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

Well, let's see. I think that's a possibility. Assuming we are taking an hour lunch break as usual.

Your Honours, I'm starting with the events of Freetown and the invasion of the 6th of January 1999.

The evidence shows in this case, in the evidence that's presented in this trial of Charles Taylor, it shows that those attacks that occurred in Freetown and the Western Peninsula in January 1999 were a coordinated actions, they were committed by the combined forces of the RUF and the AFRC, and the evidence shows that Charles Taylor played a key role in those events. In fact, that but for Charles Taylor, all that suffering that we heard about in this trial, the almost incomprehensible atrocities that occurred in Freetown, from people having their limbs hacked off to being multiply raped to being burned alive in their homes would not have occurred but for the contribution to those crimes made by Charles Taylor.

Charles Taylor planned that offensive. He facilitated the attacks, and he profited by the gains of his allies, the RUF and the AFRC alliance in what they did in December 1998 and the early part of 1999.

Several witnesses talked about Taylor's role in planning that offensive, and I'll just briefly go through some of that evidence. On the 28th of January 2008, page 2412, a witness in closed session, said, "He met us eating. He came in excited, and he said, this is Sam Bockarie, he had just been on line with Mr Taylor, with the Pa, I mean that was the common name, you know, and he said he gave the instruction directly to his commander. 'This is Operation No Living Thing. We should by all means capture Freetown.'"

Witness Karmoh Kanneh testified on the 9th of May, at page 9424, he was talking and several witnesses talked about Sam Bockarie coming back from his trip to see Mr Taylor and the trip that Mr Taylor arranged to Burkina Faso. Taylor admits arranging Sam Bockarie's trip and travel documents to Burkina Faso, and sending his chief of protocol Musa Cisse, who Charles Taylor also told us arranged his own illegal arms shipments into Liberia. Several witnesses talk about Sam Bockarie coming back with huge amounts of ammunition from that trip and Karmoh Kanneh said on the 9th of May that at the meeting at Buedu, page 9424:

"Bockarie explained to us that he has brought ammunition, he has brought enough logistics so that we will be able to run any kind of mission. So he said we should now plan how to take the move and that the first target should be Kono to Makeni and up to Freetown. And that the next target should be Segbwema and Daru, that is heading towards Kenema and to go to the southern province. Those were the things we discussed and the issue of SAJ Musa's disloyalty, what he has been doing all along."

And he went on to say, "Sam Bockarie told us that this plan was designed in Monrovia with Mr Taylor."

Isaac Mongor testified on the 11th of March about talking - going to Buedu, being called by Sam Bockarie after Bockarie returned from that trip for the meeting of the commanders, and he said that Bockarie showed him ammunition and he said, at page 5795:

"After he had shown the ammunition to me he told me the plan that he had come up with, with respect to those ammunitions. He told me that he and Mr Taylor sat together and planned to come and run an operation. He said he sat with the Pa, Mr Taylor, who took out a map and showed the locations where the RUF and the SLAs, where we occupied, and he showed that to him. He came with a plan for us to launch an operation whereby we'll capture Kono, Makeni, and advance to Freetown."

Augustine Mallah also was called to Buedu and talked about the meetings there when Bockarie came back from Liberia. And he said on 13 November, page 20219, that Bockarie, "Told us he had come from Liberia to Charles Taylor, he said he had received arms and ammunition and he brought some reinforcement that had been given to him for a particular mission that he wanted to undertake."

And he explained that this reinforcements that along with them came Abu Keita which of course corroborates Abu Keita's testimony about the Scorpion unit that was sent by Taylor. Charles Taylor personally met with Abu Keita and sent him to Sierra Leone.

Your Honours, this offensive that happened in December 1998 occurred while Sam Bockarie was making a series of threats before, during and during the offensive, that were broadcast on the international radio, and I'm not sure but perhaps some of this addresses Justice Sow's question earlier. In Exhibit P-431 we have a press report of a radio broadcast. It's dated 7 September 1998. Sam Bockarie threatened to wage a campaign of genocide if Sankoh was not immediately released. And the broadcast or the article quotes Bockarie:

"I will order my troops to kill every living thing including chickens if our leader is not released."

P-430(B) is another press report of 19 November 1998. Sam Bockarie then, it said that he had told the press the RUF will destroy every living thing, if anything happens to their leader, and it quoted Sam Bockarie as saying, "I am a ruthless commander. I am ready to damage but I am waiting till something happens to Sankoh. When I take Freetown, I shall clear every living thing and building. To my God I'll fight. I'll kill and kill. And the more they tell me to stop, the more I'll kill."

Then P-430(D) which is dated 27 December 1998, Sam Bockarie was claiming that his fighters, which is true, had captured Makeni and he said that they had killed 60 ECOMOG soldiers and dragged their bodies through the street as an example to everyone. Bockarie then threatened if Kabbah failed to resign they would start bombarding Freetown and not stop until victory was won.

On page - excuse me, paragraph 59 of our brief is the passage that the Prosecutor, Ms Hollis, was referring to earlier this morning where witness TF1-406 on the 9th of January 2008 at page 866 said that - he heard Sam Bockarie say that he would not retreat unless his father told him to do so.

The RUF contributions to the events in Freetown in January 1999 took four forms. First, the RUF contributed to it by altering the military balance in the country, in Sierra Leone, which is a small country. Second, the RUF contributed to the events inside the city, with manpower, by providing communications and by providing warnings of the Alpha Jet attacks by ECOMOG to the fighters inside the city. Third, the battle of Freetown did not take place just inside the city. It would be very artificial to look at that military situation that way. At the same time that ECOMOG was fighting the group commanded by SLA soldiers, former SLA soldiers, Gullit and others, the RUF was attacking, at the door step. The RUF was on the western peninsula trying to get into the city, attacking the forces at Jui, the Nigerian forces at Jui. And fourth the RUF contributed to the events because the evidence in this case shows without doubt that the atrocities that were occurring in the city were occurring under the orders of Sam Bockarie, the leader of the RUF, the man that Charles Taylor said he admits to having met three times in the preceding months of September, October and November, and the man that Charles Taylor said he felt like Bockarie was his son. Sam Bockarie also finished one of his letters to Charles Taylor saying, "Your obedient son."

One way we can look at how the military balance was altered is by looking at the evidence of Issa Sesay and two maps that he drew. So if we could possibly have P-574, two maps marked first, and then P-577. But first P-574 is a map marked by Issa Sesay that shows the military situation of where the RUF and the AFRC forces were and where their enemies were, ECOMOG and Kamajors as of 15 December 1998 before the offensive was launched. Perhaps that could be brought up a bit so your Honours could see and the audience can see. And we can see that Sesay marked in what looks to me like a green colour the areas that were controlled by ECOMOG. So before Sam Bockarie launched these attacks with the ammunition that he brought back from Liberia, Issa Sesay admits that none of these attacks would have been possible, the attacks on Kono and Makeni, without the ammunition brought back from Liberia. These attacks would change - what changed between 15 December 1998 and the 5th of January is that the RUF, not the SLA, not Gullit's group, not SAJ Musa's group, the RUF had taken Kono. They had taken Jaiama Nimikoro, they had taken Giema, Masingbe, Magburaka, Makeni and they had even attacked and held parts of the city for a time, Port Loko, although they were unable to hold and to capture Port Loko. P-577 then shows the situation on the western peninsula the day before the attack.

This is from the Defence witness Issa Sesay.

And what we can see from this, what's instructive about it, is that he's marked the area where Gullit's group was, because by this time SAJ Musa was dead, in blue. So they are on the western peninsula. But we see that behind them, there are ECOMOG forces, not just inside the city but at Hastings, I believe that Jui, at Port Loko, and ECOMOG still held, critically, Lungi, the international airport at Lungi. In any attack on Freetown, it was predictable that reinforcements would be sent, Issa Sesay talked about how, when he planned the attack on Koidu they planned for ECOMOG to be sending reinforcements from Makeni and he had Morris Kallon set an ambush. In this situation, the reinforcements that could come into Freetown would be expected to come from Lungi airport, or if they came from Conakry from Guinea the forces that were available they would come down the road through Port Loko. Even from Lungi to get to Freetown you have to go on the road through Port Loko, so Port Loko and Lungi were key. Issa Sesay admits that before the attack on Freetown, the 6th of January, Sam Bockarie had ordered an attack on Port Loko, with the idea, with the objective, of taking Port Loko and moving on and taking the international airport at Lungi. The evidence is not disputed and Issa Sesay confirms Prosecution evidence that after SAJ Musa conveniently died, the one person who wouldn't cooperate with the RUF, conveniently died in an explosion where he ended up with a hole in the back of his head, that when Gullit took over, communication began immediately, and Gullit asked the RUF for reinforcements. It is not in dispute, Issa Sesay confirms Sam Bockarie planned to send reinforcements. Isaac Mongor got the order from Sam Bockarie to begin to move to Freetown, to reinforce the group in Freetown, and Sam Bockarie ordered the attacks on Port Loko. When the attack on Port Loko was not successful he ordered an attack on Lungi. And Justice Sebutinde asked Issa Sesay why he, the RUF, attacked Waterloo. And his answer was absolutely clear. His answer was that the RUF - trying to find my notes exactly where that is - but his answer was that the RUF attacked Waterloo in order to get to Freetown, that Freetown was the capital, that - in other words Issa Sesay said at the same time that the RUF - the AFRC was inside the city, the RUF was fighting to go inside the city. So they were fulfilling what Sam Bockarie had promised about sending reinforcements. They were trying to, sending reinforcements to the AFRC, to the group inside the city, which included many RUF fighters.

And actually Issa Sesay said, first about Bockarie, promising to send reinforcements on the 9th of July at page 44163.

Inside - and then - okay, excuse me. Inside the city, many of the - while the troops were commanded by SLA officers, by Gullit, Bazzy, Five-Five, the troops included many RUF and Liberian fighters, particularly we received - we have - your Honours have heard a lot of evidence about the Red Lion Battalion which witnesses AB Sesay, Alice Pyne, TF1-375, King Perry Kamara, all said included RUF, SLA and Liberian soldiers and some STF. Their evidence was also confirmed by two crime victims, TF1-028 and TF1-143. They both also talked about these NPFL or Liberian fighters and RUF fighters being part of the group that made up the Red Lion battalion which committed many atrocities inside Freetown. Alice Pyne said she - that with those fighters was a man named Senegalese and this Senegalese told her that he and about 30 men with him had been sent by Charles Taylor.

King Perry Kamara explained that as the group was in the Northern Jungle and coming towards Freetown that they were joined by many RUF fighters that had become separated during the intervention but that found out that their - the group was there and came and joined them.

Inside the city we know that one of the first acts of the invading forces was to open up the Pademba Road Prison and RUF fighters were removed from the prison and joined the attackers, including Gibril Massaquoi, one of the infamous RUF commanders.

Another group that was inside the city, eventually joined the group inside the city, was the group led by Rambo Red Goat. Rambo Red Goat, the evidence is, was a SLA officer, but he had been one of those who had been on Superman's side in the fight against SAJ Musa in the north, Komba Sumana and others have testified to that. The evidence from the Prosecution witnesses including TF1-375 and AB Sesay is that Issa Sesay sent Rambo Red Goat with a group of RUF fighters into the city.

AB Sesay even was there to receive the group. He was the one that met them and brought them into the city. TF1-375 explained that Issa Sesay chose Rambo Red Goat because he was SLA and he would be known to the other commanders inside the city. What was very interesting during the testimony of Issa Sesay is that very, very early in his testimony, he was asked about a Red Goat Battalion and he said the Red Goat Battalion is the same as Rambo - is Idriss Kamara. This is all in our brief also. And then when I asked him, when he was being cross-examined, if he sent Rambo Red Goat, of course he denied it because that would show his complicity in the attack on Freetown, and he said he didn't know the name of Rambo Red Goat, but he had earlier in his own testimony said that Idriss Kamara was the person associated with the Red Goat group. He said that in July during his direct examination. On redirect examination, he tried to explain it by saying, oh, the reason he said Idriss Kamara was Red Goat was because Defence counsel in proofing, I believe he said in Rwanda but he said Defence counsel had told him the names of the witnesses and that's how he put it. The Defence counsel had told him that Red Goat was Idriss Kamara, but this contradicted what he had said earlier during cross-examination. Then he said that Rambo Red Goat used to visit the other AFRC accused in the detention unit and he had come to learn the name Idriss Kamara from the other AFRC accused.

So Issa Sesay's contradictions show that, in fact, he did know very well that Rambo Red Goat was Idriss Kamara, he's lying about that because it shows his complicity and the complicity of the RUF and eventually the complicity of Charles Taylor in the events in Freetown on the 6th of January. And to just add something into the answer of the question of Justice Sow, when the Prosecution selects witnesses, all of the witnesses we called, we believe told the truth. We certainly don't believe that about many of the Defence witnesses, and not every individual will tell the truth. We don't select people to come into court that we know are lying.

And I'll come back to Issa Sesay and the clear proof that he was lying, the person who denied all his crimes later.

The evidence also shows, from AB Sesay that Rambo Red Goat brought with him ammunition, so that would have been - Issa Sesay said the RUF had no ammunition until Sam Bockarie came back from Liberia, so that would show that Rambo Red Goat brought into the city of Freetown towards the end of the invasion when the atrocities started really happening, people were getting their limbs hacked off and burning their house, they were doing it with the ammunition sent from Liberia, that we say clearly came through the arrangements made by Charles Taylor and his chief of protocol Musa Cisse.

Many of the witnesses who testified, your Honours have heard many of these crime base witnesses, and they talked about hearing people speaking in Liberian languages during the invasion. Mohammed Sampson Bah who testified on 23 October; Abubakar Mansaray on 29 October 2008, these are all crime victims; Osman Jalloh, 1 October 2008; Alpha Jalloh, 23 October 2008; witness TF1-358, who was a doctor from Freetown, he talked about hearing it, a man named Mr John talked about that and said in fact he knew some of these - well, he said he also recognised some of the people at the hospital as people who were ex-RUF child soldiers he had tried to rehabilitate years before.

One thing to keep in mind because one obvious explanation for Liberian English would be that the STF commanders were Liberians. That evidence is not disputed by the Prosecution, but your Honours will recall that the evidence is that General Bropleh with the STF, he was on the Superman side when Superman and SAJ Musa had the falling out and General Bropleh with Superman was one of the groups that attacked Makeni. So the STF, the main STF force was not inside Freetown, it was in Makeni. That came from, for example, Komba Sumana, who was himself with the STF and from TF1-375. Bropleh was in Makeni, not inside Freetown.

Another witness who talked about the RUF being present in Freetown, if we can just play a very brief clip from P-286(A), just to remind us of who this man was, the last witness who testified for the Prosecution. This of course was Alusine Conteh, who had his left hand hacked off and when his little boy began to cry, the rebels wanted the little boy and instead Mr Conteh sacrificed his right hand.

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