INTERNATIONAL COURT OF JUSTICE

Armed Activities in the Congo (Democratic Republic of Congo v. Uganda)

WITNESSES

Social witness:
Tafari Matombu- International Relations, specialized in African Ethnicities
Born in South Africa, later on moved to the United Kingdom where she did her
college education.

AGENT: The defense would like to introduce its first witness. The relevance of Tafari
Matombu giving her testimony to this case is regarding her specialty in African
ethnicities and her studies in International Relations. Graduated from Cambridge in
the UK but was born in South Africa. Could you tell us a little bit more about your
experience with African ethnicities and how does this relate to the international
relations of African countries?

MRS. MATOMBU: There are around 3000 ethnic groups in the entire African
continent. Throughout history many of these groups have had disputes in terms of
territory, superiority and in general terms, power. Some even lead to civil wars and
severely violent conflicts. Many of these conflicts escalate into government postures
and interfere with the peaceful relations amongst countries with different ethnic
groups. In this specific case, Hutus and Tutsis .These disputes have caused
irreparable damage in society.

AGENT: If you have ever experienced closely one of these disputes, please
describe them.

MRS: MATOMBU: Yes, 5 years ago I was one of the people who intervened with the
agreements made during Rwanda's civil war. Therefore I am closely familiarized with
this conflict, which also involves the two ethnic groups who represent the main issue
for Congo and Uganda, talking about ethnicities.

AGENT: Please give us an example of one of those disputes?

MRS. MATOMBU: Sure, between April and July 1994 more than 800,000 unarmed
civilians were slaughtered, including United Nations peacekeepers who were there
trying to stop the violence. Besides launching massive genocide campaigns against
the Tutsi population.

AGENT: Please give context about this genocide.

MRS. MATOMBU: Yes, the genocide took place while the Rwandan civil war was
happening. The Congolese government supported the Rwandan current government
and expressed its support by giving resources to several government-controlled
militias, composed of violent Hutu extremists. With President Mobutu's support, the
ex-government controlled militias increased their military strength dramatically
between 1994 and 1996, and the size and frequency of their attacks also increased,
inside Rwanda and Uganda, that later became a serious military threat to both
countries. These militias later on incorporated into the Congolese armed forces.

AGENT: Now could you please give context to the massive genocide campaign
against the Tutsi population?

MRS. MATOMBU: The 1994 campaign was the one that preceded the other ones to
come between 1998 and 1999. These campaigns consisted in spreading messages
of hate and racism against the Tutsi population, it didn't matter whether they lived
inside Congolese borders or other Tutsi communities like the one in Uganda.
Through public broadcasts, speeches and interviews, Congolese leaders spread this
hate message. In fact, later on this discrimination against the Tutsi communities
developed in a civil revelation of the Congolese Tutsis, which was the reason of
Congo accusing Uganda of the allegations in the case.

AGENT: How does this discrimination and events affect Uganda?

MRS. MATOMBU: In a variety of ways. First of all it affects the right of all Tutsi
citizens to be accepted for their race and not being discriminated. This is unrelated to
the nationality, however, taking into consideration that there's a percentage of Tutsis
living in the Ugandan borders with Congo; there is a high risk of disputes in this area,
putting Ugandan citizens in danger. Like how hundreds of Ugandans were killed in
the genocide of 1994. Secondly, the events affect Uganda because of how close it,
is in terms of territory, to Congo, mainly because when a country is living in an
armed conflict all of their neighboring countries can be potentially affected , and in
this case Uganda was , and felt threatened.

AGENT: In conclusion the Congolese government has directly and indirectly

endorsed and supported separatist groups that have severely damaged the
Ugandan population and its own. It accomplished this by spreading a violent and
racist message that divides population and the possible unity that could have existed
between countries. All of this for power. Is it really worth it?

AGENT: Thank you for your time and knowledge Mrs. Matombu.

Political witness:
Paul Hanzo - Geopolitical Counselor from the Security Council
Born in Michigan, USA. Mastered in Yale.

AGENT: Dear judges, the defense would like to proceed the case regarding Armed
Activities in the Congo by taking Mr. Paul Hanzo into the stand, as he is a Counselor
from the United Nations´ Security Council, committee whose main objective is to
determine the existence of threats towards the prosperity of the world nations,
meaning, peace.
 Mr. Hanzo, inform us about the experience that makes you fit to answer questions
relating to the topic that is being discussed?

MR. HANZO: Well, after mastering from Yale University in Geopolitics, I have been
part of the Security Council, as the agent has already mentioned, since 1976. In
1988, I was chosen to argue African affairs out, especially those concerning Eastern
and part of Central Africa, the Great Lakes Region to be more precise. Therefore,
one of the latest topics I’ve been in is The Alleged Invasion of Neighbouring
Countries in Congo. So I would say those 23 years of witnessing different global
affairs have filled me with experience and knowledge.

AGENT: Mr. Hanzo, explain to us the relation that started and exists between the
different rebel groups that act against Uganda and the Democratic Republic of the
Congo's government during Mobutu Sese-Seko´s mandate?

MR. HANZO: Due to Rwanda's Civil War where the DRC gave military assistance to
president Juvenal Habyarimana in order to vanquish the opposition Rwandan
Patriotic Force, a military alliance between Mobutu Sese-Seko, Congo´s then
president, with the anti-Ugandans began, where this rebel group received supplies…
weapons, vehicles, military intelligence and such, from him. This later on repeated
with other rebel groups that have the overthrown of Uganda's government as an
objective, like the Allied Democratic Force and the FACs.

AGENT: If that's so, why do you think the Democratic Republic of Congo along with
Uganda decided to create the agreement that permitted both nations´ military forces
to cooperate to protect their border from these precise rebel groups?

MR. HANZO: I see no point… apart from this agreement being a strategy by the
Congo. That easily explains why the DRC did not act as expected from what was
established in it.

AGENT: And what about Sudan's involvement in this issue?

MR. HANZO: Oh well, the alliance that exists between Sudan and the DRC evidently
generated the arrival of Sudanese troops to Congolese territory, and they, alongside
the rebel groups, were not enough, so Zimbabwe also sent military forces, forming
what we could call a coalition.

AGENT: With all this over the table and also based on your knowledge, how would
you describe Uganda's reaction of sending troops to Congolese territory?
MR. HANZO: Uganda legitimately exercised its right of defending itself from the
evident threat that the various alliances formed with the DRC represented, if we take
into consideration the intentions of both, Mobutu Sese-Seko and Kabila had from the
beginning. What was committed is an act of national security to protect Uganda’s
sovereignty. And if I may say, Uganda had no choice but to overstep the limits of the
Congolese territory where it could operate, established in the agreement, due to the
fact that the places occupied are strategic locations that Sudanese troops could have
used to attack Uganda. The same territory where the rebel groups, that have the
potential of gaining more power, are located.

AGENT: Mr. Hanzo, please explain what national security means?

MR. HANZO: Sure. National security is the concept of protecting the stability of a
nation and everything that maintains its survival: life quality, the citizen’s well being,
international relations, and obviously its economy, to mention some. Additionally,
national security refers also to the different methods, strategies, resources and
means a country applies to achieve it. As you can see, this concept is closely related
to a nation's sovereignty.

AGENT: To sum up briefly Mr. Hanzo´s statement, Uganda´s alleged invasion to the
Democratic Republic of Congo cannot be considered as such, but as an act of
national security that implied decisive strategies to safeguard its sovereignty, as it is
important to consider that various rebel groups and troops from three African
countries, one of them being the DRC, were aiming at Uganda.
We sincerely appreciate your time and testimony, Mr. Hanzo. No further questions.

Economical witness:
Isaac Hossana- Economist and member of The World Economic Forum
Born in Israel, graduate of Bar-Ilán University

AGENT: The defense would like to introduce its third and last witness: an Economist
and Israeli entrepreneur, member of the World Economic Forum, Mr. Isaac Hossana.
The relevance of Mr. Hossana to this case falls upon his comprehension and
expertise of the complexity of economics, reason why this witness can introduce the
court into the case seen from an economical side, that if we may say, is one of the
most important aspects to be considered. Concepts of economic structures in
developing countries and the effects of war in economy.
Tell us a little bit more about your professional experience?

MR. HOSSANA: Of course. I am an economist graduate of Bar-Ilán University, one

of the most prestigious universities in Israel. Nowadays, I am the head of Economic
Health International, a company that, in general terms, supports different countries
by giving them advice on how to manage its economy. Basically, EH International
has toiled and succeeded with the uprising of stagnant economies.

AGENT: What would you consider the main areas that need to progress in the
developing countries in order for its economy to arise, particularly in the African
area?

MR. HOSSANA: ... First of all, the main goal for a developing country is to have a
stable economy. To have this, many factors intercede such as: security, growth and
equal opportunities. Most african countries lack these three and that's the reason
why most African countries have developing economies and serious issues with
poverty. These countries must center all their economic resources in order to see
progress.

AGENT: How can this progress you just mentioned be spoiled?

MR. HOSSANA: Well, think about it. To increase a nation’s economy, first of all, the
government needs to be on track and it needs to be united in order to create all the
structures, methods and plans to do so. But at the end, the progress of that country
falls upon its citizens. An extreme example, but that is closely related to the case are
armed conflicts, the different types. Attacks or threats from other countries or also
civil wars. Both create an expense of a lot of money, while the second one is prone
to generate a series of changes or reforms inside the government. They take time to
become solid and at the same time they commonly generate even more discontent.
All this leads to a stagnation or even a decrease of the economy.

AGENT: How does war affect the economy?

MR. HOSSANA: Well, it is evident that for this type of countries who don't have a
strong enough and stable economy, war can affect in a variety of ways. Mainly
because they don't have enough resources to sustain themselves, and what little
they have must now be focused into belic purposes. Wars cost a tremendous
amount of money and developing countries don't have resources to spare. Countries
now need to worry about spending resources on troops and weapons instead of
focusing these resources on more important things.

AGENT: Mr. Hossana, based on your professional opinion, how do you think
Uganda could afford war, economically speaking?
MR. HOSSANA: Well, Uganda's economy is not stable and there is no way they can
afford a war, they would have to make many sacrifices by cutting budgets of
programs that are truly important, such as public education or public health. That is
something that does not benefit this country at all. It is something that the
government would allow only for the need to protect the nation. In my opinion
Uganda is not economically prepared for war, but when it comes to defending itself,
sacrifices have to be made.

AGENT: Therefore taking into consideration all the information previously mentioned
and Mr. Hosanna´s testimony we can conclude that war, in any of its shapes,
severely affects the economy of developing countries and takes away their capacity
to focus on what really needs to be boosted regarding economy. And why is war
happening in Uganda? As other witnesses have concluded, because of its right of
self defense. So, Uganda is losing the opportunity of boosting its economy and using
resources in a war they didn't choose to be in.

That would be all, Mr. Hossana. Thank you.

Initial Hearing