Au Kanseng Security Center Cadre Concludes Testimony

Today, anonymous witness 2-TCW-900 concluded his testimony in front of the ECCC. He told the Court about living conditions at the center. Moreover, he provided information on authority structures at the security center. He denied having personally killed any Jarai and exercised his right to remain silent when he was asked whether he had ordered the killing of Jarai.

Clarifications of yesterday’s testimony

All parties to the case were present, with Nuon Chea following the hearing from the holding cell. The floor was granted to the Civil Party Lead Co-Lawyers. Civil Party lawyer Chet Vanly wanted to know why there was an integration of the two divisions 11 and 14 into Division 801. He replied that this took place to advance to liberate Phnom Penh. They were stationed at Phnom Sarat and lacked forces there. They were under the supervision of the Special Zone. Chey Orn was one of the persons in the leadership of this division.

Moving on to another topic, she wanted to know whether Sau Saroeun and Men San had their position in this division. He replied that Saroeun remained there but that San was transferred. He could not remember in which zone Au Kanseng was located in and only knew that it was in the Northeast Zone. The security center was established in around 1977. He said that it did not have any other name. The Security Center was under the supervision of Division 801. Workers were partly from 806, while others were from the handicapped unit and others were assigned from the sector. They all lived in the compound of the security center. It had a kitchen that was built next to the stream. During mealtime, security guards and cadres had their meals in the kitchen. The detainees who were shackled were bought food to where they were detained. There was no pit inside the compound of the center.

Ms. Vanly then wanted to know about the specific role of the leading roles. He replied that Se was overall in charge of the center. Tin was in charge of security matters within the compound, and the witness was in charge of confessions and documents. There was no other staff working in the center besides the nine guards. Tin managed the guards, so he did not know the details of the assignment. He confirmed that the center was controlled by 806 under the supervision of Ta Smien. After his disappearance, the communication between 806 was to be made with Ta Kuoy. Before reaching Ta Saroeun, it had to go through Mon. Koy and Mon frequently visited the center, but Saroeun never came. They held internal meetings; that is between the youth league and the party representative. They would talk about security matters and living conditions. Most of the prisoners were soldiers. There was a small number of people from the cooperatives and a few people from the union. The soldiers were brought in from regiment 81, 82, 83 and battalion 803, and some from the so-called Special Unit. Regarding the soldiers who were brought in from the soldiers, he only saw one who was blindfolded and a few who were tied on their hands. The others were not tied up, but there were armed soldiers. The blindfolded soldier’s name was Pheng Phay. This person was implicated by the confession of Lay Sarim. The latter was not sent to Au Kanseng, but he indirectly heard that Lay Sarim was sent to Phnom Penh.

He received soldiers from the regimental level. He did not know in detail who made the orders for the arrests, but he knew that it was made at the “upper level”. The Security Center supervisor did not have any authority to arrest anyone. He needed to seek permission from the upper echelon. He could not answer who the upper echelon was. Ms. Vanly wanted to know which offenses they were accused of. He replied that they were mostly accused of stealing food, fruit, or corn without seeking permission from their group or unit chief. Some of them were accused of being “lazy for work’.

When prisoners were brought into the Security Center, the work to draw lists of the prisoners’ names was done by the security staff. He never saw any confession being sent in with prisoners.

He could not remember the number of prisoners, but estimated that there were more than 100 but less than 200. The number was stable and only increased once. He never saw the prisoners being pointed at with guns on the trucks that brought the prisoners in. The armed prisoner guards unloaded the prisoners from the trucks.

Sometimes the prisoners would come in groups of three, sometimes only one, and not more than five were brought in at one time. The witness himself did not have any authority to manage the prisoners in the center. Tin was responsible for chaining the prisoners and locking them in. There was one group of prisoners who were brought in with their family members from the cooperative. Two or three families from the union were brought in with their families. At first, they were placed in different locations. Later, they worked together and were allowed to stay together at the last stage of detention.

Se was in charge of re-education meetings at the center.

She wanted to know whether there were latrines within the center, which the witness denied. As for hygiene, he said that they were allowed to clean themselves. Those who went out to work bathed in the river. Those who were detained in the holding cell would be walked towards the stream when they wanted to wash themselves. During the regime, the food rations were given in a bowl. They received one meal in the morning and one in the evening. The bowl was medium-sized.

Toward 1979, some prisoners were allowed to work with the witness and not locked in the holding cell. They were instructed to work with him close to the border.

She then turned to interrogations and wanted to know whether he examined the relevant documents in relation to each prisoner. He answered that Pheng Phay had a document with him. At that time, they wanted to know the reason why Pheng Phay was brought into the Security Center. She then wanted to know what methods were used when interrogating the prisoners. At this point, Nuon Chea Defense Counsel Victor Koppe objected and said that it had been covered by the Co-Prosecution already, that the Civil Party lawyers had been granted thirty minutes, and that interrogation was not part of the closing order. Senior Assistant Prosecutor Vincent de Wilde replied to this objection that torture was not in the closing order itself, but it could be considered as inhumane and degrading acts under the closing order and remained relevant.

She moved on and wanted to know when he got married. He replied that this took place in March 1977. He had proposed her name to Angkar. He was called in the evening and told about his marriage. The wedding took place at 10 pm. Four couples were in the wedding. They were “quite old”, he said.

 

Conflicts with Vietnam and rebellions

The floor was granted to the Nuon Chea Defense Team. International Co-Counsel Victor Koppe inquired about commanders in his unit who were “cadres from Hanoi”. He replied that they were cadres from Hanoi and disappeared later. The unit was under the supervision of San. When attacking the battlefield at Prey Treah, they were moved to the northwest of Phnom Penh. There were no cadres from the north in charge of this unit.

Mr. Koppe wanted to know whether only his unit was involved in Operation Chenla or also Vietnamese soldiers. He answered that he only saw Khmer soldiers when he became part of the unit and heard about it. Judge Jean-Marc Lavergne asked Mr. Koppe to be more precise in his question. Mr. Koppe said that it seemed like the witness did not have much knowledge about this and moved on.

He then wanted to know what the policy of their units was in relation to captured Lon Nol soldiers when they attacked Phnom Penh. The witness replied that he did not have an explanation of this issue, since he was in charge of the radio operation.

Mr. Koppe asked whether he knew in general terms what his unit did when it was hosting the big meeting in the Olympic Stadium in 1975. He answered that he did not know details about this meeting.

Mr. Koppe asked whether the witness knew Chhaom Se’s wife at the time, before he continued to read an excerpt from a statement from Chhaom Se and his wife. He replied that he knew her well and confirmed that her name was Pheap. She was a medic in the company. He did not know her rank in Company 14. Mr. Koppe said that she had given a long interview to investigators of DC-Cam and had said that Bong 05 had checked first for poison before letting guests the food.[1] Mr. Koppe wanted to know whether he knew any fears about soldiers or guests who could be poisoned during this meeting. The witness did not know.

Mr. Koppe said that the witness had said that San, Number 2 of 801, had gone to 920 and wanted to know whether there was any connection between the two divisions. He did not know. Mr. Koppe wanted to know whether Ta San (alias Number 06) was replaced by someone called Kev Saroeun. He answered that he did not know who he replaced. He could not remember this name.

Mr. Koppe asked whether he had heard of someone called Ung Ren, which the witness confirmed. He used to be the deputy commander of Regiment 82 during the northwest battles, the witness said.

Mr. Koppe turned to the topic of armed conflict and asked what he could tell about Vietnamese incursions into Cambodia in Mondulkiri and Rattanakiri. He replied that between 1978 and 1979 there were clashes along the border with Vietnam, which was where Division 801 was stationed. He answered that if he stayed at home and a cow came near his house, he would chase the cow away. He replied that he referred to other nationalities and in particular to Vietnamese people who came into the country with arms. “What is the purpose of carrying arms into Kampuchea” when they had their own country, the witness asked. Mr. Koppe referred again to Pheap’s interview, in which she had talked about Vietnamese invasions.[2] He answered that the testimony by Se and Pheap was their own recollection. Say came from the battlefield on road 19 and was in Regiment 19. The reason that they were relocated to that area was because Vietnamese came into that area. He did not know anything about Vietnamese spies coming into the country first. Mr. Koppe said that there was a Division 920 soldier who had given an interview to DC-Cam as well, who had said that it was “the Vietnamese who started the attacks first”. Mr. Koppe asked whether the witness could remember this. At this point, Mr. de Wilde said that this method was not appropriate, since he had not given references and provided the witness with information without giving any names.

At this point, the President adjourned the hearing for a break.

 

At the beginning of the next session, Mr. Koppe referred to a witness’s statement, who they had requested to appear before the Chamber, and who had said the Vietnamese started the attack first.[3] The witness replied that he was far away from the battlefield and did not know who fired first. Mr. Koppe read an excerpt of what Son Sen had said in a Standing Committee Meeting.[4] Son Sen had talked about Vietnamese border incursions and military attacks in the Northeast Zone. He replied that he only knew about attacks by Vietnamese within the Cambodian territory. When Mr. Koppe asked whether the Vietnamese did not start the attacks, Mr. de Wilde interjected and said that the question was repetitive and that the witness had already said that he did not know.

Mr. Koppe asked whether he heard anything about Vietnamese attacks in the night of 22 January 1976, which the witness did not know.[5] Mr. Koppe then wanted to know whether he heard anything about a rebellion within CPK, to which the witness responded that he did not understand. Mr. Koppe referred to storing weapons in a warehouse and attacks on the airport and the radio station in Phnom Penh with the support of Vietnam and inquired whether he had heard anything about this when he was in Division 801. Again, Mr. de Wilde interjected and said that he had the impression that the defense took for granted all the facts they had mentioned. Mr. Koppe replied that he did not understand the objection. Mr. Koppe said that he spoke about Sen Hun’s testimony. Mr. Koppe repeated his question and asked whether he had heard about any of these attempts of rebellion backed up by Vietnam. The witness said that he did not know about this.

Mr. Koppe asked whether he was sure about this, since “you are Number 2 or 3 of Au Kanseng Security Center” and responsible for taking notes in interrogations. He replied that his knowledge was not broad about situations outside the Security Center.

Mr. Koppe read an excerpt of Pheap and Chhaom Se’s testimony in which they had talked about rebellious attempts.[6] Mr. de Wilde interjected again and said it would be interesting to read the source of the statement. He said that the soldier said that the information was obtained by Theap, saying that the soldier “confessed”. They were not eye witnesses. After conferring with the bench, Judge Claudia Fenz said that it was not possible to determine whether it was torture tainted. She requested the Prosecutor to show where exactly he had found this and Mr. Koppe to move on for now. A decision would be rendered after the break. Mr. de Wilde referred to the exact extract. Mr. Koppe said that what she had said about explosions and people being trained in karate, for example, to protect Pol Pot, could not be read in confessions.[7] The sources may have stemmed from confessions, but she gave a lot more information.

Mr. Koppe moved on and wanted to know whether the witness had heard of a witness called Chan Chakrei, which the witness confirmed. He did not know details about Chan Chakrei’s activities. Mr. Koppe read an excerpt of the interview again, in which they had said that Chakrei was vicious but suffered strongly on the battlefield.[8] The witness replied that Se was at the company level and seemed to have greater knowledge than the witness.

Mr. Koppe inquired about the person called No who the witness had believed to come from Phnom Penh. The witness replied that No had told him that he came from Phnom Penh. He looked like someone who came from a city.

Mr. Koppe wanted to know whether there were also units with the numbers 809 and 810. He replied that 809 belonged to Ta Van Na, but he did not know about division 810. Mr. Koppe read an excerpt of another witness, who had said that working conditions were harsher in 810, but living conditions were similar in 809 and 810.[9] The witness replied that he did not know about this.

 

Re-education measures and categories of enemies

Mr. Koppe read another excerpt, which referred to re-education measures and said that before someone was arrested or removed from a unit, there had to be three or four sessions of education. He replied that the measures in relation to Au Kanseng Security Center were having gone through one or two re-education sessions before being arrested. When Mr. Koppe asked whether it was something he believed or something he knew that there were two or maybe three or four reeducation sessions. The witness replied that he would receive documents sometimes indicating that they had been twice to a reeducation measure and did not change in the third session. The witness replied that he did not know about the measures applied in units.

Mr. Koppe moved on and inquired whether he had heard about three categories of enemies. The witness replied that he had already answered the question yesterday. Mr. Koppe quoted Son Sen who had said that it was imperative to purge enemies according to three categories.[10] The witness answered that he did not know the document. As for Revolutionary Youth magazines, he said that he sometimes read them, but could not remember the content. Mr. Koppe referred to a Special Issue of the Revolutionary Flag of September 1977.[11] This Revolutionary Flag distinguished between different categories of enemies.

He recounted that some prisoners were not serious enemies, since they were not shackled and were allowed to work outside. When Mr. Koppe asked whether the other detainees were in the second category, Mr. de Wilde interjected and said that the question was leading. Mr. Koppe rephrased and asked whether the other detainees were also in category one or two. He wanted to know in which category the detainees from Division 801 belonged. The witness answered that it was difficult for him to answer.

After one or two “of them” had been smashed, they were allowed to work outside on a plantation. If they were allowed to do so, they fell into the third category.

At this point, the President adjourned the hearing for a break.

 

After the break, the floor was granted to Judge Lavergne, who issued an oral ruling on the matter of possibly torture tainted evidence. He explained that the Chamber could not determine with certainty that the information from Pheap came from S-21, but only that the origin was uncertain. Thus, they authorized the use of this document and the questions Mr. Koppe had attempted to ask earlier.

The floor was then granted to Mr. Koppe. He turned back to the topic of three categories of prisoners and asked whether he heard about a guideline of the Central Committee of June 1978 towards the party policy of “misled persons”. The witness confirmed this. He was aware of it through Se. He elaborated that from that time onwards, the minor offenders were allowed to work the field along Road 19 close to the border. He did not talk to these people. The guidelines were more lenient. For example, food rations had to be provided sufficiently in an appropriate manner. Prisoners who went with him to work were allowed to eat “whatever they found”. The remainder of the prisoners were released to go to work.

Mr. Koppe read an excerpt from Chhaom Se’s interview who had referred to prisoners who were released.[12] The witness explained that releasing meant that they were allowed to work outside the compound. This applied to prisoners who had committed minor offences.

Mr. Koppe then turned back to Pheap’s statement and read an excerpt.[13] The witness said that he knew that Pheap was Chhaom Se’s ex-wife. As for her testimony about rebellious acts, he said that he thought that she might have known “much more” than him.  Mr. Koppe read another excerpt, in which she had said that soldiers tried to kill Phnom Penh with explosions and injuring a messenger.[14] Mr. Koppe wanted to know whether he had heard about attempts to kill Pol Pot. He replied that he had never heard about this while being at the headquarters. Mr. Koppe wanted to know whether he had ever heard about shootings at the Olympic Stadium. He answered that he never heard about any explosions while he was working in Phnom Penh.[15]

In March 1977, Se moved to live in Au Kanseng Security Center. Thus, the witness wondered how Se could know about what happened in Phnom Penh.[16] He said that Se had overall supervision, while the witness was “simply a member” and tasked with taking notes of the confessions. Thus, he did not know the exact number of prisoners as provided for by Se. He pointed out that the numbers were not much different.

 

Deaths

He could not recall the names of those people who died of dysentery or malaria. When Mr. Koppe wanted to know how he knew that these people died of malaria, he replied that malaria was a common disease. If the treatment was not proper, the person would die. Tin was in charge of the security at Au Kanseng Security Center, which is why he, according to the witness, knew more about the conditions of the prisoners. As he had mentioned before that he had contracted malaria, Mr. Koppe asked when this had happened. He answered that he had malaria when he arrived in Rattanakiri. The witness recounted that he received information that Rattanakiri was infected with malaria before he left Phnom Penh. Thus, he tried to obtain some medicine before he left to Rattanakiri, which he took with him. When a detainee got sick, they had some modern medicine provided by Battalion 806. He confirmed that prisoners received the same treatment as security guards. Many soldiers had malaria during 1976 and 1977 and had to be treated in the hospital in Banlung. A large number of soldiers died during that time.

Mr. Koppe wanted to know whether it was fair to say that a large number of prisoners dying of malaria had nothing to do with the conditions in the prison, but more with the fact that Rattanakiri was infected with malaria, which the witness confirmed. As for dysentery, he replied that the cause was the virus in the unboiled water. The most serious disease faced by the soldiers was malaria, the witness said.

 

 

Living conditions

Mr. Koppe moved on and asked about the escape of prisoners. The witness confirmed that a prisoner had escaped and was brought back by the villagers.

The vegetables that the prisoners picked, they were to be used in the kitchen. The rice was given to them from the division. They also had MSG and fermented fish, vegetables and potatoes. The rice given to them was not sufficient, so they had to mix the potatoes with rice. They sometimes had a surplus of vegetables that they delivered to the division or to soldiers on the battlefield. Mr. Koppe asked whether it was fair to say that both prisoners and guards had enough to eat, at which point Mr. de Wilde interjected and said that the foundation for this question had not been given. Mr. Koppe reformulated and asked whether the prisoners and guards have enough food or not. The witness replied that prisoners and guards had almost the same food. “Guards never protected for the lack of food”. He confirmed that prisoners had sufficient food to eat, except those who were seriously ill, since they could not eat properly.

Mr. Koppe referred to the story of a gallbladder hanging in the kitchen of the center that two witnesses had testified about. He answered that he had not heard about this. Mr. Koppe said that presumably Nhok had hung up a human gallbladder in the kitchen. The witness reiterated that he had not heard about this.

Moving to the next topic, Mr. Koppe asked whether prisoners were ever used to guard areas and as such replacing security guards in their function. He replied that they could assist during night shifts. Tin, Thun and Set guarded at night time.

 

Jarai

Turning to his last subject, Mr. Koppe asked about the fate of the Jarai group. Mr. Koppe referred to yesterday’s testimony, in which he had said that he “assumed that perhaps the ethnic Jarai had been killed at that location”. The witness said that he had told the truth yesterday. Mr. Koppe asked whether he had been actively involved in the killing of the Jarai. At this point, the duty counsel intervened and said that his client could not respond, since it could lead to incrimination of his client. The President instructed the duty counsel to consult with his client, since it was not in his authority to decide the matter. The witness replied that he had never been involved in any acts of killings. Neither had he personally witnessed the killing. Mr. Koppe asked whether he had given any order to physically kill anyone. Mr. de Wilde said that this was a repetitive question. The witness had said yesterday already that they had a meeting with Saroeun who had ordered to “solve the issue”, which they understood as an order to kill, an order that was passed on. Mr. Koppe said that there was a difference between implementing the order and receiving an order. He repeated the question. The President informed the witness that it might be an incriminating answer and informed him about the right not to answer. The witness chose not to answer.

Mr. Koppe read out a few excerpts of Chhaom Se’s Written Record of Interview.[17] Se had said that the Jarai people came from Vietnam and were taken to be killed in Banlung. In his testimony, Se had said that the Saroeun bore the sole responsibility for the killing of the Jarai.[18] The witness said that the task was carried out by Tim, the deputy of Chhaom Se. When Mr. Koppe asked whether he said that Chhaom Se was shifting the responsibility to other soldiers, he said that he could only say what he knew. Mr. Koppe pressed on the matter and wanted to know who killed the Jarai. The witness replied that he did not implicate anyone “and I do not shift my responsibility to anyone”. They had to perform their duties based on the assignments they received. At this point, the President adjourned the hearing for a break.

 

Personalities

After the break, Mr. Koppe said that he had finished his line of questioning and the floor was handed over to the Khieu Samphan Defense Team.

Khieu Samphan Defense Counsel Anta Guissé asked whether the letter he delivered concerned civilians or only soldiers. He answered that it concerned both soldiers and people who were sent from the union. Ms. Guissé said that he had indicated that there were two kinds of soldiers: those who were shackled and those who were brought to the Security Center for lighter offences. The witness confirmed this information. Turning to the topic of guards, she asked whether there were people who came from the ethnic minorities amongst these guards. He replied that one guard was member of an ethnic minority. This person was called Chang, but he did not know which minority he belonged to. She pointed to the recording of his interview in 2009, in which he had said that he had spoken about two guards who were Cham.[19] He replied that he could not recall this. The witness said that Chang worked in Unit 806 “for a long time”. He could not provide further details.

She then wanted to know whether he could remember one of Saroun’s deputies called Ta Lou, which the witness confirmed. He was from an ethnic minority, but he did not know which one. She referred to Chhaom Se’s and his wife’s interview who had mentioned Ta Lou.[20] He did not dare to ask Ta Lou about his background.

The witness disputed having had responsibility for guards and being able to punish them for offences. She referred to his interview: he had said that Ta Auy had committed moral offence and was transferred.[21] He replied that the decision to transfer Ta Auy came from Battalion 806. She asked whether she understood him correctly that Ta Moeun and Ta Kuoy took him away, which the witness affirmed.

Next, Ms. Guissé wanted to know whether he had worked with Ung Ren. He recounted that he worked with him during the battle in Phnom Penh. Later on, Ung Ren became the regiment commander. Initially, he was in charge of Regiment 82 before being transferred to Division 101. After this, Ung Ren was transferred to work in the headquarters in Phnom Penh.

Ms. Guissé wanted to know whether he remembered that prisoners were liberated after an intervention. He answered that he did not remember that prisoners with light offenses were released, but said that he might have forgotten. This prompted Ms. Guissé to refer to Ung Ren’s testimony.[22] Ung Ren had said that prisoners in the Northeast Zone who had been accused of light offences were released later. He said that he could not remember anyone being released.

Ms. Guissé then referred to the person No who came from Phnom Penh. She wanted to know whether he was a soldier. The witness said that No said that he used to be a soldier. No arrived during the rainy season and returned after around three months of having worked at the Au Kanseng Security Center late that year.

He learned about the name Tuol Sleng later on, but the location had been mentioned earlier and described as being a school. The witness had No asked about the location. He had only said that he was in Division 12 and that his superior was called Nhab.[23] Sambath was in charge of the radio system from the time onwards that Saroeun was in charge of Division 11. Soeun was the wife of Sambath. The witness left Division 801 in 1977. To his recollection, Soeun and Sambath worked in the headquarters of the division for the entire time of the regime.

Ms. Guissé wanted to know whether Chhaom Se held meetings with the prisoners in the Security Center. He answered that meetings would be held every ten days to educate prisoners at Au Kanseng. They discussed the loyalty to the Party.

Ms. Guissé referred to the Written Record of Interview of Chhaom Se, who had said that he held meetings every two weeks with the prisoners.[24] The witness attended the meetings sometimes, but not always.

Ms. Guissé then gave the floor to her national colleague Kong Sam Onn. Mr. Sam Onn asked what the division was called after the fusion with another one. He replied that it was called Division 11.

Brother Sang was the leader of the meeting. The deputy informed them that they would have to be transferred to Rattanakiri Province. At that time, they did not mention the clashes between Cambodia and Vietnam. The selection was made by the general staff or commander in chief.

He was based at the divisional headquarter when he was asked to go with Man and another person to bring a letter to Phnom Penh. He did not bring the letter from Veun Sai. He never attended any training sessions in Phnom Penh, but only in Veun Sai. The cadre Sa communicated with other units. With this, Mr. Sam Onn finished his line of questioning.

The President asked whether submissions could be heard now in relation to a request by the Nuon Chea Defense Team to call an additional witness. Mr. de Wilde replied that the e-mail stated that the submissions and responses would be heard tomorrow. This was backed by Ms. Guissé. The President thanked the witness and announced that he could return to a desired place. The President adjourned the hearing. It will resume tomorrow at 9 am with the submissions and responses to hear an additional witness and then continue with the testimony of Ysa Osman.

 

[1] E3/9734, at 01079525 (EN), 00932020 (KH).

[2] ibid., at 01079520 (EN), 00932017( KH).

[3] E3/7960, at 0045905 (EN), 0073898-99 (FR), 00851665-66 (KH).

[4] E3/221, at 00000813 (KH), 00386178 (FR), 00182696 (EN).

[5] E3/7883.

[6] E319/23.4.1, at 01079524-25 (EN), 00932020 (KH).

[7] 01079526 (EN).

[8] E319/23.4.1, at 01079546 (EN).

[9] E3/5173, at 00272661 (EN), 00272667 (FR), 00189266 (KH).

[10] E3/13, at 00940354 (EN), 00052414 (KH), 00334983 (FR).

[11] 00063146 (KH), 00492822 (FR), 00486325 (EN).

[12] E3/407, at answer 6.

[13] E319/23.4.1, at 01079524 (EN), 00932019 (KH).

[14] Ibid., at 01079526 (EN), 00932021 (KH).

[15] Ibid., at 01079527 (EN), 00932022 (KH).

[16] E3/405, at answer 8.

[17] E3/9459, at answers 24, 26, and 27.

[18] E1/77.1, at 9:53.

[19] D232/51R, at 1:27:36-1:28:24.

[20] E319/23.4.1, at 00931998 (KH), 01079493 (EN), no French translation available.

[21] E3/406, at answer 4.

[22] E1/15.81, at 15:41-15:46

[23] E3/406, at answer 3.

[24] E3/3984, at answer 6.