The trial resumed at noon, with Munyard continuing the cross-examination.
Def: You said that the police were in uniform and you were not happy. The Special Court people were not in uniform so you felt at ease. People in uniform make you feel uneasy?
Wit: With the police officers, it was just after the war. I don’t feel uneasy with them all the time.
Def: This is not a criticism of you – many people would share your unease. It made you feel more comfortable with people not in uniform. Did the police tell you that you would be paid by the Special Court?
Wit: They did not tell me anything about money. They only told me that the Special Court wanted me to go to Freetown and I had to go with them.
Def: The first time assisted financially was with the OTP?
Def: And you spent two days away from home on that occasion. And they paid you 30000 Leones for lost earning for those two days?
Wit: They did not pay me, it was just an assistance.
Def: You didn’t tell them an amount. So they just decided to give you 30000 Leones?
Wit: I did not tell them what they should give to me. I gave them the estimate.
Def: What was your estimate for you and your family on a daily basis?
Wit: I told them that my family would normally use 5000-10, 000 per day, and they gave 20,000 for the two days.
Def: Both lots of money were given under the category of lost wages, and the reason was funds required to facilitate the witness for interview process.
Wit: I don’t know if that was the reason stated there. I told them I as not formally employed but some menial jobs where i could get that amount.
Def: You made a profit on that trip didn’t you? How much could you earn in November 2003 on average?
Wit: 5000-10000 for construction jobs. At times I could even get more than 10,000.
Def: Did you get work every day?
Wit: Yes, on a daily basis. I would be on a contract basis, two week contract, one week contract.
Def: How many in the family in November 2003?
Wit: six. Me, wife and four children.
Def: You did tell us yesterday that you incurred no transport, accommodation or food costs because you were driven by a police officer, put up for the night and provided with meals. Correct?
Def: When you told us that you were given money for food that can’t be right, unless it was a profit?
Wit: The money was for food in the morning.
Def: What morning?
Wit: It was 10000 leones.
Def: Was it the first morning you were being interviewed in November 2003?
Wit: The evening for dinner, cigarette and breakfast and lunch.
Def: You said yesterday that they brought that to you at no cost to you? If they give you money for food and meals, they say so in the document that spells out how much was given. How much does a packet of cigarettes cost in 2003?
Wit: Up to 1000 Leones.
Def: how many packets to you have a day?
Wit: At times I can smoke 2 sticks of cigarettes.
Def: how many in a packet?
Wit: 10 or 20.
Def: How many do you get for 1000?
WIt: pack of 20
Def: How many packets do you smoke for one day?
Wit: This money is for your breakfast and lunch and you can smoke. They did not give it to me – I requested it. It was not only food and cigarettes, I bought some medicines. I was not feeling well. I did not explain that to them. Apart from food they bought to me, I got more food so I could eat more than one meal a day.
Def: How can you remember that you asked for money for cigarettes and medicine in November 2003?
Wit: I’m not getting things mixed up.
Def: You were not paid a single Leone for anything other than lost wages for 30000 Leones. Now you saw them again in March 2004 and you told us about that occasion. In 2004, it was for more than one day – do you remember?
Wit: When they met me in 2004 and I traveled to Freetown I was there for more than a day.
Def: How many days?
Wit: Up to 4-5 days.
Def: Did you pay your own transport costs or did they take you?
Wit: They paid the transport fare and the accommodation.
Def: Did you pay for your meals?
Wit: they paid for the food where I was.
Def: Did they pay for your cigarettes?
Wit: I was given money for transport I thought I could pay from change for cigarettes,.
Def: Did they pay you for loss of wages for those days?
Wit: I was not permanently employed, the looked into that and they assisted me.
Def: When I use the word pay – it means to give someone money. If it means something more than that to you I will use another word.
Did they give you money – 5000-10000 for the family. How much did you need per day for the family and how much were the earnings from the casual work you were doing?
Wit: The work that I did, there were days I would get 5000, sometimes 10000. They were just assisting me because the money from the casual jobs I was doing was sometimes more than what the Special Court gave me – because there are contracts that i had that I would get more than 50000 leones. In 2003 and 2004 the money they gave me for 2 days, 4 days, they did not pay me the exact money I used to get. It was just an assistance.
Def: In a typical week, you would earn 5-10,000 a day in a typical week, not 50000 leones a day?
Wit: They told me that they would not pay me so I accepted that.
Def: They assist people.
Wit: I don’t know about other people.
Def: They assisted you didn’t they? And you are well aware that they assisted other people as well as you, aren’t you?
Wit: I don’t know about other people. I know about mine. This is my honest answer. I did not meet with any other person who was a witness. They only me about mine. They told me I should not disclose anything related to the court.
Def:Between 20 Nov 2003 and February 2008 – you have never come across anyone else who has been given assistance by court.
Wit: I don’t know.
Def: What else did you get assistance for in 2004?
Wit: Only transportation fare – only that.
Def: And loss of wages.
Wit: I was not on salary.
Def: Earnings maybe. You would need to be assisted to the loss of money otherwise earned. When you go to the court in 2004, weren’t in full time court, and same with November 2003. They gave you 30000 leones assistance to cover the lost opportunity that you had to make money that you weren’t able to do because you were in Freetown with the Special Court. So they presumably gave you the same as you were in he same position as in November 2003.
Wit: Yes they assisted me.
Def: You said in 2003 you had spent some money on medicines and cigarettes.
Wit: But that was my own private issue I did not discuss it with them. The money they gave to me was not even up to what I used to earn for a day.
Def: Why did you not tell them that it was not enough?
Wit: I just accepted it.
Def: You said that a packet of Leones cost 1000. Does it cost a round sum or something other than a round sum? Could it cost 638 Leones for example?
Def: What would it be?
Wit: Some sold at 500, some at 1000.
Def: Can you find things for other sums?
Wit: There are bills and coins.
Def: What is the value of Leone coins?
Wit: smallest coin is 50 leones.
Def: does it go up 50, 100, 200 and so on?
Wit: The highest is 500 leones.
Def: so you pay for things in 50s, 100s, or 1000s?
Def: You said you have a precise memory of money for 2003. Is your memory of 2004 absolutely accurate?
Wit: It was transportation fare.
Def: How much was that?
Wit: I cannot remember the exact amount.
Def: How much did it cost to go from your home to Freetown and back?
Wit: Transportation 17000 leones, 15000 leones – one trip. If you make a trip.
Def: So also paid you for fact that you couldn’t make money during those 4-5 days in Freetown?
Def: How much?
Wit: I cannot remember the amount they gave me.
Def: Was it 30000 leones?
Wit: it was more than that.
Def: how much more?
Wit: I cannot tell the exact amount. But it was more than the first occasion,.
Def: Put prosecution on notice that we want records of payments for March 2004.
Now move on to January 2006. You told us you think you were there for several days. Let me ask you about the 26th January 2006. The documentation we’ve been given, you were paid 30000 leones, for transport/meals. Can you remember being paid 30000 Leones for transport and meals in late January 2006?
Wit: In January they met me but cannot recall the amount of the money they gave to me.
Def: your memory of what given then is not as accurate on your memory in 2003?
Wit: Some areas I could recall but I cannot recall. Besides 2003 there was some assistance but some I cannot recall.
Def: on the same day of 2006 you were given another 30000 for transport and meal costs to meet with Witness Management Unit. Did you have to go anywhere else apart from Freetown while you were there?
Def: So you got 60000 for transport and meal costs. Did you get anything else that time?
Wit: Later I was assisted at the time I was unemployed I was given money for school fees for my children, books, uniform and shoes. My wife fell ill, I also got ill, I got assisted.
Def: I’m only asking about January 2006. Confine to that. Know you got 60000 in transport and meal costs – did you get other assistance?
Def: Is your memory accurate about amount received in 2006 January?
Wit: I cannot recall exact amounts were. My memory is accurate 50 per cent on this issue.
Def: you got 60000 for lost wages two days after 60000 for transport and meals.
(Defense continued to go through payments – the following picks out only the major points)
May 2006 – interviewed in Bo. Similar questions were asked about transport and food money. The main themes were to determine whether the witness was profiting from his engagement with the Special Court. The witness rejected the notion that he profited.
The discussion also canvassed the assistance the witness received to pay for his wife’s operation. Witness noted he was given 150,000 for the operation. And given 180,000 Leones for the rest of the medical costs.
Munyard and Mansaray also discussed interviews which took place in his home, as well as payments for the witness’ school fees and uniforms. The defense suggested that the witness got a profit of 250,000 Leones because the Special Court paid for school expenses.
The defense reached December 2006, and discussed the Special Court’s assistance with Mansaray’s medical bills, before the session ended. The defense indicated it had six more occasions to ask the witness about on Monday.
In the 45 minutes after this session was scheduled to end, the court moved to discuss the next witness to be called. Munyard indicated that Defense lead counsel Courtney Griffiths (who had prepared to cross-examine the next witness the prosecution wanted to call on Monday) will be cross examining an expert witness at a retrial back in London on Monday. He cannot say for certain whether he can be in The Hague for Tuesday morning. The Prosecution wanted to push ahead with the witness, as they had put extraordinary security measures for a family of a witness in place for next week. If the witness did not start providing testimony by Monday, according to the Prosecution, their evidence may not be finished by the end of next week. Yet the security measures for the family of this witness can only be guaranteed until the end of next week. “This is the most important trial taking place in the world today,” said Nick Koumjian for the prosecution. He said that the defense had appointed four senior counsel, and the witness should be able to start in chief even if lead defense counsel was not in court. Defense objected to the way that the Prosecution had dealt with the Defense about this witness and the order in which the witness was scheduled to appear, and argued that it was not proper for the Prosecution to expect that another counsel can simply take over preparations for the witness over a weekend. Lead Prosecutor Brenda Hollis responded forcefully to object to the defense objections. The bench retired to consider the decision.
Cross examination of Mansaray will continue Monday morning at 9:30am.