Strictly Confidential- NSENGIYUMVA CASE: a HIGH LEVEL CONSPIRACY; FABRICATION of TESTIMONIES AGAINST ME -Strictly Confidential

Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME -Strictly confidential-

NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTlMONIES AGAINST ME.

1. After having examined the accusations against Anatole NSENGIWMVA, after having studied different Prosecution statements, I arrived to a conclusion that it has been a well hatched plot against me, and that the majority of the Prosecution witnesses have been trained for that. and statements fabricated.

2. I have realised that some people or associations have participated in that conspiracy against me. The most important are: Hassan NGEZE; RPF; opposition political parties in place in 199 1-1 994 in Rwanda; AVEGA; IBUKA, and others.

3. In the following lines, I want to explain what I know, or what I think about every member of the conspiracy against me. 1 will say why I think that they are part to the plot, I will name the Prosecution witnesses fabricated by every member of the plot, and I will try to indicate the evidence.

4. I don't mean that all these forces acted together. I simply mean that every one has a share of responsibility, in conspiring against Anatole NSENGIYUMVA. I will hereunder try to demonstrate this.

Hassan NGEZE

5. Mr Hassan NGEZE has trained a lot of witnesses to charge me, so that he could avoid some charges which were against him. He trained both Defense witnesses and Prosecution witnesses. But unfortunately for him, his manoeuvres have been discovered, and many of his witnesses have been found not credible. NGEZE himself has been qualified as a liar, who doesn't know what the truth meant.

6. It is important to say how I have known Mr Hassan NGEZE, and why he decided to harrass me, and to accuse me. Why did he target me and some of my officers, when all his allegations were completely false ? Why did he target me, more than other persons ? I will explain all this, and I will say how he proceeded.

How have I known Hassan NGEZE, and my relations with him.

7. Before the October 1990 invasion of RWANDA by the RPF, I was in Kigali, in post in the Army General Staff, and in charge of the military intelligence. I would see reports from Gisenyi, talking about one troublemaker, whose name was a certain Hassan NGEZE. I had never seen him. The reports indicated that this Hassan NGEZE was manipulated by a rich businessman, whose name was Valens KAJEGUHAKWA. Strictly confidential- NSENGIYUMVA CASE: A HlGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

8. Hassan NGEZE would write inflammatory articles in a newspaper created by Mr KAJEGUHAKWA, and NGEZE would sign articles prepared by Mr Valens KAJEGUHAKWA. Besides, Hassan NGEZE was presented as somebody who was involved in many shady activities, and who would create troubles in the city of Gisenyi. For all these reasons, he would be many times arrested. I had not seen him until 1990.

9. The first time I met Hassan NGEZE was towards mid-1990. Mr KAJEGUHAKWA, who wanted to join the RPF before the invasion of October 01, 1990, found a pretext, by saying that he had been attacked by soldiers, who wanted to kill him. He publicised that allegation, through his journal KANGUKA (not KANGURA), in which Hassan NGEZE would write inflammatory articles, together with a certain Vincent RWABUKWISI. But this time, to spread news about that alleged incident, NGEZE would have been ignored by his boss KAJEGUHAKWA, who prefered to refer to RWABUKWISI Vincent, who did not live in Gisenyi. NGEZE was angry.

10. As it was alleged that soldiers had attempted to attack KAJEGUHAKWA, the Chief of Staff sent me to Gisenyt, together with lieutenant-colonel RWABARINDA, who was in charge of the G3 in the General Staff. We had to investigate that problem.

11. In Gisenyi, we contacted the local Commander of the army, lieutenant-colonel BAHUFITE. He told us that a person who might tell us what happened was that NGEZE, who was very close to KAJEGUHAKWA, but who, for the moment, was not in very good terms with his boss.

12. We looked for NGEZE, and eventually met him at TAM-TAM bar, near Kivu Lake. This is the first time I saw that man. He told us many stories about KAJEGUHAKWA, and told us that his boss wanted to join the RPF, and had decided to find a pretext to leave the country. It was around May-June 1990. In September 1990, KAJEGUHAKWA left the country and joined the RF'F in UGANDA, and the attack came on 010ctober 1990.

13. The second time I saw NGEZE was on May 3 1, 1991. The official and private press had gone to MUTARA zone, to see by itself how the Rwandan army was controlling the whole territory. There were about 28 journalists. At a given moment, NGEZE told the other journalists that he had informed me about the date of the attack, but that I did nothing to prevent it. This was a lie. I told him that this was dishonest of him, as he was saying such a lie before so many joumalists. Eventualy, he alleged that he was kidding. Anyway, I was not happy with such a joke.

14. I met Hassan NGEZE for the third time in May 1994, in Gisenyi, during the period of the events. This is what I want to explain, and this will be the next topic.

Why does Hassan NGEZE target me so persistently ?

15. In April 1994, when President HABYARIMANA was assassinated, I was in Gisenyi, as Gisenyi Operations Sector Commander. During the first days that followed the assassination of the President, I have not seen Mr Hassan NGEZE. I have not seen him Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME on the 6th,on the 7Ih, on the 8Ih and on the 9Ih of April 1994, contrary to what he alleges. But on April 9, 1994, I heard a vehicle with a megaphone, and somebody who was saying that the population had to refrain from drinking water, because the Inyenzi had poisoned it. People said that it was NGEZE who was making that announcement. I remember that we have criticised that in the meeting of the Prefet, which has been held that very day. The population was told that the announcement was not serious, and that the person who did it had made a very bad joke.

16. The following days, almost every night around 2.00-3.00 a.m., we would hear many, many shots from the direction of NGEZE's residence in the city of Gisenyi, GACUBA I neighbourhood. At the beginning, we thought that the city of Gisenyi was attacked by the RPF. But eventually, we came to know that Hassan NGEZE had young men at his home, his body guards, and it is them who would shoot so intensely. The population was scared, and the situation was not tolerable.

17. The security council of the Prefecture of Gisenyi met, and discussed the question. It was decided that the Gendarmerie had to go and search NGEZE's house, and seize the weapons. The Gendarmerie tried to do so, but met a serious opposition of those young men, who would climb up the roof of NGEZE's house, and threaten the gendarmes with grenades and guns.

18. When this seemed to be very difficult for the gendarmerie, I proposed to the Council to let me do it with soldiers. I was given leave to act, and the local prosecutor gave me a search warrant. I organized the search. I gave that mission to my S2-S3 officer, Major Franqois-Xavier UWIMANA, who was in charge of operations. He prepared it, and proposed to me to send soldiers of the 42nd battalion, under the command of the battalion Commander, Captain HABIMANA Faustin. I OK'd the proposal and the operation took place.

19. The young men sensed danger quickly fled. NGEZE was not been found at his home. But when fleeing, the young men left EIGHT guns there, as well as a radio transmitterlreceiver, of the mark "KENWOOD, the same radio as those used by the RPF troops. The guns and the radio have been seized. But NGEZE has not been found. I have informed the General Staff of that incident, and asked it to help us to find NGEZE, so that I could interrogate him. I denounced that in a meeting of the Prefect, which was held on the Umuganda Stadium, on May 2, 1994.

20. At a given moment in May 1994, I heard NGEZE giving an interview on the radio. I advised the General Staff, and asked it again to help get NGEZE for interrogation. I was asked to transmit a message to all units to help me to get NGEZE. I did it. And some time after, around the 8Ih of May 1994, NGEZE was arrested in the city of GISENYI and brought into the military camp, to be questioned about the detention of eight guns and a radio transmitterlreceiver, like those in use in the RPF troops.

21. The interrogation was conducted by Major UWIMANA Franqois Xavier, S2-S3, with the collaboration of Lieutenant BIZUMUREMYI, as a former gendarmerie officer, and who was under the orders of Major UWIMANA, the S2-S3 officer. NGEZE spent one Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME night in detention. The next day, when he was being just interrogated, I received a telegram from the Ministry of Defense, with a copy for information to the General Staff, asking me to release NGEZE immediately and without any condition. I was obliged to execute that order, to my dismay.

22. NGEZE had not yet said how he got those weapons and that radio transmitterlfreceiver, with whom had he been in communication through that radio, etc ...

23. After that incident, NGEZE's residence has been attacked by unknown individuals. Nobody has been able to know what exactly happened, and NGEZE disappeared from Gisenyi. I had even believed that he had got other weapons, and that his men were still shooting. But meanwhile, he launched a campaign, saying that Anatole NSENGIWMVA was an accomplice of the enemy, because he was against Hutu people, who wanted to defend the population. This campaign has been spread throughout Gisenyi, but I kept calm. NGEZE has never forgotten that. And I didn't meet him in Rwanda any more.

NGEZE's activities against me during the exile

24. Once in exile, NGEZE resumed publishing his newspaper KANGURA. He attacked me a lot, as well as lieutenant BIZUMUREMYI, and captain HABIMANA. The issues of KANGURA would be distributed in the refugees camps in Zai're. I was not happy at all, especially when he was treating me as an accomplice of the RPF, or squarely a member of the Inkotanyi.

25. In 1995, I left the refugee camps and sought refuge in Cameroon, wherAwas arrested in March 1996. 1 was transfered to Arusha on January 23, 1997. NGEZE was arrested in July 1997 in Nairobi and brought to Arusha. When he arrived at the UNDF, we could not even talk. He would tell other detainees that I was his enemy number one, and that he would do anything to have me condemned to life imprisonment.

26. NGEZE would say that he had already talked with the Association "AFRICAN RIGHTS", and had given incriminating information against me. Until then, I didn't know what it was exactly. Later on, I saw the document he sent to AFRICAN RIGHTS, but it seems that there is another document, well elaborated, that I have never seen. In all those documents, NGEZE alleged that I tried to kill him, because he had been helping Tutsi, by hidding them andlor taking them to Zaire. I had never been aware of those actions by Hassan NGEZE.

27. At a given moment, when we were at the UNDF, just after his alleged attempt to commit suicide, NGEZE found us where we were praying. All the detainees were present, and all those who were already in custody at the UNDF know that fact. He found us and asked us to let him say something important. He revealed to us, that when he had been arrested and brought to Arusha, he was very happy, because he felt that he would be able to find a gun from the guards of the prison, and that he would kill Anatole NSENGIYUMVA. He was then apologizing, because of that evil plan he had Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME hatched, and that he found later to be ill-advised. He apologised to me, and 1 beliced that all had now become normal. But that was another trick from him, to have me accept to collaborate with him, with the view of helping him in his trial.

28. He then contacted me many times, asking me to testify in his favour, and tell the Court that he had been arrested by me during the night of the 6'h to the 71h of April 1994, and that he remained in detention, until April 09, 1994. He told me that this approach would help him, and that it would help me too, because those who allege that he had been with me during that period, distributing weapons or attending meetings, would be surprised by our arguments.

29. I refused to accede to his offer, as I didn't want to be involved in his lies before the Court. I didn't want to participate in his manoeuvres, because I had not arrested him at all, during the night of 61h to 7Ih of April 1994, and he had not been detained at the camp, until April 9, 1994. He was trying to tell lies to the Tribunal. I then refused to embark on that strategy.

30. NGEZE then started threatening me, fabricating other accusations against me, and telling me that if I accept to help him, he would not tell the Court that I did this or that. I was not moved by that threat, and I completely refused. NGEZE was very angry with me.

31. On May 04, 1999, NGEZE wrote a letter to all former officers of the FAR, who are detained in the UNDF, asking us to callaborate with him so that we could have a common strategy before the Court. He alleged that I attacked his house, because I wanted to kill him and those Tutsi he had hidden in his home. He alleged that I arrested him during the night of the 61h to the 71h of April 1994, and that I kept him in detention until April 9, 1994. He said many other things, which were false. He involved some Interahamwe, including Thomas MUGIRANEZA, TWAGIRAYESU alias MABUYE, Damas KALIKUMUTIMA, MUNYAGISHARI Bernard and GAHUTU. He specified that those names appear in the SERUSHAGO case.'

32. He talked about many other imaginary incidents where I was targeting him. I will talk about all that below. But, the fact is that in this document, NGEZE targets Anatole NSENGIWMVA, lieutenant BIZUMUREMYI, and captain HABIMANA. He also talks about Interahamwe, whose names have been given by SERUSHAGO during his trial too.

33. In a letter dated on October 26, 2001, NGEZE wrote asking the Tribunal to provide him with translations of letters he had written to Anatole NSENGIYUMVA. He gave me a copy of the letter, as well as to other colleagues. I found out that he was talking about five letters that I had never received, even though NGEZE was supposed to have addressed those letters to me. Mr NGEZE has fabricated all alleged events involving me in thc killings and other wrongful conduct.

' 1 will comment on that document and to others later.

5 Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

Why does Hassan NGEZE target lieutenant BIZUMUREMYI ?

34. He targets that officer, only because he interrogated him together with Major UWIMANA, when hc has been arrested in May 1994, after weapons and a radio transmitterireceiver were discovered at NGEZE's home. He does it not only in his fabricated letter and in other documents, he does it also in his KANGURA newspaper. So, we can understand a bit why lieutenant BIZUMUREMYI is demonized by some other witnesses. Those could be amongst the ones trained by NGEZE. But the most amazing thing is that NGEZE docs not target Major UWIMANA. It is strange. NGEZE also targets captain HABIMANA, because he went to search his house, and seized the material I have mentioned above.

NGEZE fabricated documents, and participated in the training of Prosecution witnesses

35. It is important to compare the letter of May 04, 1999, with the letter NGEZE wrote to AFRICAN RIGHTS, or the letter of April 10, 1994, with the letter that NGEZE wrote to the Commanding Officer of the UNDF, Mr GUINDO, on January 04, 2005, because one can see that there are big differences, which shows that NGEZE has always fabricated evidence.

36. At a given moment, he says that I sent him Interahamwe to arrest him, and to bring him to the military camp. And those Interahamwe are the same mentioned by SERUSHAGO in his statements, as well as witness DO in his statements too. This clearly shows that NGEZE participated in the training of those witnesses, so that they could say the same thing, and involve the same persons.

37. You will realise that at a given moment, NGEZE changes his previous allegations, and says that people who came to arrest him were soldiers who were led by second lieutenant Eustache DUSABEYEZU. And SERUSHAGO, at a given moment, has also changed his statement, and said that it was lieutenant Eustache DUSABEYEZU who came to inform him of the death of the President, and the killings which had started during the night. Nevertheless. he had said before, they were Interahamwe with handicapped officers who had came to inform him. And DUSABEYEZU was not a handicapped officer.

38. This is not a coincidence, they have certainly consulted each other, and decided to charge lieutenant DUSABEYEZU too.

39.1 have seen two judgements in Rwanda, one of BANZI Wellars and 53 others, and another of witness DO and 11 others. All those witnesses talk about what has happened in the city of Gisenyi during the period of the killings, and they do not involve those Interahamwe discussed by NGEZE, SERUSHAGO, DO and ZF. And what is strange, is that DO is an accused in one of the judgements in Rwanda. I am not defending MUNYAGISHARI, MABUYE and others, but what I mean is that what is said by NGEZE, and by the witnesses who appeared in Arusha, is completely different from what has been said before the Rwandan tribunals, regarding the events in Gisenyi city. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

How DO I recognize witnesses trained by Hassan NGEZE ?

40. The major objective for Mr NGEZE was to have Anatole NSENGIYUMVA condemned, and to demonise lieutenant BIZUMUREMYI. You will recognize witnesses trained by Mr Hassan NGEZE by these two details: to target Anatole NSENGIWMVA and demonise lieutenant BIZUMUREMYI.

41. But Mr NGEZE wanted also to get an alibi, especially from the night of the 61h to the 7th of April 1994, and the period from April 7 to April 9, 1994. He decided to say that he was in detention in the Gisenyi military camp. You will recognize the witnesses trained by him, by the fact that they allege that NGEZE was arrested during the night of the 6th to the 7Ih of April 1994, taken to the Gisenyi military camp, and kept there until April 9,1994. This is what most of his defense witnesses have tried to say, and it is what some Prosecution witnesses have said. But it is known that this is not true at all.

Who are the witnesses prepared by Hassan NGEZE ?

The first witness is Mr Omar SERUSHAGO. In fact, SERUSHAGO targets Anatole NSENGIYUMVA and lieutenant BIZUMUREMYI, for facts which we have not committed at all. And we how that SERUSHAGO, when he left TINGI-TINGI in the DRC (then Zafre), has been accomodated by Hassan NGEZE in Nairobi. This is said in a letter written by Hassan NGEZE to Omar SERUSHAGO. And when SERUSHAGO arrived in Nairobi, Hassan NGEZE had already written his letter to AFRICAN RIGHTS, targeting Anatole NSENGIWMVA and lieutenant BIZUMUREMYI.

We also how, that when SERUSHAGO arrived in Nairobi, Hassan NGEZE had already written his articles in his journal KANGURA, including the article saying that he will vex Anatole NSENGIYUMVA and others (BIZUMUREMYI and captain HABIMANA) with his pen.%^^^^ had already written his other articles in his journal, talking about Anatole NSENGIYUMVA and lieutenant BIZUMUREMYI, alleging that we attacked him at home, and wanted to kill him.

In his letter written to SERUSHAGO from the UNDF, Hassan NGEZE seems to remind SERUSHAGO what he had to say about me and BIZUMUREMYI, concerning his alleged arrest and detention, as well as the alleged attacks against him. He wanted SERUSHAGO to tell that to the Prosecutor and the Judges.

In his deposition in the Media Trial, SERUSHAGO says that he was an informant of the Prosecutor when he was in Nairobi, but NGEZE was an informant too. This means that the two men managed to lie to the Prosecutor giving similar details about me, and BIZUMUREMYI.

Anyway, it is clear that Hassan NGEZE used SERUSHAGO to accuse me, and to have me condemned. It is not mere coincidence that he refers to the SERUSHAGO trial, in

'See KANGURA issue, number 60, of I" to 1 5Ih September 1994

7 Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME his letter of May 04, 1999; to show that the Interahamwe NGEZE was talking about were also mentioned in the SERUSHAGO Trial. I have understood that it is Hassan NGEZE who asked SERUSHAGO to mention those names.

47. The other witnesses are OAB and OAF. These two witnesses talk about the alleged arrest of Hassan NGEZE, during the night of the 6Ih to the 7th of April 1994, and his detention in the military camp. They say that without being asked any question by anyone, during the examination in chief. And we know that those allegations are not true. They just talk like NGEZE's defense witnesses.

48. Indeed, NGEZE himself said that he had known that those two witnesses had been approached by the Prosecutor, who wanted to call them against NGEZE himself. NGEZE wanted them to come and testify in his favour, to the dismay of the Prosecutor. At the last minute, the Prosecutor changed, and brought those two witnesses in our trial, to charge Anatole NSENGIYUMVA. NGEZE managed, anyway, to get the transcripts of their deposition and use them for his appeal.

49. Many detainees in UNDF know that Hassan NGEZE had prepared those two witnesses himself. He would say it openly.

50. Another detail about these two witnesses, is the fact that they alleged that they would transport Tutsi into a drum, to take them to Zalre. This had been said by Hassan NGEZE too, during his deposition in the Medias case. But when they realised that the judges didn't accept that allegation, they changed and said that they would take the Tutsi not inside the drums, but among the drums. But NGEZE stood firm, and said that the Tutsi were put into the drums and taken to Zai're. This shows, anyway, that the witnesses had had a consultation with NGEZE on that issue.

51. I must add that NGEZE said, in his deposition, that he taught some other people how to transport Tutsi inside the drums. He gave names and the first person is witness OAB, the second is witness OAF. Is that a pure coincidence ?

52. Witness ABQ has clearly been prepared by Hassan NGEZE. We have heard this witness say that he was at NGEZE grand father's home, where he was mourning the latter's death, when he was informed that President HABYARIMANA had been lulled. We heard also that ABQ said that NGEZE has been arrested during that night of the 61h to the 71h of April 1994, by soldiers, and taken to the Gisenyi military camp.

53. We know that NGEZE's grand-father was not dead at the time alleged by ABQ.' This means that ABQ has lied. But we are at least sure that this witness has been prepared by Hassan NGEZE. In fact, the Prosecutor has been misled by Hassan NGEZE. Indeed we have seen that the link betwwen ABQ and the office of the Prosecutor was NGEZE's brother, KAGABO Issa, who lived in Nairobi . All this constitutes evidence to show

' In his letter of May 04, 1999, page 5 and 6, Hassan NGEZE alleges that his grand-father was killed in an attack launched against his home, long after the date hc is supposed to have been taken to the military camp. Thus, what ABQ has said is a fabrication. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME that ABQ has been prepared by NGEZE, perhaps through his brother KAGABO Issa, and put in contact with the Prosecution, under the pretext that ABQ had interesting information against Anatole NSENGIYUMVA.

54. This was very interesting for the Prosecutor, as ABQ had to corroborate OQ's allegations. And it was not difficult for NGEZE to tell ABQ what to say, as he had been accused by witness EB to have incited the Interahamwe to kill members of GASAKE's family, after a meeting at Bamabe's house. NGEZE wanted to put that under the responsibility of Anatole NSENGIYUMVA. For the Prosecutor, ABQ was interesting, as he would corroborate OQ, but for NGEZE, ABQ had to prove his innocence. It is what ABQ tried to do. I point out, by the way, that ABQ could have testified in the Media case, in favour of NGEZE, under other names. I have even been told that ABQ could have visited NGEZE at the UNDF, many times.

55. The other witness is DO. You have seen how DO targets BIZUMUREMYI very persistently, even during the period in which that officer was not yet appointed in ~isen~i.~I have seen two judgments in Rwanda, involving people of the city of Gisenyi, but none talks about BIZUMUREMYI during the events. Apart from witness DO'S himself, I have seen the BANZI Judgment, which involves 54 persons of the city of Gisenyi. The DO Judgment involves 12 persons of the city of Gisenyi, and apart from DO himself, no other person talks about BIZUMUREMYI.

56. We have heard DO saying that he was very close to Hassan NGEZE, and that he even lived in NGEZE's house at a given moment. In one of his statements, DO even says that when soldiers went to search NGEZE's house, DO was personally present at NGEZE's residence, and that he escaped with NGEZE's boyguards. What was DO doing at NGEZE's residence, so early at about 5.00 a.m. ? Is it not possible that DO could have been a member of NGEZE's bodyguards ?And if so why is he not disclosing that fact.

Which is the evidence to support my allegations ?

57. Mr Hassan NGEZE has written many documents, which would show that all that he said is only lies, and that the major aim was to have me condemned, and to demonise lieutenant BIZUMUREMYI. Amongst those documents, I will mention the following:

- Letter from Hassan NGEZE of May 04, 1999, sent to Anatole NSENGIYUMVA and other former FAR officers, detained at the UNDF.~In this letter, NGEZE tells fictitious stories, on how I arrested him many times, how I threatened him with death, how I attacked his residence, etc ... He alleges that in the night of the 6'h to the 7'h of April 1994, 1 sent him some soldiers and Interahamwe to arrest him and bring him in the camp. He gives details on what other officers did to him. But all this is a simple fabrication.

Witness DO alleges that lieutenant BlZUMUREMYl (he says that he was captain)was seen walking through the city of Gisenyi, in the company of Interahamwe, since 1993. But that officer was not yet in Giseny in 1993. 5 The letter is in Kinyawanda.

9 Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRlCATlON OF TESTIMONIES AGAINST ME

Letter of February 02, 1995, sent to RAKIA OMAR of AFRICAN RIGHTS. NGEZE talks about me a lot, as well as lieutenant BIZUMUREMYI and captain HABIMANA. But he doesn't talk about the Interahamwe as in the letter of May 04. 1999.'

Letter of April 10, 1994, written by Hassan NGEZE, and supposed to have been sent to Anatole NSENGIYUMVA. NGEZE alleges that he had been detained in the Gisenyi military camp, from the night of the 61h to the 71h of April 1994, and gives details on that alleged arrest and detention.'

A letter refering to another supposed to have been written on May 10, 1994, and supposed to have been sent to Anatole NSENGIYUMVA by Hassan NGEZE. I have never received those letters, when I was in Rwanda. I am supposed to have received them, but I received none officially.8 NGEZE talks about his alleged problems with me.

A letter supposed to have been written on June 8, 1994, by Hassan NGEZE, and supposed to have been sent to Anatole NSENGIWMVA. NGEZE talks about an alleged search at his home, and an alleged kidnapping by soldiers. I had never seen the letter, when I was in ~wanda.'NGEZE mentions rockets and rockets launcher, as well as stream grenades. This reminds me that Mr SERUSHAGO mentions the same materials, in his written statements, when he was still in Nairobi. It is the moment when he was with NGEZE in that Kenyan city. This is supplementary evidence that they have consulted to have me condemned.

A letter written on October 26, 2001, by Hassan NGEZE, and sent to Mr Stephen RAPP, then Senior Trial Attorney in the Office of the Prosecutor, in the Media Case. This time, NGEZE gave me a copy, but I did not take this seriously. It is now that I understand that the letter is important. I have a copy of the letter." . The letters in respect of which NGEZE was requesting a translation included letters written on the 16 March 1994, 10 April 1994, 10 May 1994, 16 May 1994 and 8 June 1994. All those letters were supposed to have been sent to me, but I have received none at all.

I am sure that all those letters have been fabricated in Nairobi, or even here in Arusha.

The letter is in French and English. ' The letter is in French and English. I had never received this letter in Rwanda. NGEZE gave it to me certainly unwillingly, when he gave me a copy of the BANZl Judgment in Rwanda, Kinyanvanda version. It was on April 18, 2003, during the period he was paylng court to me, so that 1 could accept to testify for him, and help him to tell lies. The letter is in French and Kinyarwanda. The letter is in English, French and Kinyanvanda. 'The letter is in English. 10 The letter is in English. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

- A letter written by NGEZE to Omar SERUSHAGO, in 2001, and talking about Anatole NSENGIWMVA, among other things." The transmitting letter written to Mr RAPP is dated November 2,2001.

- A handwritten letter by Omar SERUSHAGO, with Claude BOUCHARD as witness, explaining how SERUSHAGO had received the letter sent to him at the "Safe House" by Hassan NGEZE."

- Ex-parte motion to produce Accused Persons as Witnesses, written by NGEZE's counsels, on September 26, 2002. I was among those proposed by NGEZE's counsels, together with others. We have responded by the "Anatole NSENGIYUMVA'S response to ex-parte motion to produce accused persons as witnesses". Our response is dated October 15, 2002.

- An e-mail sent by Hassan NGEZE to Ms MONASEBIAN of the Office of the Prosecutor in the Media Case. The e-mail has been sent on February 28, 2002. This e-mail shows that Hassan NGEZE had enough means to get in touch with persons outside the UNDF. It is in that way he has manipulated witnesses who had to come to charge me, including those who defended him, in involving me in different matters.

- You remember that witness ABQ said that he came to see the Prosecutor, after having received an e-mail sent to him by someone. But he refused to say who whas the person who sent him that e-mail. Nevertheless, we know that the link between ABQ and the Office of the Prosecutor was NGEZE's younger brother, i.e. Mr Issa KAGABO.

- The "Appellant Hassan NGEZE's Motion for leave to present additional evidence in Hassan NGEZE Vs the Prosecutor (respondent) -Case No ICTR- 99-52-A", written on January 11, 2005, by Mr BHARAT B. CHADHA, Lead Counsel. Mr NGEZE wants the Appeals Chamber to ask me to go and adduce evidence in his favour. This is a second attempt, as we had refused that, at the trial Chamber level. I have to add that NGEZE has not given us a copy of the motion.

- A letter called "Prisoner Hassan Ngeze concerns adressed to the Commanding Officer and the Tribunal authorities", written by Hassan NGEZE, on January 04, 2005." Ngeze is talking about me and about some of my colleagues, concerning the allegations that we arrested him, we threatened him, and many other accusations. He even alleges that 1 killed people who were with him in detention in the military camp in Gisenyi, that KABILIGI tried to kill him in Goma, that this operation has been conducted by NTABAKUZE without success, that we went back to Rwanda to kill survivors of genocide, etc ...

I I The letter is in Kinyarwanda and English. NGEZE tried to deny that he was the one who had written the letter. " The letter has been given to us as "SERUOMA -04". '' We received no copy of this document. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

- I find out that these attempts to influence all the authorities of the Tribunal are very prejudicial to me. I complain about the Ngeze's attempt to have me demonised by the Tribunal authorities. This is very dishonest, and could explain what I am just trying to do, i.e. to show that Hassan NGEZE has always tried to do harm to me, and to have me condemned.

- I have to add that NGEZE tries to find any pretext to have me condemned, by using lies. He realised that the lies he has fabricated during his trial didn't work, and now, he has fabricated others. All those are lies, but they are very harmful for me. The allegations contained in the document are very grave, and could participate in influencing the Judges' opinion, to my detriment.

Other evidence

58. Here are some other evidences, of how NGEZE has fabricated allegations against me, so that I be demonised, together with Captain HABIMANA and lieutenant BIZUMUREMYI, only because we knew what he did:

- Kangura No 62: In this Kangura issue, NGEZE says that KANGURA has forgiven those stupid persons who would hunt him down, and that the most active were lieutenant BIZUMUREMYI and captain HABIMANA, and those who would assign them missions (meaning Anatole NSENGIWMVA).

- This shows that NGEZE had a grudge against BIZUMUREMYI, HABIMANA and Anatole NSENGIWMVA. But the only reason to all that, is the fact that we knew who he was, and the search we conducted at his home, with the weapons and radio we discovered.

- Kangura No 65: In this Kangura issue, NGEZE attacks lieutenant BIZUMUREMYI, Captain HABIMANA and Colonel Anatole NSENGIYUMVA, saying that they attacked his home, and wonder why we had not yet joined the WF in Rwanda, as we are known as INKOTANYI.

NGEZE contends that he has been detained in prison 20 times, and 35 times in other detention facilities, as well as another one time when Colonel NSENGIWMVA has detained him in May 1994, which makes 36 times he has been detained in other places than in prison.

NGEZE considers then Anatole NSENGIYUMVA and General GATSINZI as Inyenzi like other Inyenzi. This shows how NGEZE has a grudge against me.

- On page 12 of the very issue, NGEZE cites again the names of Colonel Anatole NSENGIYUMVA, Lieutenant BIZUMUREMYI and Captain HABIMANA, and says that we were accomplices of the Inkotanyi. He asks the population to keep attention, so that other accomplices couldn't infiltrate their ranks, like we had done it before. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME

- All this should shows, at least, that I could not collaborate with this Mr NGEZE, as some prosecution witnesses say it. This should also show that it is true that some people in the city of Gisenyi would consider me as an accomplice of the enemy, as some of our defense witnesses affirm it. This was caused by this propaganda conducted by Hassan NGEZE.

- We also note that NGEZE has been arrested by me only once, and that this occurred in May 1994, only. This is very important, because it contradicts other allegations advanced by Hassan NGEZE. It then shows that NGEZE fabricated many things against me.

- Kangura No 66: Hassan NGEZE has shown a list of persons supposed to have helped the RPF, in killing the Hutu, from the beginning of the war in October 1994. He alleges that that list has been written by a "Christian Bureau in Eastern Europe", which sent it to the ICTR.

- The list contains 235 names, and Anatole NSENGIYUMVA is number 45, Captain HABIMANA is No 46, and lieutenant BIZUMUREMYI is No 47. On Number 57, we find Father KAJYENGO, a priest of Nyundo Diocese, who has been under my protection, together with Bishop KALIBUSHI, from April to June 1994. On No 58, there is Father NSENGUMUREMYI Jean Marie Vianney, a priest of Nyundo Diocese, who was the superior of BUSASAMANA Parish in April 1994.

- Most of the transcripts of the deposition of NGEZE's defense witnesses charge Anatole NSENGIWMVA, and allege that NGEZE had been arrested during the night of the 6"' to the 71h of April 1994. They contend that NGEZE has been arrested on many other occasions, during the period April-July 1994, by Anatole NSENGIYUMVA. They even allege that my soldiers attacked NGEZE's home.

- All that is false, and the Prosecutor has given evidence on that, in the Media Case. This is another example which shows how NGEZE built his Defense, in trying to have me condemned too, as he has proclaimed it every time.

- All this shows the level of hatred by NGEZE against me, which made him to try to fabricate witnesses, so that I be condemned by the Tribunal. He has always talked about that issue, even very openly.

Conversations held by Hassan NGEZE

59. 1 have not recorded all the conversations I had with NGEZE, or all the conversations he had with others. I only give exemples, which will show who is NGEZE, and which relations exist between him and me. Those conversations are noted below: Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME On June 17, 2001, around 17h00-18h00, NGEZE came to see me. He asked me to tell the Court that I had arrested him during the night of the 6thto the 7thof April 1994, and that he stayed in dentention until the 9Ih of April 1994. He told me that all this would help us, as the matter of the alleged distribution of weapons, supposed to have been done by NGEZE and by me during that period, would not stand. l4

I refused to be involved in his lies to the Court, and I told him that I didn't want to help him in his lies.

The next time, June 18, 2001, he came back to see me for the same issue. When I refused again, he began threatening me. He told me that I had given him grenades, and that if I help him, he would not say that I did it. This matter of grenades was not true; it is another fabrication from NGEZE. It was pure blackmail.

- At the same occasion, NGEZE told me that he had many other witnesses in Rwanda who would help him to destroy the Prosecution strategy. According to him, those witnesses were prosecution witnesses, but when they would amve before the Court, they would talk in favour of Hassan NGEZE. He even revealed to me that one of my drivers would come to confirm that he had been detained in the military camp, the night of the 6'h to the 71h of April 1994. He asked me not to challenge the driver's deposition. I didn't respond to that request.

NGEZE then told me that my soldiers had attacked his home, but that he will not say it to the Court, if I accepted to help him to conduct his strategy. I rejected that proposal, and NGEZE left, very angry. This happened around 18h00.

When he told me that, some of my colleagues saw us, and were surprised by that conversation, as it was not common to see me with NGEZE talking. They asked me and I told them what we were talking about.

On August 28, 2001, around 18h30, NGEZE said that he had sent a letter to Mr Omar SERUSHAGO, that he had declared war on SERUSHAGO, but that the letter had been seized. He said that he would not recognize having written that letter.

On another date in June 2003, NGEZE told two of the detainee that he bad known that witnesses OAB and OAF had been contacted by the Prosecutor, to come and charge him. He then asked those witnesses to come and talk in his favour, making the Prosecutor become ridiculous. But he added that the Prosecutor didn't bring them in the Media Case.

14 It is a fact that I distributed no weapons with NGEZE or alone, but 1 could not embark in his manoeuvres and tell lies to the Court.

14 Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME - Later on, the Prosecutor brought those two witnesses in our Case, and they charged me. NGEZE then managed to get their transcripts and used them in appeal. This means that he had also asked them to charge me.

60. Those are some details I have collected about Hassan NGEZE. I have not said all that I know. But I think that these elements are enough to show that NGEZE has fabricated some witnesses against me, as well as against lieutenant BIZUMUREMYI.

61. This will give an idea, as to why NGEZE does his utmost to have me condemned. It gives an idea, on why he is against me and against lieutenant BIZUMUREMYI. We simply knew what NGEZE has been doing. NGEZE knows that weapons and the radio transmitterlreceiver were seized at his home. That is the reason why he fabricated all those stories, so that I be discredited before the Tribunal. Now, he is trying to have me discredited before all the authorities of the Tribunal.

62.1 find that attitude very prejudicial, and fits well within the framework of his campaign against me in KANGURA,when he says that he would harm me with his writings.

63. NGEZE is not the only one who has influenced false testimony against me There are some others who did it.Although I have no direct evidence , I can nevertheless imagine what happened. It is what I want to show below.

The responsibility of the RPF

64. The RPF has always done it utmost to harm me. For example, in March 1993, the RPF wrote a letter to the Rwandan Minister of Foreign Affairs, sending a list of persons who had to be fired from their posts. I was No 4 on that list, and I was labelled as a member of the hypothetical "Death Squads". No single evidence has been given for that. Lieutenant BIZUMUREMYI appears on that list, and he is the only officer, with the rank of lieutenant, to appear on that list.

65. It is then not suprising to find our names cited by some prosecution witnesses coming from Kigali. The same RPF could have contacted them and asked them to charge us. In that category of witnesses, I would cite witness ZF; XXQ, DAS, DBN and ON.

66. Indeed, concerning ZF, it is somebody who had worked with me in Gisenyi, and as you know it, he had been working in a very sensitive domain. The RPF has certainly known what ZF has been doing during the warI5. Normally, someone like ZF had to be executed by the RPF as a traitor. He has not been executed, and he even has been given a job by the RPF Government, as ZF said it himself, during his deposition.

67. This means that in exchange of that preferential treatment, ZF has accepted to charge me, and to fabricate a lot of ridiculous issues against me, and against lieutenant

l5 In KAREMERA and others case, ZF acknowledged that the RPF had shown him copies of messages he had been recording before we fled from the country. This happened when ZF came back from exile.

15 Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME BIZUMUREMYI. You have seen that he even alleged that BIZUMUREMYI had been in Gisenyi since 1992, what was not true.

68. Besides, the Prosecutor refused to give to us ZF whereabouts. We have not been able to how what kind ofjob ZF had received from the Government, and where ZF was living, what he was doing, during the period he came to testify against me before the Court. This is very prejudicial to me, because his whereabouts could have enabled me to show how ZF had been manipulated. It is what the Prosecutor avoided. So, my opinion is that ZF has been manipulated by the RPF.

69. Concerning witness XXQ, he has been interrogated by the deputy General Prosecutor on the highest lever of the Rwandan justice, Mr RUKANGIRA Ernmanuel, and that his file has been sent to the ICTR by the highest Prosecutor in the Rwandan justice, Mr Gerald GAHIMA. This is a unique case, which has been handled like that.16 And the two personalities were members of the RPF.

70. I cannot doubt at any moment, that the witness is a fabrication of the RPF. Besides, we know that that witness had been an officer in ex-FAR, who had joined the RPF. He had worked in the military intelligence of the RPF, before being arrested for genocide, and detained. He has been sentenced to death. So, what he has said has been fabricated by the RPF, and he did it so that he could get some favours from his jailers. Perhaps he expected his sentence to be changed into imprisonment, instead of death penality.

71. You have seen for example how he added me in his allegations, once before the Court, when he had not mentioned my name in his written statements. And he alleged that I was a member of the death squads !

72. Witness DAS could have been prepared by the RPF, but he might have been prepared by IBUKA as well. Indeed, in his first statement, he talked about one Anastase MURUMBA. And that MURUMBA has been for a long time, the Vice-president of IBUKA Association. It is then not surprising that Mr MURUMBA might have asked witness DAS to make that statement, accusing all the officers he knew as having lived in the Kiyovu neighbourhood in Kigali city.

73. Witness DBN was a Tutsi soldier of the FAR, who then joined the RPF troops. That is the reason why 1 say that he has been prepared by the RPF to come and charge me. Indeed, what is surprising, is the fact that DAS alleged that I was in Kiyovu neighbourhood of the city of Kigali, on April 14, 1994, when witness DBN said that I was in Kanombe camp the next day, i.e. April 15, 1994. This is not a simple coincidence. Their statements have certainly been coordinated. Who coordinated it ? I think it is the RPF. or IBUKA.

I6 Gerald GAHIMA was the General Prosecutor in the Supreme Court of Rwanda, and Emmanuel RUKANGIRA was his deputy. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME Some Prosecution witnesses have been influenced by opposition political parties and/or by the RPF.

74. Those witnesses are, for example, DESFALI and GHH, i.e. Alison DES FORGES and Filip REYNTJENS.

75. I will not be long about DES FORGES, because every body understood that her deposition was very biased in favour of the RPF. And wben she was asked to reveal her sources of information, she first refused, but eventually, she gave some sources. She talked about Alphonse Mane NKUBITO (MDR); KAMEYA Andrk (PL); KATABARWA Andre (PL); SHAMUKIGA Charles (PL); SISI Evariste (PL); NDASINGWA Landoald (PL), MUJAWAMARIYA Monique (MDR), and others. She also said that she got informations from the RPF, from the American Embassy, from churches, etc ...

76. It is then clear that such a witness could not have information which was not biased. And we have seen the kind of informations she had. Anyway, she had contacted no members of the the regime, or those close to the MRND or allies. Then, it is clear that Alison DES FORGES has been influenced by the opposition political parties, the RPF and persons of the same tendency.

77. Concerning Professor Filip REYNTJENS, his contacts were also members of the opposition, even though he does not recognize it formally. But he doesn't deny that persons like KARAMIRA Frodouald were his friends, especially wben KARAMIRA had not yet become a member of the MDR Power wing. KARAMIRA told me that he had been amongst those who asked Filip REYNTJENS to widely spread the idea, regarding Death Squads in Rwanda, composed by persons close to President HABYARIMANA, his family and the family of his wife.

78. It is Mr Anastase GASANA (MDR) who proposed that persons very close to the MRND be demonised and treated as killers, murderers, etc ... This has been written in

the famous document from the very GASANA Anastase - MDRZZZZ-1 - of May 1992. We have seen that REYNTJENS wrote his report in september 1992, four months after MDRZZZZ-I, and alleged that there were Death Squads in Rwanda. He labelled members of those alleged Death Squads as members of HABYARIMANA's family, members of his wife's family, and in general, members of the BUSHIRU region, the region of the President, or those very close to the MRND and CDR, etc ..., just as Anastase GASANA wanted it to be said.

79. It is then clear that Filip REYNTJENS has been influenced by political parties of the opposition. We have seen that he relied on what Mr Janvier AFRIKA told him, and we

have seen that that man - Janvier AFRIKA - was very close to the opposition and the RPF. REYNTJENS recognized it himself. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME The AVEGA Association played a role in trainine witnesses who had to come to Arusha

80. I find out that witnesses OC and OQ have been trained by AVEGA. If we consider witness OC first, this witness is a member of the AVEGA association. It is written in her identification file. And we have seen that what she came to say before the Court in Arusha is completely lies. She alleged that her husband had been killed by persons who were with me, on April 7, 1994, around 18h00. But we got informations on how her husband has been killed. Witness DEF-I of the defense has given reliable explanations.

81. 1 considered that the fact of lying so shamelessly, has been dictated by her situation as a member of AVEGA Association. The objective of that association, as well as the objective of IBUKA Association, is to have most of educated Hutu condemned and put in jail, or even killed. Everybody saw how OC could even not identify Anatole NSENGIYUMVA.

82. Concerning witness OQ, he accused me of having held a meeting at Bamabe SAMVURA's home, after which I gave an order to massacre members of his family. This is completely false anyway.

83. The alleged meeting at SAMVURA's home has first been evoked by witness OE, in 1995. She then said that the meeting was chaired by Colonel Pierre Celestin RWAGAFILITA. She then alleged that when she left RWAGAFILITA at SAMVURA's home, she went to the Gisenyi Catholic Parish, and met Anatole NSENGIYUMVA near the Gisenyi market, in the company of Interahamwe.

84. In September 1995, Colonel RWAGAFILITA died in CAMEROON. Witness OE rectified her statement, and made another one in 1996. She then said that it is Anatole NSENGIWMVA who was chairing the alleged meeting at SAMVURA's home. She did not mention Colonel RWAGAFlLlTA anymore !

85. Meanwhile, witness OE fell sick. She subesequently died. But before she died, she could have had the opportunity to train witness OQ, so that he be able to charge me, involving me in the alleged meeting at SAMVURA's home, and in the killings which would have followed the meeting. OQ did it in 1997, and OE died. When OE had said that I chaired the meeting at 5h00 a.m., OQ said that I chaired it between 9h00 and 1Oh00 a.m.It wAs necessary this time to change the time to be able to explain that it was broad daylight and hence I could easily be identified.Moereover it would have been difficult for witness OQ to explain his presence outside Samvura's residence at 5 am!

86. We have seen that ABQ talked about the same meeting, but said that OQ was not in Rwanda in 1994, because he had joined the RPF a long time ago. And we had got the same information that we suggested to OQ.

87. After having considered all this, I found out that the alleged meeting at Barnabe SAMVURA's home has been fabricated by witness OE, within the framework of the AVEGA activities. I have to specify that witness OE, before she died, was the Strictly confidential- NSENCIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRICATION OF TESTIMONIES AGAINST ME President of AVEGA in Gisenyi. This is very important, for somebody who wants to understand all the manoeuvres of those associations.

The IBUKA Association has also trained witnesses who came to charge me

88. It is indeed very difficult to differentiate the training by IBUKA from the training by the RPF, because it is almost the same. But I think that witnesses ON, DCH, XBH, XBG and XBM, have been trained by the RPF.

89. In fact, concerning witness ON, we have seen that he was a high-ranking civil servant of the rwandan government, after the taking of power in Rwanda by the RPF. He became Ambassador in Uganda, and after, he became a member of the Parliament. Such a person was very close to the RPF. It is within that framework that I say that he has been trained as a witness to charge me, by the RPF.

90. We have seen how this witness ON globalizes, when he talks about Hutu people, saying that they planned, prepared and executed the "genocide". The way he does it, is characteristic of RPF. But he could have been trained by the IBUKA Association, as he is a member of that association. And I have said that it is difficult to differentiate RPF and IBUKA.

91. Concerning DCH, he is a Hutu. We cannot say that he is a member of IBUKA. When I consider the way he has testified, I think that he has been trained by the RPF. But he could have been trained by the IBUKA Association as well.

92. Witness XBH declared before the Court, that he had written to the Association which

collaborated with the Tribunal - meaning IBUKA - even if he has immediately withdrawn that allegation, saying that he had not said it. I intervened and told the Court what the witness had just said. The President of the Chamber has said that verifications had to be made in the Kinyarwanda recordings. But until now, nothing has been done.

93. We know that XBH, XBG and XBM have been trained together in prison, in Gisenyi and Ruhengeri. Thus, I consider that XBG and XBM have also been trained by IBUKA, just like XBH. The way the Prosecutor introduced the three witnesses is very suspicious, and what XBH has said might be true, meaning the fact that he has written to IBUKA, before meeting the investigators of the Prosecutor.

CONCLUSION

1. I have shown how NGEZE manipulated witnesses, so that they be able to charge me, and have me condemned. The most important witnesses amongst those trained by NGEZE are Omar SERUSHAGO, OAB, OAF, ABQ, and perhaps DO.

2. I strongly denounce that. And the evidence I have given confirms it. Strictly confidential- NSENGIYUMVA CASE: A HIGH LEVEL CONSPIRACY; FABRlCATlON OF TESTIMONIES AGAINST ME 3. NGEZE continues to do harmful things, so that I be annoyed, in one way or the other. The letter he recently wrote to the authorities of this Tribunal is an obvious example which coihfirms that. This is a continuous campaign of destabilising me, and influencing the opinion of the authorities of the Tribunal, so that I be condemned without any hesitation.

4. I commenced by talking about witnesses trained by Hassan NGEZE, but eventually, I have talked about almost all the witnesses, and how they might have been trained.

5. 1 remind you what Mr OSSOGO, then member of the office of the Prosecutor, had said on December 2,1999, when we were pleading the joinder motion. He contended that Anatole NSENGIWMVA was born in Gisenyi, the region of President HABYARIMANA, that the President would go on holidays there, that Anatole NSENGIWMVA was the military commander in that very region during the period of the events, and that therefore, it was unbelievable that Anatole NSENGIWMVA could not have been involved in the genocide and the conspiracy.

6. Another issue is that persons I have arrested, like NGEZE and SERUSHAGO, kept a grudge against me, and are now doing their utmost, to take their revenge against me. I am then a victim of having done my job, during the events of April-July 1994. I think that this point is very important to be mentioned, because finally, that is the real problem I am facing.

7. Another point is the one of the RPF, IBUKA and AVEGA. As the RPF had targeted me a long time ago, it is logical to proceed in the same way. Here, I have in mind the letter of March 1993, written by Mr MAZIMPAKA of the RPF, to the Rwandan Minister of Foreign Affairs, and where Anatole NSENGIYUMVA's name was number four. And I have specified that there was no difference between the RPF, IBUKA and AVEGA.

8. Details which are in the transcripts of the deposition of NGEZE's defence witnesses might show how I have always been targeted by that man - NGEZE.There are also the different articles contained in the KANGURA issues, as well as in different other documents written by NGEZE, which are clear pieces of evidence of Ngeze's fabrications.

9. What I am doing is not to denounce NGEZE as such. I simply want to show what the source of my problems is.

Done In Arusha This 7'h Day of Octobe52006 By