Defense Questions Relevance of Witness and Civil Party
Today, Witness 2-TCW-913 and Civil Party 2-TCCP-235 gave their testimony in relation to the role of the accused. Both remained anonymous due to ongoing investigations and were only referred to by their pseudonym. 2-TCW-913 recounted how he was forced to defrock in 1975 and later sent to work as a cook at Borei Keila in Phnom Penh, where he was instructed to taste food to protect guests of poisoning. He also told the court how he escaped death when the members of his unit were executed. Civil Party 2-TCCP-235 provided his knowledge regarding senior cadres, including Nuon Chea, Ta Mok and Sou Met.
Leaving the Monkhood
With a ten minute delay, the hearing commenced. Civil Party Sar Sarin had health problems and could not attend the hearing. There was a reserve witness 2-TCW-913. National Judge You Ottara was absent and replaced by Judge Tou Mony. Khieu Samphan Defense Counsel Anta Guissé was absent without having indicated a reason. Due to ongoing investigations, the witness was not referred to by name. Two documents were admitted.
Khieu Samphan Defense Counsel said that his national colleague had announced her absence on November 8.
The floor was granted to the Co-Prosecution. International Co-Prosecutor Nicholas Koumjian inquired which zone his family was from. He replied that they were from the east. He was a monk for three years. He left monkhood in 1975. He was still a monk on 17 April. He was in Ta Suor pagoda in Svay Rieng Province. There were 19 monks in this pagoda. “I was forced to defrock.” They were forcibly disrobed, he said. “They wanted to abolish the religion. All monks had to disrobe.” He was told two or three times to disrobe. “I was told to disrobe as quickly as possible, since they did not want monks in the pagoda, so we had to disrobe in order not to be mistreated.” This happened in April 1975.
Borei Keila
He was then transferred to a cooperative where he had to transplant rice in his birth cooperative. He was there for two or three months before he was further transferred to work in a factory in Phnom Penh. When he arrived in Phnom Penh, he was assigned to raise pigs and ducks at Borei Keila or Batuk School in the city. Upon his arrival he was assigned to raise pigs and ducks and cook rice to welcome guests.
Mr. Koumjian inquired whether he underwent any training before he went to Borei Keila, which he denied. The building at Borei Keila was used for training sessions. The structure was an open structure. There were chairs and tables there. He himself was never trained. Ta Chamran was his supervisor. He worked there for three months before being sent to Steung Cooperative.
Mr. Koumjian wanted to know who was in overall charge of K-5 when he was there. The witness answered that he did not know. He heard of the person Phan, but never met that person or saw his face. “I did not know how he looked like.” Mr. Koumjian inquired whether he had heard of Phoum, which he also confirmed. He also drew sugar cane at Borei Keila. He did not know how many people worked there. He only heard the name K-5 and heard no other names.
Mr. Koujian asked whether he ever heard of the Monkey Forces. He replied that they were told that they were called Monkey Forces by others. “We were newcomers. We were not familiar with locations. […] We were referred to as the monkeys.”
He served guests twice a month, who came from all over the country. The sessions lasted between three days and a week. He did not know who conducted the trainings. He knew that Ta Chamran was there, but did not know “who did this and who did that.” He did not witness any senior leaders at Borei Keila, but he heard that they came for study sessions. “I simply cooked.” He was not allowed to enter the training compound. There were several groups of people, and another group was in charge of delivering food and serving it to the guests. Mr. Koumjian pressed on the issue of the presence of senior cadres. He denied having seen Pol Pot, Khieu Samphan or others. He had heard of them. “I am telling you the truth, I am not breaking my promise; that is the oath.” Neither did he see Nuon Chea there. “The training school was far,” he said. Thus, he “did not see any of the senior leaders.”
He tested the food before giving it to the person who would bring it to the guests. He was told to do so by Chamran. “If it was poisoned, it would mean that I would die first. It would be for me to die and not the guests.” He tasted rice, food and water. He did not know who the food tester would be once he was reassigned. “I was never poisoned or fell ill. It was a precaution.” He said that they had to taste everything, since they would be blamed if guests died. He did not know the level of their position. He was not aware of the content of the study sessions. He heard that Khieu Samphan was the instructor. He heard people talk about Khieu Samphan only and no one else. After three months, the witness was reassigned.
He estimated that there could be hundreds of participants, but he was not certain. He could see the training room only from around three hundred meters away. He did not know the total number of participants in the training sessions. He never entered the training room and could therefore not estimate the size. He did not know whether it had been dismantled or not. He did not know the level of seniority of the people.
The witness himself did not attend any training sessions and therefore did not know the content. “I was a very low ranking person”.
Mr. Koumjian presented a document to the witness.[1] The witness said that this document was his biography that he was asked to write when he arrived in Phnom Penh.
At this point, the President adjourned the hearing for a break.
Training Sessions
Mr. Koumjian inquired how many times he had to complete a biography when he was at Borei Keila. He replied that he made it only once. Mr. Koumjian said that on the top right it indicated that he was in Unit S-71 and wanted to know what this was. He replied that he was told to write this code. Mr. Koumjian inquired whether he had filled in this form in 1976. The witness answered that he came to Phnom Penh after he disrobed, which would have been in early 1976, he said. He was asked whether he knew S-200 School. He said he had heard of it, but he did not remember. Mr. Koumjian inquired whether he recalled Pan Sochea from Documentation Center of Cambodia coming to his village and speaking to him. He answered that he could not recall this. He never read it when speaking to the investigators of the court. To refresh his memory, Mr. Koumjian read an excerpt of his interview, in which he had mentioned the S-200 School, where he studied for around two months.[2] He replied that he was sent to work in a cooperative before he was defrocked and then sent to a factory as well as Ampil Pagoda. He was told to spend two nights there, but this was not a training session. They later arrived at Svay Rieng. There was a meeting held at Wat Tonlé, but this was not a big training session, he said. “I did not engage in any significant training sessions.” They moved from place to place.
Mr. Koumjian wanted to know what other people there were. They were not allowed to move freely. “We received a training session, but we were not given materials.” He said that there were no “significant training sessions.” They stayed at one pagoda, but there were no monks anymore. He was the only one who was a former monk. “I was a really newcomer.”
He stayed at Borei Keila for a few months, before being sent to another cooperative where he had to plow the field. He was warned not to break the items.
Mr. Koumjian asked whether he was transferred to Trapeang Tralong in Kampong Speu, which the witness confirmed. Those who were in the east were considered enemies, he said. Those who were from Svay Rieng and another location were “called to be tempered.” They were told that they were with a Vietnamese head and a Khmer body. “I was called to [be] refashioned.” He was at Steung Cooperative and asked to take care of weak water buffalos and plow the field. “I had to be very careful [and] owing to my carefulness I was transferred to another location.”
When Mr. Koumjian inquired about executions at Steung Cooperative, Nuon Chea Defense Counsel Victor Koppe objected and said that this was outside the scope of the trial. He referred to decisions by the chamber and said that the witness did not belong to one of the targeted groups.[3] Moreover, it did not fall into the scope of the security centers. Mr. Koumjian replied that it was in the scope of the trial, as it related to the targeting of East Zone soldiers. Mr. Koppe replied that if this was to be allowed, it would be a “direct violation of your own order.” The president announced that questions should be inside the scope of the trial and that he had run out of time.
Mr. Koumjian inquired about people who attended the sessions. He replied that they came from several district and that they did not know each other.
Killings of People from the East Zone
Mr. Koumjian inquired whether he was ever sent to Kampong Som area. The president interjected and said that questions had to be inside the severance order of the proceedings. He replied that he was sent to an area in Kampong Som area called Steung Hao. All of the workers came from the East Zone “to engage in hard labor.” Mr. Koumjian wanted to know whether anything occurred to him there. He replied that they were not given sufficient food and overworked. Some looked for food in the forest because of their hunger. They were accused of not working, but they joined their hands to arrest Hoeun, who was in charge of the area, and sent him to the military barracks. They told the soldiers that they were not given sufficient food. Hoeun was taken to another barrack and the next day, the fifty workers were called to a meeting to “resolve the matter”, as they had arrested their chief. They went there at noon time wearing their blue krama. “For some reason, the situation became chaotic, and that we should not flee, we were told, and they decided that Hoeun was correct.” He continued “they started to tie us all.” Mr. Koppe objected and said that it was outside the scope of the trial. Moreover, the questions did not relate to the role of the accused. “I have no idea why this witness is testifying to the role of the accused.” Mr. Koumjian replied that all relevant evidence was admitted, even if it did not related to the segment they were testifying in. The president inquired which segment exactly it related to and which decision Mr. Koppe had referred to. Mr. Koumjian replied that it related to the purging of East Zone cadres. Mr. Koppe replied that the annex of the decision previously mentioned set out that purges of East Zone cadres only included Steung Tok execution site and movement of population phase 3. The Co-Prosecutor replied that a requirement for a Joint Criminal Enterprise was to find common intent. Even if the crime site itself was not part of the crime sites included, it went directly to the charges of Joint Criminal Enterprise. It was therefore relevant to the policy to target all people from the East Zone. Mr. Koppe replied that factual evidence related to the purging could only be included “upon reasoned application” in order to expand the scope of the trial. Mr. Koppe replied that it was a “legally totally untenable argument” to merely say that it was part of the Joint Criminal Enterprise and that the situation was “clear.” Mr. Koumjian rebutted by saying that it was “clearly relevant to the issue.” The bench discussed the matter for a few minutes. The floor was then handed to Judge Jean-Marc Lavergne to issue a decision.
Judge Lavergne said that the crime site was not within the scope of the trial and that there was therefore “no need” to inquire about details. However, the Chamber had previously allowed questions related to national policies. The Co-Prosecutor was allowed to ask “two or three questions”, but that he should not go into details.
Mr. Koumjian asked who gave them the blue scarves. The witness replied that Hoeun gave them the blue scarves and that the soldiers later used these scarves to tie them up. Mr. Koumjian asked him to briefly explain what happened to him after they were tied up. The witness answered that after being arrested, they gave them only “one or two pieces of potatoes” per meal. This lasted for around 14 days. “They tortured us, they beat us up”. On the night of the 7 January, “they said that the issue could not be resolved” and that the Party in Phnom Penh would resolve the matter. They were tied up on another layer. They were taken away in a group of ten each. “We found out that those who were taken away were killed at the mountain. They also killed us. I was hit by a few clubs on my head, but somehow I survived. And then, amongst the dead, I saw Khan, who also survived. So we tried to erect ourselves although we were tied and then he untied me and I untied him. Then we used the mud to put it on our wound and I had to drink my own urine in order to survive. Then we went to look for our clothes at our worksite”, but everyone had fled. “So I cooked rice there.” He stayed there for “over one month” in a cave at this location. Mr. Koumjian then gave the floor to the Civil Party lawyers.
Follow-Up Questions by the Civil Party Lawyers
Civil Party Lawyer Hong Kim Suon asked about his statement that he did not know about DC-Cam having interviewed him in 2005. The witness could remember that there was a group of people who interviewed him at his place. “They took my photograph as well.” Two people interviewed him. He had read the interview before arriving in court today. Mr. Kim Suon asked whether he spoke about his experience of seeing Khieu Samphan and Nuon Chea in that interview. He replied that he was not asked whether he saw any of them during that interview. Mr. Kim Suon asked whether he recalled the content of the interview. The witness answered that his memory did not serve him well “because I was struck in my head.”
To refresh the witness’s memory, Mr. Kim Suon referred to his interview.[4] He replied that Khieu Samphan came to teach on one day, but when they asked later, he had said that Pol Pot came to teach. However, he had never seen any of them. Nuon Chea was not mentioned, but “they mentioned frequently about Khieu Samphan. Pol Pot rarely came. Khieu Samphan usually came for every training session.” However, he was “told those answers” when he was asked the questions. He did not see any of them even from afar. Mr. Kim Suon said that he had described the physical appearance of both Khieu Samphan and Nuon Chea. Mr. Kim Suon asked whether these were his answers. He replied that “this is what I was told” and that he “repeated what I was told.” He had said that Khieu Samphan came to give training sessions. With this, Mr. Kim Suon concluded his line of questioning.
The president informed the parties that 2-TCCP-235 would be heard after the conclusion of this witness’s testimony. Sar Sarin could not be contacted via his phone number and had left his hotel. “It seems like he cannot come to testify tomorrow.”
Questions by the Bench
Judge Lavergne asked whether his brother worked at K-5 as well, which the witness denied. Judge Lavergne said that his biography stated that Nhong and Nhet were tasked to work at K-5 as well.[5] He replied that he did not work there. He was the eldest sibling in his family. Judge Lavergne asked why he had to defrock and what the exact situation was. He replied that they forced him to disrobe. “They said that the regime required no monks.” There was no traditional ceremony when they were disrobed. “How could I stay in the monkhood since all monks had been disrobed? They wanted to destroy all evidence and they wanted to abolish the religion at the time.” They had all been disrobed at the same day.
Ta Yar was part of the committee of Tros. Another individual was part of the committee of Sang. They were the ones who were responsible for the defrocking. They had guns to defrock individuals. The two individuals used to be “the supreme monks” but later “mistreated monks.” After they had been defrocked, they were sent to different location. Some went to their home villages.
With this, Judge Lavergne concluded his line of questioning. The floor was handed to the Nuon Chea Defense Team, but Mr. Koppe stated that they did not have any questions, as they did not know why this witness was called in this segment.[6]
Working as a Cook
Khieu Samphan Defense Counsel Kong Sam Onn asked him about his biography and asked whether he had lied in his biography. He replied “if I had not lied to them, I would have died.” He had to cook dishes for the number of guests who came for the training. He first raised chickens and ducks at Borei Keila, where he was also a cook. “I had to divide my time” raising life stocks besides being a cook.
Of his unit chiefs he could only recall Morn. He would transport items. He did not know Ta Chamran’s superior’s name. “He had overall supervision at Borei Keila,” the witness said. As for the food he “was required to taste them” before the meal was served to the guests. Before the dishes were served, he had to taste them, he repeated.
Judge Claudia Fenz asked that she did not understand where the questioning was leading. Mr. Sam Onn said that there was “no information” relating to the poisoning of the food, but only to taste whether it was poisoned. Mr. Sam Onn inquired how long after he had tasted the food they delivered the dishes. He replied that they would take the meal after he had tasted it. They served cabbage and morning glory soup, mixed with pork or fish. He did not know where the meat was taken form. Mr. Sam Onn inquired whether he was afraid when he tasted it. “Every time I tasted the food, I trembled. I was thinking that perhaps they wanted to kill me.” He was afraid, because “if someone wanted to mistreat me, to kill me, to smash me.” He was “continuously afraid” that they wanted to kill him.
Mr. Sam Onn asked whether he ate the leftovers of the guests or whether there was a specific meal for him. He replied that the rice in the cooking pot was not finished by the guests, which he would then eat. He would not eat the leftovers themselves, as they would be fed to the pigs. Mr. Sam Onn asked whether he stood by his statement that working conditions and food were normal at Borei Kala.[7] He replied that he did “not support it.” He then said he stood by his previous statement. With this, Mr. Sam Onn concluded his line of questioning and the testimony of the witness came to an end. The president thanked and dismissed him.
New Civil Party: 2-TCCP-235
He then announced that 2-TCCP-235 would be heard next. The president informed the public that the Chamber would proceed to hear the Civil Party in relation to the role of the accused. The Civil Party would only be referred to by his pseudonym due to ongoing investigations. The Civil Party confirmed his identity as provided in a document.
Civil Party lawyer Ven Pov asked where he lived in 1975 and what he was doing. He replied that he ordained as a monk at Chrak Pagoda in Ou Rumchek District in Kampot Province. In 1971, the militia group “of the Revolutionary Angkar” forced them to disrobe and forced them to work. He was disrobed when he was 15. He was sent to be located between National Road 4 and a battlefield. He was in Division 1 in Regiment 16, Battalion 180. Division 1 was newly established at the time.
Angkar provided them with training in order to attack and seize Phnom Penh. He was chief of a special group for intelligence gathering attacked to Battalion 180. On the day of the capture of Phnom Penh, he reached Pochentong at around 6 am. The Lon Nol Armed Forces “as well as female soldiers prepared some flowers in order to greet us.” Between 9 am and 10 am, Ta Mok and Sou Met arrived. They issued “various orders”. He was looking for his relatives at the time so that they could leave the area. When they entered Pochentong, they saw women who had flowers in order to greet them and celebrate the victory. Some people within the army were “mean”, he said. “Some beat up those women and grabbed the flowers and threw them away. As for me, it was very difficult to say anything, because at that time, Lon Nol soldiers had wine and food for us soldiers to drink and those Lon Nol military pilots were ordered to gather in one place in order to greet Angkar.”
When Ta Mok, Ta Met, and Ta Muth arrived, they organized GMC vehicle for them to meet Angkar. He told some of the men and women not to go and that they should not believe them as they would be killed. Some believed him and did not go, while others boarded the vehicle and drove westwards. He had an elder brother who was a helicopter pilot. The Civil Party tried to look for him and found a few friends of his. “I told his friends to take off their uniforms and if they were asked questions, they should say that they only worked there.” He told them that he could take them out of the airport for them to return to their native villages. He told them that if they were asked they should say that they were ordinary workers.
Kampong Som
He then said that he was sent to Kampong Som with a GMC truck. This was around April 30. One battalion of 400 to 500 soldiers were sent there. When Battalion 180 was “demobilized” by Angkar. Some soldiers, including himself, were sent to the navy, while others were sent elsewhere. They were part of the navy and in a “big ship”. They tried to seize those who tried to fish in their waters, including Thai military and Thai fishermen. He stayed there for four to five months. He was requested to stay at Koh Sdach Island. He arrived with a messenger. “Then they pointed a gun at us. I fought back. [I] actually caught the gun, but I fell in my attempt, because there were many of them. Then they caught me. Then they handcuffed me and my messenger was chased away.” He said that “the other nine were also under the arrest. They were put on a big ship with electrical equipment to shock us. We were accused of being infiltrated enemies. I was the last one to receive electrical shocks […] but I protested the accusation.” Three of them were released, while the others were put in the bottom of the boat. Others were sent to Koh Kong for hard labor. Others were forced to build roads and bridges. Ron, the secretary of the sector, who had a protection unit guarding them. They were not given sufficient food and some of them were removed from time to time. “First, there were around 40 of us, and later on, only a little bit more than ten of us remained.” He stayed at Koh Kong for around 12 or 13 months. There was another person who deceased by now by the name of Chantha. Some of his close friends were afraid after some of them had been sent away. In mid-1977, a messenger from the sector called out his name. At the time, he did not use his real name but used an alias. He was sent by a motorboat from the inner sea to Trapeang Rung and was walked by the guards. “I was thinking that I would die. In fact, there were two of us. […] We were talked to Andung Dik.” They were told to rest there. He took a rest close to a temple where people were shackled. The messenger of the sector came to see him and brought food to him. At 7 or 8 am, there was an announcement that “Parties invite all of you to […] boat a big ship.” This ship could house around 100 or 200 passengers and there were two big ships. He was told to board this ship. The ship went to Sre Ampil where there were GMC trucks. At around 8 or 9, there was another announcement over the loudspeakers. They were told to board a train.
At this point, Nuon Chea Defense Counsel Victor Koppe said he needed clarification by the chamber. “Not one question has been about the role of the accused.” He asked whether this segment was “some leftover category” and what the purpose was of this witness for this segment. Mr. Sam Onn supported the objection. “They’re not really relevant,” he said. Mr. Pov responded that they were approaching “close to the relevant questions in relation to the role of the accused. Please be patient.” Judge Nonn said that they were indeed “far from the facts” and that they had scheduled witnesses and Civil Parties particularly in relation to the role of the accused. Other facts were supplementary. International Senior Assistant Prosecutor Vincent de Wilde responded that the Civil Party testimony provided context and was relevant in relation to the role of the accused and Kraing Ta Chan.
Mr. Pov asked about “an incident” when he was transported. He recounted that he arrived in Phnom Penh at around 10 pm together with around 1,000 other people. They were sent to Borei Keila. They spent around half night at this location before a film was shown to them about the fighting between China and Japan. On the third day, they were told to “go and have rice” before being lined up. During the time that they were lined up, there were Ta Mok, Son Sen and Nuon Chea. Nuon Chea stayed close to Ta Mok since the beginning, he said. He knew that this was Nuon Chea, because the Civil Party got injured in 1973 and sent to Kraing Loveal Forest Hospital, located between Oral and Amleang. There, he saw Ta Mok and Nuon Chea who came to visit the injured people. The messengers told him that this was Brother Number 2, who was the deputy of state. The messenger said that this was Chea.
Senior Cadres
Son Sen, Ta Mok and Nuon Chea were three leaders, he said. Nuon Chea was in charge of the military. “He spoke and gave encouragement to almost 1,000 soldiers, including me.” He could recall some of the speech, but not all. He convened them to say that “you have engaged in the war against the American Imperialists and its puppets. You have fought for the victory of 17 April 1975 for our revolutionary party. This is well-known across the globe. But as of now, contemptible yuon enemies do not abandon their ambition to annex Cambodia into Indochina. They bring a number of division in and they sent spy-agents into our Democratic Kampuchea and into our army. It is our very courageous soldiers who have fought against those spy-agents. Our party believes in all of you, comrades. We absolutely prevent the yuon enemies to invade our country.”
After Nuon Chea made this speech of encouragement, Ta Mok and others organized them to be sent in two groups. One group was sent to Nhek Loeun. His group had to fetch a ferry and cross Tonlé Bat. There were also Chinese made vehicles and tanks on the ferry crossing Tonlé Bat. With this, Mr. Pov concluded his line of questioning.
Disrobed
Mr. de Wilde asked about the moment that he was disrobed. He recounted that they were told that they would not have any food if they did not disrobe. The commander of Division 1 was the first Sou Met. Ta Soeung and Ta Sary were the second-in-command and in charge of other affairs respectively. Bunteng was the commander of Division 180 and had received training in Hanoi. He was arrested upon their initial arrival, he said. The three divisions were under Ta Mok’s overall charge and Nuon Chea was his partner. “They were close to each other”, he said. He insisted on this point: “I’m very sure about Ta Mok. It was Choeun, alias Ta Mok.” His older brother Dan was a military pilot for helicopters. During the battle, “they had to take action.” When he was at Pochentong, he knew “for certain” that his older brother was located at Pochentong. He learned this information through radio-communication. Thus, he went to looks for him. Then, he went along with the others. He escorted them out. Through instructions, he learned from Angkar that “any pilot had to be executed upon our entry.”
A person who came from the same village as him did not believe him and said that he wanted to meet Angkar. He asked the children about the fate of their father, “and they said their father died.” His two elder brothers were also working in the Lon Nol period, he said.
Mr. de Wilde asked whether he had to hide the fact that he had members of his family who had worked as Lon Nol servicemen. He replied that he did not use his birth name and did not indicate his actual birth village. They were trained how to “distinguish classes.” Mr. de Wilde asked whether Ta Mok said anything regarding the fate of the soldiers who were sent away in the GMC trucks. He replied that “Ta Mok said nothing.”
He arrived in Borei Keila in June, July or August.[8] Mr. de Wilde asked whether he was told where they were going when he left Koh Kong, which the witness denied. They were invited to an office in which Ta Phin was in charge of.
He was initially afraid that he would be imprisoned in a new location. After he reached Veal Rin, it appeared that he would not be imprisoned, he said. They were all brought to Borei Keila, where they stayed in a three-story building. Some worked in a mobile unit, some were from the district, and some others were from the sector. He said it appeared that there were no children or women there. There was a documentary shown to them about the fighting between China and Japan.
Mr. de Wilde said that he had mentioned Khieu Samphan as well.[9] HE replied that he never saw him. He replied that he had heard his speeches over a radio broadcast in 1975 or 1976. Khieu Samphan mentioned the rice supplies and that one individual would receive one or two cans of rice.
At this time, he had already become a member of the youth league, “as I was a progressive person.” Mr. de Wilde said that he had characterized Nuon Chea as “the person in charge” of the army. He replied that someone had told him that Nuon Chea was the deputy secretary of the party and that he had to take care of the military and economics.
Mr. Koppe interjected and said that “it might speed up things” if they took into account that the defense team had conceded that Nuon Chea was the deputy secretary of the party, played a role in “formulating the key policies” and spoke at Borei Keila. Mr. de Wilde said that the questions related to his role in the military. The witness replied that they had told him when he was at the hospital.
At this point, the president adjourned the hearing. It will continue tomorrow morning at 9 am, when the testimony of 2-TCCP-235 will continue.
[1] È319/23.3.3A.1.
[2] E3/9086, at 00977447 (KH), 00983502 (EN).
[3] E301 and E315.
[4] E305/13.23.377; E3/9086, at 00977451 (KH), 00983507 (EN).
[5] E319/23.3.38.1, at 00983490 (EN), 00977436 (KH).
[6] E319/23.3.38.1, at 00983485 (KH).
[7] E319/23/3.39.
[8] E319.23.3.2.
[9] E3/5979a, at 01190877-78 (FR), 00865685 (EN), 00578510 (KH).
Featured Image: Witness 2-TCW-913 (ECCC: Flickr).