken place in secret without the knowledge of radio operators at the Executive Mansion. This would mean that all these radio operators would have been in - would have been in on the secret operation as well unbeknownst to Taylor.

2, the witness himself acknowledged that even other AFRC/RUF radio stations in Sierra Leone heard these communications between Buedu and Base 1, yet DCT-008 still maintains Taylor was ignorant of the communications.

3, during the time period the witness is recounting, which is late 1998, the international community and ECOMOG had started to significantly publicly criticise Taylor for his relationship to the AFRC/RUF. It is simply not plausible that Taylor continued to remain ignorant of the radio communications and relationship Bockarie had with Yeaten with knowledge of so many others including the radio operators in the Executive Mansion and more importantly some of Taylor's most trusted advisers including Musa Cisse, as he continued to publicly deny any connection to the AFRC/RUF.

Your Honours, I would now turn to the sections dealing with two counts in the indictment, count 9, which deals with the crime of recruitment of child soldiers. Count 9 charges Mr Taylor with the offence of child soldiers, conscripting, enlisting and/or using children under age of 15 to participate in hostilities from 30th of November 1996 to 18th of January 2002. And in all districts of Sierra Leone.

The law and evidence led by the Prosecution on this count are to be found in section 9(G) of the Prosecution's final trial brief. I propose to touch on only a few of those submissions.

Recruitment of child soldiers by the rebels dates back to the early days of the RUF in Liberia. This practice of conscripting and using child soldiers in combat had much deeper roots in Taylor's NPFL. The evidence shows that the NPFL had a small boys unit, SBU. Exhibit D-118 which is a newspaper report that's been already referred to by my colleague, Ms Hollis, is a newspaper report that states that around 1990, Taylor had 12,000 men, women, boys and girls in uniform. Moreover, Taylor had heavily armed 14 to 16 year old boys guarding him and his Executive Mansion was guarded by 10 to 12 year olds. When the RUF was created, it was not surprising, therefore, that it also mimicked the use of child soldiers and the term SBU. During the Sierra Leone war thousands of boys and girls under the age of 15 were used to participate in hostilities. Conscription started just as soon as the RUF and the NPFL forces invaded Sierra Leone. Many who later became RUF commanders were themselves conscripted by the invading forces in the early days in Kailahun and Pujehun districts. The rationale was simple and clear: Young boys were braver and more obedient than adults. Further, those who were also children became more effective killers.

The expert witness, Dr Stephen Ellis, stated in his expert report that such practice was likely taken directly from the NPFL. Doctor Ellis's report states at page 15 and I paraphrase that, the RUF's small boy unit was quite likely created in imitation of the NPFL's unit of same name and that the administration of drugs to young fighters was highly likely a particular abuse learned from the NPFL. Soon after the 1991 invasion, the RUF established various training bases at Kisiwolo in Pujehun District, at Dia and Pendembu in Kailahun District. Later also Matru Jong in the Bonthe District and Camp Lion in Kenema District were opened. During the indictment period between 1998 and 2000, a permanent base was opened at Yengema in Kono District. Temporary training facilities were also generally established at locations where rebels were based such as at Kangari Hills between 1995 and 1997, and at Superman Ground in Kono District between 1998 and 2000 and also at the Agricultural Road compound in Makeni in 1999.

The evidence shows that children were trained at these bases and underwent the same extensive training as adults. They were taught how to lay an ambush, how to attack, how to make an area fearful. Their training was often harsh and brutal. These children were deprived of food and medication and trained using very dangerous combat techniques, some involving live bullets. Such techniques often resulted in the death of trainees, the sad reality, as stated by a former RUF training commander, was that the deaths never meant anything. Dr Ellis, again, testified to this Court explaining the rationale behind such brutal training, and I quote from his report:

"Children abducted at very young age, 7, 8, 9 years old, then went through an initiation which brutalised them and created the state of mind of somebody who is prepared to cut off the hands of people who they have never met and against whom they have apparently no personal grudge, and who aren't even necessarily government supporters."

The conscription of children often commenced with their abduction. Several former child soldiers met this fate. Prosecution witnesses TF1-143, TF1-158 and also Komba Sumana and Edna Bangura, all former child soldiers testified to their abductions by rebels, all at the time under the age of 15. Thereafter, they were forcibly trained and used as front line fighters in full-scale operations including carrying out attacks during which they would often be assigned to the most outrageous tasks such as amputating hands, raping and looting. Other tasks included being used as food finders, bodyguards or domestic servants or even carrying ammunition and other supplies to and from combat operations. Abductions usually occurred during rebel attacks on villages. The evidence shows abductions around Kangari Hills between 1995 and 1997, also in 1998 during Operation Pay Yourself, many children were abducted in Makeni en route to Koidu and then between March 1998 and December 1999 about 500 children were abducted in Buedu. Abductions took place in many other areas across Sierra Leone. In the aftermath of January 1999 invasion of Freetown, some 2,000 children were reported missing by the UN. The rebels exercised control over children by brutally carving the letters RUF and AFRC or sometimes on the bodies, the forehead, the arms and the chest. These showed ownership and prevented them from running away. Under the influence of drugs such as cocaine, amphetamines, heroin and local alcohol, these children acted fearlessly carrying out the orders of their commanders, they committed the most horrible crimes known during the conflict. Prosecution witness Komba Sumana, aged 14 when captured in 1998 was given two months' training after which he was given a gun by Mosquito. He participated in numerous attacks during the indictment period including an attack on the town of Mongor Bendugu near the Guinean border. Two attacks on Kabala in Koinadugu District, an attack on Binkolo in Bombali District, an attack on Makeni and an attack on Gberi Junction near Lunsar. TF1-143 who was 12 when captured in Konkoba, Koinadugu District in September 1998 had very little training before being assigned to combat support duties by his commander. He was forced to hack to death two children, a man and a woman with a machete on the way to Rosos. Later, the witness and some other boys were given extra training at Rosos to prepare them for the January 1999 invasion of Freetown. He was part of the advance team. Under a different commander named Adama Cut Hand, he was actively involved in several amputations in Freetown on the orders of this commander.

The evidence shows that the child combatants were involved extensively in several operations of the AFRC/RUF across Sierra Leone during the conflict. During the January 1999 Freetown invasion, for instance, a significant number of rebel combatants were children; most adult fighters had SBUs attached to them. Human Rights Watch reported that RUF child combatants armed with pistols, rifles and machetes were witnessed actively participating in killing and amputations. Taylor's witnesses corroborated the Prosecution evidence led on the rebel's practice in Sierra Leone of recruiting child soldiers and using them in hostility, a practice borrowed from their big brother, Mr Taylor. As DCT-146 told this Court throughout the conflict, the RUF used children under the age of 15. The whole world knows about that. It happened. It happened. They used them for fighting. The children carried guns and they fought. It happened.

Finally, your Honours, I look at count 10 of the indictment, which deals with enslavement.

Count 10 charges Charles Taylor with the offence of abduction and forced labour in four districts in Sierra Leone, Kenema, Kono, Kailahun and Freetown and the Western Area. The offence is charged within the time frame provided in the Statute, that is, 30th November 1996 to January of 2002, but it is limited in scope for each of these districts, for Kenema, it is charged from 1 July 1997 to 28 February 1998. For Kono District, 1998 - February 1998 to 11 - to 18th of January 2002. For Kailahun District, it started November 1996 to January 2002. And for Freetown and Western Area, it's from 21 December 1998 to 28 February 1999.

The law and the evidence on this count like with the previous count is already in the Prosecution's final trial brief, and this can be found in section 9(H) of the brief. This aspect of my presentation therefore is intended to provide an overview of the evidence and it will complement the Prosecution's written submissions.

The evidence shows that the practice of enslavement was part of a pattern of conduct by the AFRC/RUF penetrated throughout rebel-held areas in Sierra Leone before, during and after the indictment. Like other forms of criminal conduct, associated with the war in Sierra Leone, enslavement of civilians was a prevalent tactic among NPFL forces that was derived from Liberia. It was introduced and gained notoriety almost immediately after the invasion. Shortly after the invasion, the NPFL began to use captured civilians to carry looted goods back to Liberia. Streams of civilians carting goods back to Liberia for NPFL commanders led Liberians to refer to Sierra Leone as "Kuwait", meaning a rich country. RUF fighters wasted no time in copying the practice. Soon they were conducting hit-and-run raids and returning to their base camps with captured civilians bringing looted goods. The evidence shows that both NPFL and RUF fighters generally captured civilians to perform forced labour or to conscript them into the fighting forces. Throughout the conflict, civilians were needed by fighters to support their needs in many areas, for conscription purposes, for carrying military supplies and looted goods, to perform domestic chores for commanders, for food finding, for making farms for RUF commanders, for mining diamonds and they also were used to serve as sex slaves and this they were engaged in the use of civil works such as the construction of the airstrip at Buedu.

In later years of the war, in particular during the Freetown invasion, fighters invented a new use for civilians and this was that they started using civilians as human shields. The AFRC/RUF therefore constantly hunted down and terrorised civilians during attacks on towns and villages. Civilians were captured and brought back to bases and camps to live with fighters. Civilians were so important to the fighting men that the AFRC kept a record of those held under their control. For instance in Kono District around the period 1998 to 2000 records were kept of commanders who took out civilians from the camps for food finding and other activities. Similarly, names of new civilians captured in operations were entered in the roster.

In addition to these methods of control -- in addition to these methods of control, the AFRC/RUF organised -- the AFRC/RUF's organisational structure had the office of the G5. Now, this office was responsible for coordinating between civilians and combatants. The holder of the office appointed a chairman from among civilians whose responsibility was to coordinate and supervise the efforts of his fellow townspeople whether for farming work, for civil works or for food finding. One such person was Aruna Gbonda. He testified for the Prosecution in this case. Gbonda told the Court:

"When the war came we were enslaved. Whatever they would tell us to do, that was what we would do. That was why we were doing the farming. We were in slavery. He was controlling us. If you did not do it, you would be beaten and that would be your pay."

Conditions of enslavement were quite pitiful. Captives were subjected to forced labour under threat of physical violence or death, often at gunpoint. Those who refused to work or tried to escape were routinely killed or brutally beaten. Life was often extremely difficult. Victims were generally deprived of adequate food and sometimes stripped and made to work naked.

In Kenema and Kono districts, which are diamond-producing areas, the practice of enslavement was primarily to provide forced labour for mining and for food finding to sustain fighters. The patterns of enslavement were similar in both districts. As mining depended on civilian manpower, the AFRC/RUF commanders pointed - appointed and made use of civilian chairman whose duties were to mobilise local civilians for labour and for mining. Men who refused to cooperate were beaten or killed. Where the civilians were kept in camps, they were simply moved to mining pits to work under the guards and returned daily. Refusal to work was met with beatings and killings, as this amounted to a failure to follow instructions, which was an offence within the AFRC/RUF, "FFI", they called it.

In Tongo, a rich mining town about 27 miles from Kenema, the civilian chairman also had to help evaluate the diamonds, in addition to providing labour. He was sometimes forced to provide men up to 5- or 600 a day. Mining was mainly conducted at a pit called Cyborg. Working under heavily armed security which included boy soldiers, civilians were made to surrender any diamonds they found to the authorities. If they refused or tried to hide it they were beaten or killed. Sam Bockarie and Eddie Kanneh had mining supervisors appointed there to whom all diamond were handed. During the junta period, Bockarie and Kanneh went to collect diamonds from Tongo weekly. The sandy walls of Cyborg Pit collapsed many times, burying alive civilians who were forced to mine there. Similar conditions applied to civilians in mining pits throughout Kono District, in particular Koidu, Wondedu and Tombodu.

Defence evidence largely corroborates Prosecution's evidence on the commission of the offence of enslavement. Many defence witnesses testified to AFRC/RUF's involvement in mining and in the use of civilians for that purpose. They also testified to the use of civilians for forced labour, to make farms in Kailahun District and to work on the construction of an airstrip which exercised - which exercise was embarked upon, upon the instruction of Charles Taylor.

Defence witnesses also testified to the AFRC/RUF involvement - being involved in looting and using captured civilians to convey looted property.

Your Honours, that ends my part of the closing arguments. And unless there are questions, I would hand over to my colleague, Mr Koumjian, who will address the Bench next.

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