May Firstiradvocates.mayfirst.org/sites/default/files/03.12.12 Samario Transcript & Exhs.pdfGore...

In The Matter Of:Claudia Balcero Giraldo, et al. vs.

Drummond Company, Inc., et al.

Letters Rogatory Video Hearing

Vol. 1

March 12, 2012

Gore Brothers Reporting & Videoconferencing

20 South Charles Street, Suite 901

Baltimore, MD 21201

410-837-3027

www.gorebrothers.com

Original File 031212hrg.txt

Min-U-Script® with Word Index

Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com

1

1 THE UNITED STATES DISTRICT COURT

2 FOR THE NORTHERN DISTRICT OF ALABAMA

3 SOUTHERN DIVISION

4

5 CLAUDIA BALCERO GIRALDO,

6 et al.

7 Plaintiffs

8 vs. Case No. 2:09-cv-1041-RDP

9 DRUMMOND COMPANY, INC.,

10 et al.

11 Defendants

12 ___________________________/

13

14

15 The Letters Rogatory Video Hearing in the

16 above-titled matter, as translated by Guiomar Emedan-

17 Lauten and Maria Kisic, Interpreters, was held on

18 Monday, March 12, 2012, commencing at 9:10 a.m., at

19 the Third Circuit Criminal Court of Valledupar,

20 Colombia, before the Honorable Judge Alfonso Tatis and

21 Steven Poulakos, Notary Public.


2

1 APPEARANCES:

2

3

4 ON BEHALF OF THE PLAINTIFFS:

5 TERRENCE P. COLLINGSWORTH, ESQUIRE

6 LORRAINE LEETE, ESQUIRE

7 FRANCISCO RAMIREZ CUELLAR, ESQUIRE

8 Conrad & Scherer, LLP

9 1156 15th Street, N.W., Suite 502

10 Washington, D.C. 20005

11 Telephone: 202-543-4001

12 Facsimile: 866-803-1125

13 Email: [email protected]

14

15

16

17

18

19

20

21 (APPEARANCES CONTINUED on the Next Page.)


3

1 APPEARANCES CONTINUED:

2

3 ON BEHALF OF THE DEFENDANTS:

4 WILLIAM H. JEFFRESS, JR., ESQUIRE

5 BRYAN PARR, ESQUIRE

6 TONY DAVIS, ESQUIRE

7 JOSE MIGUEL LINARES, ESQUIRE

8 Baker Botts, LLP

9 1299 Pennsylvania Avenue, N.W.

10 Washington, D.C. 20004

11 Telephone: 202-639-7700

12 Facsimile: 202-639-7890

13 Email: [email protected]

14

15

16 ALSO PRESENT: JOHN SHERMAN, Videographer

17 GUIOMAR EMEDAN-LAUTEN and

18 MARIA KISIC, Interpreters

19 and

20 GREGORIO ALVEAR PALOMINO, ESQUIRE

21


4

1 INDEX

2 Letters Rogatory Hearing

3 March 12, 2012

4

5 Witness: ALCIDES MANUEL MATTOS TABARES, alias SAMARIO

6

7 Examination By: Page

8 Mr. Collingsworth 10

9 Mr. Jeffress 78

10 Mr. Collingsworth 157

11 Mr. Jeffress 166

12

13 Plaintiffs' Exhibit No. Marked

14 Exhibit 1 A Declaration 22

15 Exhibit 2 A Photograph 34

16

17 Defendants' Exhibit No. Marked

18 Exhibit 2 Testimony on April 23, 2009 102

19 Exhibit 3 A Disk 136

20 Exhibit 4 A Disk 156

21


5

1 PROCEEDINGS

2 THE COURT: We are about to begin. We have

3 just started in the Court and we will proceed in the

4 following manner. First, we will identify the witness

5 Manuel Alcides and we will ask for his address, his

6 place of residence, et cetera.

7 Please stand up to identify yourself.

8 THE WITNESS: My name is Manuel Alcides --

9 Alcides Manuel Mattos Tabares, alias Samario, and my

10 cedula number is 84.082.05.28. I am from Rio Hacha. I

11 am currently in the jail of Valledupar.

12 MR. JEFFRESS: Your Honor, may I object.

13 There seems to be another camera in the courtroom.

14 Perhaps I'm not sure who. The news media? May we ask

15 that they be excused?

16 THE COURT: I believe --

17 THE INTERPRETER: My name is Mr. Rosedo

18 from RPT News, Channel 12 TV in Valledupar.

19 THE COURT: I believe that this is a

20 proceeding that is not private. Counsel?

21 MR. JEFFRESS: Our understanding was that


6

1 it was private, that this proceeding would be only for

2 the parties and for the personnel that are necessary.

3 THE COURT: What do Plaintiffs say? What

4 does the other party say?

5 MR. COLLINGSWORTH: We have no objection to

6 this being an open proceeding, Your Honor.

7 THE COURT: We will not accept it because

8 the gentleman is undertaking the duties of a legal

9 profession and he has a duty to inform the citizens.

10 So we will let him remain.

11 MR. JEFFRESS: Very well.

12 THE COURT: As agreed first we will have

13 instructions from Plaintiff and then from the other

14 party. So, please, begin introducing each of counsel.

15 MR. COLLINGSWORTH: Good morning, Your

16 Honor. My name is Terry Collingsworth and I'm counsel

17 for the Plaintiffs in this matter. I wanted to thank

18 you for your flexibility in letting us invade your

19 courtroom and we're going to do our best to make this

20 an efficient procedure.

21 With me I have Lorraine Leete who is my


7

1 co-counsel and Francisco Ramirez Cuellar who is my

2 co-counsel.

3 THE COURT: Could Defendants, please, state

4 their names for the record, those that are accredited

5 to -- for part of these proceedings.

6 MR. PALOMINO: Gregorio Alvear Palomino.

7 MR. JEFFRESS: William Jeffress for the

8 Defendants.

9 MR. DAVIS: I'm Tony Davis for the

10 Defendants.

11 MR. PARR: Bryan Parr for the

12 Defendants.

13 MR. LINARES: Jose Linares.

14 THE COURT: Thank you.

15 As and in compliance with the legal

16 assistance for international proceedings and as we

17 have agreed we will follow the following order of

18 proceedings: Initially Plaintiff will be

19 interrogating the witness and then we will afford an

20 opportunity for cross to the Defendants. Initially

21 we will swear in the witness.


8

1 Whereupon,

2 ALCIDES MANUEL MATTOS TABARES, alias SAMARIO,

3 called as a witness, having been first duly sworn to

4 tell the truth, the whole truth and nothing but the

5 truth, was examined and testified as follows:

6 THE COURT: But since we are swearing in

7 this witness and since these depositions are taking

8 place here in Colombia I believe it is fitting to

9 provide the due warnings for testimony that we normally

10 would use here in this country.

11 But according to our legislation anyone

12 testifying before Court and is sworn to say the

13 truth in any judicial proceeding you are not

14 compelled to testify against yourself, against your

15 spouse, against anyone related to you until the

16 fourth generation.

17 And if you are sworn to say the truth

18 before the competent authorities and you do not,

19 this conveys a penalty of 6 to 12 years of jail

20 time.

21 Considering the above do you swear to


9

1 say the truth and only the truth?

2 THE WITNESS: Yes, I do.

3 THE COURT: So we now afford this space to

4 plaintiff if they would like to interrogate the

5 witness.

6 MR. COLLINGSWORTH: Thank you, Your Honor.

7 We'll begin. Our videographer needs to read a

8 paragraph that formalizes the proceedings for our

9 court.

10 THE COURT: Perfect.

11 THE VIDEOGRAPHER: We're now on the

12 record in the matter of Claudia Balcero Giraldo,

13 et al., versus Drummond Company, Incorporated,

14 et al., in the United States District Court for the

15 Northern District of Alabama, Southern Division,

16 Case Number 2:09-cv-1041-RDP. Today's date is March

17 12th, 2012. The time is approximately 9:14 a.m.

18 This is the video-recorded deposition of

19 Alcides Manuel Mattos Tabares being taken at the

20 Third Circuit Court of Valledupar, Colombia.

21 My name is John Sherman here on behalf


10

1 of Gore Brothers Recording and Videoconferencing.

2 With me is the court reporter Steve Poulakos from

3 Gore Brothers.

4 EXAMINATION BY MR. COLLINGSWORTH:

5 Q Mr. Mattos, good morning. I'm going to ask

6 you a series of questions about some of the events that

7 occurred while you were a member of the AUC. Is that

8 okay?

9 A Yes.

10 Q And you are in the justice and peace

11 process here in Colombia; is that correct?

12 A Yes.

13 Q So in addition to the oath you took this

14 morning, does the justice and peace process also

15 require you to tell the truth?

16 A Yes. This is a commitment we made after

17 the demobilization.

18 Q Can I ask you to, please, give us a history

19 of your participation in the AUC?

20 A Yes, of course. I joined the AUC in 1997

21 where I was a militant for the AUC under the Central


11

1 Bloc Bolívar with the now extradited Macario. That was

2 his alias when he was active.

3 Q And after that?

4 A I was there until 1999 in the BCB as we

5 called it or as it was known then. I was a militant of

6 the Juan Andrés Álvarez Front and I was a militant or a

7 participant in the Auto defensas under Jorge Cuarenta,

8 Jorge Forte.

9 I was there until mid-2000 until my capture

10 or until the date of the demobilization which occurred

11 in March 11th, 1996.

12 Q Is it -- there must be either a translation

13 issue or let's ask for a correction.

14 When did the demobilization occur?

15 A March 11th, 2006.

16 THE VIDEOGRAPHER: Can I ask the

17 interpreter to wear the microphone.

18 BY MR. COLLINGSWORTH:

19 Q Can you, please, tell us more about what

20 positions you held while you were in the Northern Bloc?

21 A I joined the forces as an escort for


12

1 Commander Tolemaida, T-O-L-E-I-M-A-I-D-A [sic], who was

2 a commander with the forces then. I was chief of the

3 security for the commander of the front until the year

4 2002.

5 So precisely I was the chief of security

6 until May of 2002 when I was first captured by the

7 Colombian authority in Becerril, Cesar,

8 B-E-C-E-R-R-I-L, Cesar, C-E-S-A-R. Then that year

9 until December 10th, 2002 I came back and I took up the

10 position that had been granted me and I was there until

11 January of 2003 with those responsibilities for the

12 front.

13 I was the commander of the Urbanos groups,

14 U-R-B-A-N-O, and I was a commander for rural groups in

15 the Becerril municipality. Becerril, B-E-C-E-R-R-I-L.

16 Q Can I ask you a clarifying question.

17 Before you -- May 2002 you were captured, but you were

18 working with the Juan Álvarez Front. When did you

19 start working for the Juan Alvarez Front?

20 A I joined the Northern Bloc in the second

21 half of the year 2000. I don't remember exactly, but


13

1 it was the second semester of the year 2000, between

2 August and September of the year 2000. The Northern

3 Bloc.

4 Q And then I interrupted you. You got out

5 and in 2002 you took a different position with the Juan

6 Alvarez Front; is that correct?

7 A Yes. I then took up a position as a

8 commander of the Urbanos group and also the rural

9 groups in the highlands of the Becerril municipality.

10 I was also commander in the municipality of La Jagua de

11 Ibirico, L-A, one word, Jagua, J-A-G-U-A, one word,

12 D-E, one word, Ibirico, I-B-I-R-I-C-O. I -- that was a

13 part of the Codazzi municipality, C-O-D-A-Z-Z-I, and

14 the municipality of El Paso and a part of the

15 subdivision municipality, subdivision of La Loma.

16 Q During this entire time with the Juan

17 Alvarez Front was Tolemaida your commander?

18 A Yes, of course.

19 Q Do you know his full name?

20 A Ospino Pacheco. Yes, I found out during

21 the justice and peace process. His name is Oscar Jose


14

1 Ospino, O-S-P-I-N-O, Pacheco, P-A-C-H-E-C-O.

2 Q What was your understanding of what the job

3 of the Urbanos was?

4 A Well, we at the AUC qualified or described

5 the Urbanos as what they were. They were groups of hit

6 men, you know, in charge of being hit men in the urban

7 areas of certain municipalities. That is what they

8 were.

9 Q By hit men you mean executioners?

10 A Yes, exactly.

11 Q And you were the head of the Urbanos?

12 A Yes. During -- for a while I was the head

13 of the Urbanos at the front.

14 Q Can you tell us precisely when you were the

15 head of the Urbanos?

16 A From January 2003 until April 2005.

17 Q What responsibilities did being the

18 commander of the Urbanos give you?

19 A Well, you know, as any commander, the AUC,

20 we had guidelines, you know, from the central command

21 for the bloc and for the AUC.


15

1 I, as a commander, had the responsibilities

2 of, in the areas where there were subversives, to

3 execute it, to put it in this way. You know, as

4 responsibilities we were in charge of going to the

5 rural areas -- I'm sorry, to the urban areas and to

6 clean out the areas of subversives because we were in

7 an all-out war here in Colombia during the conflict.

8 Q Why did you join the AUC?

9 A Well, it is no secret that this is a very

10 unequal country, you know, very poor with lack of

11 resources and inequality. So I joined the Colombian

12 Army as a young man when I was very young and I liked

13 it.

14 I always wanted to be in the military but

15 was not able to do so for lack of let us say resources.

16 And for a while I acted, you know, outside the Army or

17 I was not a part of the Army. I sought jobs and

18 unfortunately was not able to find one. Unfortunately

19 the AUC gave me a job.

20 So I joined the AUC because, you know, let

21 us say they gave me a job back then and I lasted all


16

1 the time that I lasted because, you know, of the

2 inequalities that there are in this country.

3 Q When you joined the AUC was there -- did

4 you believe there was a civil war going on?

5 A Yes, of course. When I was a part of the

6 military forces I was a soldier and I was a part of the

7 Army struggling against the subversives.

8 And, of course, not on an equal footing

9 because at the AUC we could not fight the subversives

10 in the same way that the AUC would. So a large part of

11 what I saw while I was a member of the AUC was just

12 like being in the Army.

13 THE INTERPRETER: Could the interpreter ask

14 the witness to repeat the previous comments?

15 MR. COLLINGSWORTH: Yes, of course.

16 Or I can ask another question.


18 Q Was there a difference in the way that the

19 military fought -- let's have a -- strike that.

20 How long were you in the actual military?

21 A I was there, I don't remember exactly, but


17

1 about three years.

2 Q Was there a difference in the way the

3 military could fight the subversives versus the way the

4 AUC would fight the subversives?

5 A Yes, of course, there was a difference.

6 And I learned in all of the years that I was here in

7 the conflict in Colombia that there is no worse spine

8 than that coming out of the same stem. We operated in

9 the same way that they operated. And I can even say

10 that a lot of the military and even public forces

11 supported us.

12 Q When you joined the AUC you were former

13 military, do you know if that was common, were there

14 lots of former military who joined the AUC?

15 A Yes. When I joined, one of the

16 requirements in order to join the AUC was to be a

17 reservist or to have been a part of the military.

18 Q And you said that you could fight the same

19 as them which was unclear. By them do you mean the

20 subversives or the regular military?

21 A No. Just like the subversives of course.


18

1 Q And what -- what do you mean by that?

2 A Well, let's say that in any military force

3 in any country they are governed by international

4 regulations and human rights and so on. We were not

5 governed by this.

6 When they captured someone they would make

7 them available to the competent authority, but we would

8 not capture them. We would either put them down or we

9 would assassinate them, as we would say.

10 Q Did you view yourself when you were in the

11 AUC as fighting on the same side as the military?

12 MR. JEFFRESS: Objection, form.

13 THE WITNESS: Yes. And that is what I saw

14 for the time that I was there at the AUC.


16 Q What did you see while you were at the AUC?

17 What do you mean?

18 A Well, you know, it is no secret I was a

19 soldier and I don't like to speak ill of the military,

20 but, you know, we -- they had a lot of contact with me,

21 you know. And we worked together in several operatives


19

1 where a lot of people died, you know. And as a matter

2 of fact we would go into new areas or new zones and

3 they would lend us the arms with which we would kill

4 people.

5 Q Mr. Mattos, do you remember giving me a

6 signed statement a while ago?

7 A Yes, of course.

8 MR. COLLINGSWORTH: Your Honor, may I

9 approach the witness to show him a statement?

10 THE COURT: Yes.

11 MR. COLLINGSWORTH: And, Your Honor, may I

12 approach to give you a copy?

13 THE COURT: Yes, you can.

14 MR. COLLINGSWORTH: If I could ask the

15 translator for a little help. There is an English

16 translation at the outset and then it is the original

17 Spanish.


19 Q Is that your signature at the bottom of the

20 Spanish page which is marked 084 in our document

21 numbering system?


20

1 A Yes, of course, it is my signature.

2 Q And can you read the date of your

3 signature?

4 A It's on the 4th day of December of 2009 in

5 the medium security prison of Valledupar, Colombia.

6 Q And do you remember on the day signing this

7 statement and putting your thumb print there?

8 A Yes, of course, I do remember.

9 Q Now, could I ask you -- again recognizing

10 that you speak Spanish and I speak English we will have

11 to take this slow. The Spanish version begins on page

12 078 of our numbering system and it goes through page

13 084. Could you review this at your own pace just so

14 that I could ask you if this is actually the statement

15 that you signed?

16 A Yes.

17 (Witness reviewing document.)

18 Q Have you finished your review of the

19 document, Mr. Mattos?

20 A Yes.

21 Q Is that the statement that you provided me


21

1 and signed on December 4th, 2009?

2 A Yes, yes.

3 Q Now, after the actual declaration there's a

4 long list of names. Can you, please, look at that and

5 tell me if you can identify that?

6 A (Witness reviewing document.)

7 This is the same one. It's been repeated.

8 Q Do you recognize that list?

9 A Yes, of course.

10 Q Could you tell me what the list is?

11 A That is the informational platform that the

12 ones -- according to Law 975, the postulated ones that

13 work with that, the facts that are attributed to us,

14 the front that I belong to, which are disappearances

15 and killings.

16 Q So it's a list of disappearances and

17 killings that you admitted to; is that correct?

18 A Yes, almost all of them. Well, yes, almost

19 all of them. I did not participate in all, but, yes,

20 almost all of them. These are facts attributed to the

21 Front Juan Alvarez.


22

1 MR. COLLINGSWORTH: I would move to admit

2 into evidence this document which we have marked

3 Plaintiffs' Exhibit 1 which Mr. Mattos has identified.

4 (Plaintiffs' Exhibit 1 was marked for

5 purposes of identification.)

6 MR. JEFFRESS: Objection.

7 MR. COLLINGSWORTH: And what's your

8 objection?

9 MR. JEFFRESS: No foundation of personal

10 knowledge, hearsay, no authentication of the document.

11 THE COURT: But I think that that has to

12 maybe referenced to Letters Rogatory that the witness

13 has to be heard. And according to such Letters

14 Rogatory, the examination is to be done in accordance

15 with jurisdictional law of the country of Colombia.

16 And according to that document there has

17 been -- the examination of how such questions are to

18 be posed in accordance with the Letters Rogatory and

19 with the international legal assistance.

20 So even if that has been the case and

21 those questions have been posed and are in


23

1 accordance with the jurisdiction of the authorities

2 that allow for that posing of the questions we

3 cannot go beyond that screening in our own

4 jurisdiction. Those Letters Rogatory do not ask of

5 us any more than to swear to witness. However, this

6 Court does consider that.

7 According to what it implies, that --

8 those Rogatory Letters, the trial will take place in

9 August and, therefore -- and then in that procedure

10 then they will be able to present any type of

11 evidence, exclude evidence, or do anything pertinent

12 that is in accordance with such jurisdiction.

13 Therefore, this Court believes that any

14 type of objections that is done to any questioning

15 posed to the witness are within the scope of the

16 jurisdiction that is asking such questions; and they

17 do not represent any foundational objections in

18 accordance to this Court. Unless the question is

19 superfluous, is misleading, it's not clear, and

20 other types of questions that are not well posed.

21 And any type of other procedure, legal procedure


24

1 that the witness had to undergo have already been

2 done.

3 Therefore, any objection is to be posed

4 and set forth within any type of procedure that will

5 be done in the United States. And the witness must

6 answer it, please.


8 That's fine. We are just making our record and we'll

9 move on.

10 MR. JEFFRESS: If the Court please, if I

11 understand the Court's ruling, although I must make

12 objections in order to present them to the Court of the

13 United States.

14 THE COURT: With all due respect, yes, I

15 admit for you and accept for you to do your objections.

16 However, I will not resolve them for you.

17 MR. JEFFRESS: I understand.

18 THE COURT: Even though the faculty within

19 those Letters Rogatory have not been set forth, such

20 faculty for me to resolve them. Therefore, it is very

21 clear and described therein that you can pose such


25

1 objections. And there will be a record of them so they

2 can be resolved by a competent jurisdiction in the

3 United States.

4 MR. JEFFRESS: Very good. Thank you, Your

5 Honor.

6 MR. COLLINGSWORTH: If I may might add, and

7 then we'll move on, Counsel and I have agreed that we

8 reserve all objections to make later so that we can

9 continue with the proceedings without interpreting

10 objections.

11 THE COURT: We agree.


13 Q Mr. Mattos, can I ask you again to look at

14 pages 78 to 84 which you have reviewed? And is that

15 what you just reviewed?

16 A Yes.

17 Q Is everything in that statement true?


19 Q Thank you.

20 Mr. Mattos, we'll put the document aside

21 for now. I want to ask you some other questions.


26

1 What was the first time you recall meeting

2 with anyone to discuss doing some operations with

3 Drummond?

4 A I remember that it was I think in November

5 of the year 2000. Exactly it was -- well, it was in La

6 Loma de Potrerillo. And that should be L-A, one word,

7 L-O-M-A, Potrerillo, P-O-T-R-E-R-I-L-L-O.

8 Q And who did you meet with?

9 A At that time I was a security chief of

10 Tolemaida of the front -- Front Juan Alvarez and Jaime

11 Blanco Maya was present in that meeting as well.

12 Q Do you know who Jaime Blanco Maya was?


14 THE INTERPRETER: And for the Court

15 Reporter Blanco, B-L-A-N-C-O, Maya, M-A-Y-A.


17 Q Can you tell us?

18 A At that time, well, he was a contractor

19 with Drummond. He had the contract for the food there

20 at Drummond. And he was the half brother of

21 ex-attorney general of Colombia Edgardo Maya.


27

1 Q What was discussed at this meeting?

2 MR. JEFFRESS: Objection to the lack of

3 foundation.

4 THE WITNESS: Well, initially that meeting

5 took place in what we call a casino. And it's the

6 dining room in Potrerillo. Another person was there

7 present as well.


9 Q Who was the other person? Let me ask, who

10 was the other person present?

11 A Jairo Jesus Charrez Castro.

12 THE INTERPRETER: And Jairo is J-A-I-R-O,

13 D-E, one word Jesus, J-E-S-U-S, Charrez, C-H-A-R-R-E-Z,

14 Castro.

15 MR. COLLINGSWORTH: I-S. C-H-A-R-R-I-S.

16 THE INTERPRETER: Thank you. Castro,

17 C-A-S-T-R-O. Thank you.


19 Q So there was a meeting and you've

20 identified Tolemaida, Jaime Blanco Maya, and Charris,

21 and yourself. Was there anyone else there?


28

1 A No, I don't remember at this time.

2 Q And the meeting was in what you call the

3 casino. Can you describe that for us?

4 A Yes. At that time the casino was not

5 within the facilities of the multinational, but it was

6 outside in the outskirts of the subdivision of the

7 municipality of La Loma. We call it here Obra Negra.

8 THE INTERPRETER: And that should be

9 O-B-R-A, Negra, N-E-G-R-A.

10 THE WITNESS: But that means it's under

11 construction. It was an open space. I remember at

12 that time there were like some mango trees, actually

13 small ones. It was thereabout a church and also there

14 was the police station thereabout.

15 It has some Rima brand chairs, R-I-M-A.

16 There were some white plastic chairs. I remember that

17 who came to receive us was Jairo de Jesus Charris

18 Castro at the entrance of such casino. He came in and

19 he called Mr. Jaime Blanco Maya. I remember that Jaime

20 Blanco came out and he was already waiting for us.



29

1 Q Do you know what the function of this

2 casino was?

3 A Well, as far as I know it's one that

4 supplied the food to the multinational.

5 Q When you say multinational what are you

6 referring to?

7 A To multinational Drummond.

8 Q What happened at this meeting?

9 A At that time, well, we had, well, issues.

10 We had issues with the union leaders of the

11 multinational Drummond.

12 Q Let me -- let me get a clarification. When

13 you say we, what are you referring to?

14 A Well, there were problems between the

15 Drummond multinational and the union leaders.

16 Q Someone told you this at that meeting?

17 A Yes, of course, was there Jairo de Jesus

18 Charris Castro who was a pretty good friend of mine at

19 that time. And, of course, I was the chief of security

20 of the Tolemaida. And, of course, I have to find out

21 what's going on.


30

1 Q So tell us what was discussed at the

2 meeting.

3 A The union leaders were on the verge and on

4 the works of doing a strike at Drummond because they

5 had issues with the food, the bad quality of the food.

6 And let's say this would generate losses for the

7 multinational. And like in previous years there was an

8 agreement between the --

9 THE INTERPRETER: The interpreter needs

10 repetition.

11 THE WITNESS: There was an agreement

12 between the multinational and the AUC with the, at that

13 time, ex -- the outgoing chief of the AUC was -- his

14 name was Jhon -- Jhon Jairo whose alias is El Tigre.


16 Q Again, you used the word multinational.

17 What are you referring to?

18 A Drummond is the multinational.

19 Q Could I ask so that the record is clear,

20 since there are other multinationals operating in that

21 area that if you mean Drummond to, please, say


31

1 Drummond?

2 A Okay, no problem.

3 Q You mentioned that there had been a prior

4 agreement between Drummond and El Tigre. What did you

5 know about that?

6 A So I can't speak for the time while El

7 Tigre was operating because I was not in that area, but

8 he is the one who has knowledge of the initial

9 agreement that there was between multinational Drummond

10 and the AUC, of course. I know of what happened after

11 El Tigre was captured when I joined the Front Juan

12 Andrés Álvarez. But I have knowledge because Tolemaida

13 the ex-commander had a direct link with Jaime Blanco

14 and other officials at the multinational from the time

15 when Alias El Tigre was there.

16 Q And, again, you mean Drummond when you say

17 multinational?

18 A Yes, Drummond.

19 Q So we can all be clear, El Tigre was the

20 commander of the Juan Alvarez Front and then Tolemaida

21 took over for him. Is that what you said?


32

1 THE INTERPRETER: Could Counsel repeat that

2 for the Interpreter?

3 MR. COLLINGSWORTH: Yes, of course. I'm

4 asking him if what he said was if El Tigre was the

5 commander of the Juan Alvarez Front and then Tolemaida

6 took over for El Tigre at some point.

7 THE WITNESS: Yes, of course.


9 Q So you were describing a meeting that you

10 were having with Tolemaida, Jaime Blanco, and Charris,

11 and yourself. And it was -- and you mentioned that

12 there had been a prior agreement; is that right?


14 Q Was that discussed by anyone at this

15 meeting we're referring to?

16 A No, it wasn't mentioned at that specific

17 meeting because these were prior agreements. There

18 was, therefore, no need for them to be mentioned right

19 then and there.

20 Q So you have told us that at this meeting

21 there was a discussion of the problems with the


33

1 Drummond union; is that correct?

2 A Yes, of course.

3 Q Was there any outcome of the meeting?

4 A Well, you know, the results are

5 self-evident. You know, almost the entire leadership

6 of the union was murdered and not precisely for their

7 subversive ideals.

8 Q What -- what do you mean by that?

9 A The union leaders were a problem for the

10 Drummond multinational. And since we were the gray or

11 the dark part of the state, the ones who were able to

12 kill, so our services were sought as it had been done

13 before for us to murder or assassinate the union

14 leaders.

15 Q You said this meeting occurred in late

16 2000; is that correct?

17 A Yes, in November of the year 2000.

18 Q Was there another meeting after that where

19 the same topic was discussed?

20 A (Speaking Spanish).

21 Q Can you tell us about that meeting?


34

1 A Yes, of course.

2 Yes, that occurred outside the facilities

3 of the Drummond multinational, exactly right in front

4 of the entrance where there was myself, then Tolemaida,

5 an escort for Tolemaida, alias Kener, K-E-N-E-R, and a

6 Drummond official Alfredo Araújo, A-R-A-U-J-O.

7 Q And you were there?

8 A Yes, of course.

9 MR. COLLINGSWORTH: Your Honor, may I

10 approach the witness and show him an exhibit?

11 THE COURT: Yes, of course.

12 (Plaintiffs' Exhibit 2 was marked for



15 Q Mr. Mattos, I've handed you a document

16 marked Exhibit 2. It's a photograph. Can you identify

17 who is in that photograph?


19 It's blurry, but this is Alfredo Araújo.

20 Q This is the same Alfredo Araújo who was at

21 the meeting you described?


35

1 A Yes, of course.

2 Q Tell us what was discussed at this meeting

3 with Mr. Alfredo Araújo present.

4 A Well, you know, I remember that it was not

5 a long meeting because, you know, it happened outside

6 on the side of the road of the Drummond multinational.

7 And, you know, practically speaking it was to make

8 clear the final details and to get the last word so we

9 could begin the series of killings of the union

10 leaders.

11 Q Do you remember anything that Mr. Araújo

12 himself said at this meeting?

13 A I don't remember well, but I know that they

14 were waiting for word of the higher top executives of

15 the Drummond multinational to begin with the operations

16 in order to do away with all of the union leaders for

17 Drummond. So let me just remind you that where the

18 union leaders were killed they were not killed by just

19 one front. So, you know, we had to specify details to

20 cooperate -- you know, a cooperation between both

21 fronts.


36

1 Q So at this meeting did you learn that you

2 had approval to conduct the operation?

3 A Yes, of course. Tolemaida told me so.

4 Q Now, did -- prior to this meeting did you

5 know who Alfredo Araújo was?

6 A No, no, before the meeting I did not know

7 who Alfredo Araújo was.

8 Q At the meeting did you come to an

9 understanding of who he was?


11 Q And what was that understanding?

12 A Well, at the meeting right then and there

13 Tolemaida did not tell me who exactly he was. He told

14 me later. He told me then that I believe he was chief

15 of staff or something like this, chief of personnel.

16 And that he was Alfredo Araújo from the Araújo family

17 here in Valledupar.

18 Q You said chief of staff or something,

19 you're not clear. But of what? What was his position?

20 A Excuse me, mine or Alfredo Araújo?

21 Q Alfredo Araújo, do you know what company or


37

1 what -- what organization that he worked for?

2 A Okay. Yes, he worked for the -- for

3 Drummond the multinational. And, you know, exactly

4 what his position was I can't remember it right now,

5 but it was something I believe like chief of personnel

6 for Drummond multinational.

7 Q You earlier mentioned the Northern Bloc and

8 Jorge Forte. Who is Jorge Forte?

9 A Jorge Cuarenta was the commander of the

10 Northern Bloc of the AUC. Initially the bloc was

11 commanded by Salvatore Mancuso. And in 2002 Jorge

12 Cuarenta then assumed the position of being commander

13 of the Northern Bloc of the AUC, for the entire bloc.

14 Q Do you know if he had a relationship with

15 Alfredo Araújo?

16 A Well, if Drummond the multinational had an

17 agreement with the AUC, then Alfredo Araújo did so too.

18 I don't know about Jorge Cuarenta's childhood, but I

19 have heard that they have been friends since they were

20 children. So I did not know personally of the

21 relationship between Jorge Forte and Alfredo Araújo.


38

1 This is what I hear.

2 Q Thank you.

3 Now, after this meeting you've described

4 where Alfredo Araujo was present and there was you and

5 Tolemaida and Kener, was there anyone else there?

6 A No, nobody else.

7 Q What happened after this meeting?

8 A And I was not present but I knew of several

9 many other meetings between the AUC's and Alfredo

10 Araujo, Jaime Blanco, and, you know, held here in

11 Valledupar El Portal Del Valle.

12 THE INTERPRETER: E-L, one word, Portal,

13 P-O-R-T-A-L, one other word, D-E-L, one other word,

14 V-A-L-L-E.

15 THE WITNESS: And then after this the

16 murders of the union members happened. Orcasita and

17 Locarno, I remember these were their last names.


19 Q Let's go back a moment to these other

20 meetings. You identified a building called El Portal

21 Del Valle. What is that? What are you describing


39

1 there?

2 A I don't know it, but El Portal Del Valle

3 they this say this is the building where the

4 headquarters of the Drummond multinational are located.

5 So that is why I say that I was not present, but there

6 were other meetings held at that building where members

7 of the AUC were present. And, you know, there was a

8 patrolman, you know, but let's just say he was a member

9 of the AUC who was within or he was infiltrated into

10 Drummond. And he would work there so that he could

11 report on the movements of people that were suspected

12 to be subversives within Drummond. It was

13 Mr. Aristides Peinado.

14 Q Can you spell that, please?

15 A P-E-I-N-A-D-O.

16 Q Who was Peinado?

17 A He was the person who was within Drummond

18 bringing information to the Juan Andrés Álvarez Front.

19 So let us say this was a person who had a job at

20 Drummond as a subcontractor I believe, but he was

21 really a member of the AUC. And he effectively didn't


40

1 work there, but let us say that he was inside bringing

2 information. So he was the man within the facilities

3 of the Drummond.

4 Together with Jairo de Jesus Charris Castro

5 they were pretty close with the executives of the

6 Drummond multinational. So since they couldn't hold

7 meetings periodically, you know, between Drummond

8 executives and the commanders of the front they were

9 the people who were inside.

10 Q Did Peinado himself give you information?

11 A Yes, of course. We were militants in the

12 same front. So since I was the person that was chief

13 of security for Tolemaida I took information to

14 Tolemaida. I was, you know, the one who received

15 communications from, say, Peinado or Charris, and I

16 would bring the information to Tolemaida.

17 Q Now, let's go back to these meetings that

18 were held in the Drummond headquarter's building in

19 Valledupar. You said you weren't at those meetings,

20 but you knew about those, correct?

21 A Yes, I did know about the meetings because


41

1 of the information that Aristides Peinado and Charris

2 would pass on to the commander of the front.

3 Q What do you know about those meetings as

4 you received this information?

5 A What I remember most right now was a

6 payment that Drummond the multinational made to the

7 AUC, you know, to the Juan Andrés Álvarez Front for the

8 murder of the union members.

9 Q Who told you about the payment?

10 A Aristides Peinado and Jairo de Jesus

11 Charris, even Tolemaida himself.

12 Q When Tolemaida discussed this payment with

13 you did he then give you some direction as a result of

14 this information?

15 A Well, you know, he didn't have to give me

16 instruction. You know, he was the commander of the

17 front. He would just make comments to me and tell me

18 because there was a lot of trust between us.

19 Q What did he tell you?

20 A Yes. I remember that he told me that

21 because of the payments by Drummond the front was going


42

1 to develop to grow. You know, he said from now on the

2 front is going to definitely grow because Drummond will

3 be paying more. And from now on we will be able to buy

4 more arms and to have more people.

5 Q When did the union murders occur in

6 relation to that discussion?

7 A About two or three months after.

8 Q The union murders were after the

9 discussion; is that correct?


11 Q Tell us what you can about -- you mentioned

12 two names before Locarno and Orcasita. Tell us what

13 you can about their murders.

14 A They were the president and vice president

15 of the union of the Drummond multinational. And they

16 were the main people that had to be murdered because

17 they were trying to lead and create a strike within the

18 company.

19 Okay. In order to put an end to the strike

20 or to stop the strike from happening, you know, these

21 were the people that had to be targeted because they


43

1 were the ones in charge of leading the workers within

2 Drummond for the union.

3 Q Did you participate in any way in the

4 executions of Locarno and Orcasita?

5 A Well, I wasn't exactly the one who pulled

6 the trigger, but I did -- I was a part of the events.

7 Q Tell us what your role was.

8 A Let us say that since I was the head of

9 security I was lent or I borrowed Adinael who was the

10 head of the Urbanos -- Adinael, A-D-I-N-A-E-L, of the

11 Urbanos, U-R-B-A-N-O-S -- and of the leaders of the

12 Juan Andrés Álvarez Front which was in the area of

13 where Drummond was. So with the Urbanos there is never

14 a specific person. Anyone within them can assassinate,

15 but, you know, I was a part of the entire operation

16 being that I dealt with security.

17 And within the operation itself, as I said

18 before I was not the one to pull the trigger to murder

19 the union members. But once again let me say that I

20 was part of the criminal act that was undertaken then

21 where the two union members were murdered. And so I


44

1 was even the person who first got onto the bus.

2 Q Were you convicted here in Colombia for

3 your role in the murders of Locarno and Orcasita?

4 A Yes, of course.

5 Q Tell us what you can recall about how they

6 were killed.

7 A Well, let us say that what I remember is

8 that we left the municipality called Baden, B-A-D-E-N,

9 with Magdalena, M-A-G-D-A-L-E-N-A, in two trucks, one

10 green, one wine colored, and I remember one of them was

11 a Ford.

12 THE INTERPRETER: The interpreter needs to

13 make a correction. Badelco, B-A-D-E-L-C-O, is the

14 municipality.

15 THE WITNESS: I did not know then when we

16 started out that this was going to be the time when we

17 were going to assassinate the two union members, but

18 then I knew that this was going to be as we later

19 called it the operation for the killing of the

20 president and vice president of the union for Drummond

21 the multinational.


45

1 Let me just clarify. I didn't know

2 right then and there that this was going to be the

3 time when the union members were going to be killed,

4 but I knew of course from before that the operation

5 in order to murder the union members was to take

6 place.

7 We left Badelco and we went to the

8 subdivision of the municipality called Cuatro

9 Vientos. C-U-A-T-R-O. Vientos, V-I-E-N-T-O-S. We

10 waited there for our communication between a person

11 that I don't know who it was and Adinael via phone

12 of course.

13 After that near Zinc, which is a -- like

14 a village -- after that call that was made we

15 intercepted the buses. I remember that we passed

16 them through like a pathway, a pathway that goes by

17 Zinc. I got on the bus first, the bus that

18 transported the union members and other workers.

19 I believe that they made me get off the

20 bus, the Commander Adinael, and he sent me to the

21 rear of the bus. It was like a short discussion in


46

1 the bus and they got out, a man, a gentleman. He

2 was taken towards the green truck that had the

3 windows -- the windows were pretty darkly tinted.

4 There was a person there who was

5 recognizing the union members. I believe that there

6 was a mistake because they took the man back into

7 the bus. That's how I perceived it. Then they got

8 another one off the bus. And there was another one

9 that was armed who was in the bus, but I think he

10 objected and he was killed right then and there.

11 I remember that the other one was taken

12 to this subdivision of the municipality Badelco

13 Magdalena where alias Tolemaida was at. I don't

14 know what they spoke about. I -- I moved away. And

15 after that he was killed and he was left at Loma

16 Linda or Loma Colorada, if I'm not mistaken. And

17 Loma Linda is L-O-M-A, Linda, L-I-N-D-A or Loma,

18 L-O-M-A, Colorada, C-O-L-O-R-A-D-A. This was in the

19 afternoon hours. This is I what more or less

20 remember.

21 Q Do you know which of the union leaders was


47

1 the one who was armed on the bus?

2 A No, I don't remember who it was.

3 Q Who else was on the crew with you that

4 conducted this operation?

5 A I remember that Peinado was there,

6 Aristides Peinado, alias Yuca. Alias Yuca, Peinado

7 Yuca. And then El Borri if I will remember. I don't

8 know if it was El Borri or El Boca. And those are the

9 ones that I remember more or less at this point in

10 time.

11 THE INTERPRETER: El Borri, E-L B-O-R-R-I.

12 That's phonetically according to the interpreter or El

13 Boca, E-L B-O-C-A, two words.


15 Q Are you aware of any cooperation that

16 occurred with your operation by the -- either the

17 military or the police in the area?

18 A No, I don't know. I don't remember. I

19 don't rule out that that happened, but I did not -- was

20 not present in that.

21 Q Do you remember roughly when these killings


48

1 occurred of the first two union leaders?

2 A I think it was in March. I think it was in

3 March of 2001. I believe it was in March of 2001.

4 Q Did you participate in killing any other

5 Drummond union leaders after this?

6 A No, I did not participate in any other

7 killings of union leaders of Drummond the

8 multinational.

9 Q Do you know if there were other union

10 leaders killed?

11 A Yes, I did find that out by the front

12 called Resistencia Motilona, commanded by ex-commander

13 alias Omega, O-M-E-G-A. And Resistencia Motilona is

14 R-E-S-I-S-T-E-N-C-I-A. And Motilona, M-O-T-I-L-O-N-A.

15 Q Do you know anything about the murder of

16 Gustavo Soler?

17 A No, I don't. I don't know.

18 Q Are you aware that it occurred? Are you

19 aware that he was murdered?

20 A Yes, of course. Yes, yeah, I did get to

21 know, but I did not participate.


49

1 Q After the approximately March 2001 murder

2 of the first two unionists, Locarno and Orcasita, did

3 you participate in any meeting with a Drummond official

4 present?

5 A Well, yes, I do remember in that same year

6 of 2001, this was a farm that is near the subdivision

7 of the municipality Bosconia, B-O-S-C-O-N-I-A. I do

8 remember precisely that this farm is off a man called

9 Amador Ovalle. This was I think May or in June. I

10 don't remember necessarily exactly, but May or June.

11 And there was this man, U.S. man, and this

12 was -- seemed to be an important meeting because these

13 U.S. citizens were in the facilities of Drummond and

14 they weren't going out just except maybe to La Loma de

15 Potrerillo.

16 Q Let's back up a little bit and tell me who

17 all was at the meeting that you knew.

18 A I'm sorry, but you mean the meeting of

19 May 2001?

20 Q Yes.

21 A In that meeting was present Jorge Cuarenta.


50

1 I mean Jorge Cuarenta himself because in that meeting

2 was going to be a direct role, a U.S. man. This U.S.

3 citizen was in charge of security for Drummond the

4 multinational.

5 Q Before we talk about him, though, please,

6 just picture for us who else is at the meeting, every

7 person you can remember.

8 A There was Jorge Cuarenta in that meeting,

9 also the security group of Jorge Cuarenta. He was

10 Amacho. There was also Machoman and he was alias 05.

11 The security forces of Tolemaida. Kener was there,

12 myself, Alfredo Araujo participated, Jaime Blanco.

13 Those are the ones that I remember so far at this

14 point.

15 Q And then you mentioned an American. Was it

16 one?

17 A Yes, only one. I'm sorry, I'm missing

18 someone. Alias Niki, N-I. It was a bodyguard that

19 Tolemaida had at that point. It was somebody very

20 close to Jorge Cuarenta at that time.

21 Q Can you describe this American for us?


51

1 A Well, how can I tell you, they're pretty

2 much all the same. It was a tall man. He was tall and

3 very light haired, blondish, Mono as we call it here.

4 (And that should be for the Court Reporter M-O-N-O.) I

5 don't remember him much because I didn't pay too much

6 attention to him. That's what I remember pretty much.

7 He was a tall man, light hair, light eyes.

8 Q Was he younger or older?

9 A He was like of an age -- well, I really

10 can't describe it, but I would say that he was like a

11 little bit over 40.

12 Q Tell us at the time did you know what his

13 name was.

14 A No, at that time I did not know his name.

15 I got to know that much later.

16 Q How did you get to know it later?

17 A Let's say that because of my closeness to

18 the commander of the front who is -- who is the one

19 that told me that he was in charge of security at

20 Drummond. I remember that he told me his name, but he

21 said it to me but let's say wrongly pronounced.


52

1 And among the people that were there was

2 Niki who told it right to me because he understood

3 English. I remember it is something like this, like

4 Hacken, Hackins.

5 Q And when you say the commander, who are you

6 referring to?

7 A The commander of the Juan Andrés Álvarez

8 Front alias Tolemaida Ospino Pacheco.

9 Q So at this meeting May of 2001 you've

10 identified Jaime Blanco --Jaime Blanco

11 THE INTERPRETER: Just a second there is an

12 issue with the Court.

13 THE COURT: We're going to have a short

14 break.


16 (Deposition recessed at 10:50 a.m.)

17 (Deposition resumed at 11:07 a.m.)

18 THE COURT: We will continue with the

19 deposition of Alcides Manuel Mattos and the Plaintiff

20 has use of the microphone.



53


2 Q Before the break you had identified a

3 number of persons who were at a meeting in roughly

4 May 2001 and I'd like you to now tell us what happened

5 at that meeting.

6 A I remember, of course, that at that meeting

7 Jorge Cuarenta was present. I personally saw him. And

8 the head of the Juan Andrés Álvarez Front, alias

9 Tolemaida, and he personally congratulated him on the

10 killing of the two union leaders that occurred in March

11 of that year. I also remember that at the meeting

12 other matters were going to be dealt with for other

13 types of operations such as the follow-up payment for

14 security at Drummond and at the railroad line.

15 Q Let's start with the first portion of what

16 you said. You said that Jorge Forte congratulated

17 Tolemaida; is that correct?


19 Q Who was -- who was present when that

20 statement occurred?

21 A Let's say that, you know, practically half


54

1 of the security forces for Jorge Cuarenta were present.

2 You know, 05 was there. The American citizen who was

3 there. Alfredo Araujo was there. Niki was also

4 present. Jaime Blanco. I was there.

5 Q Do you remember -- tell us your best

6 recollection of what Jorge Forte said and anything you

7 remember about him saying it.

8 A He didn't used to call him Tolemaida. He

9 called him Juan Carlos. And I remember that he said,

10 Juan Carlos, congratulations for the job on the

11 Drummond union members. Well, and I remember him

12 saying that it was not him alone, but rather the boys

13 under his command. You know, the boys that he had

14 ordered to do it.

15 And I remember that he also said no and it

16 was also Samario. The one who came from the BCB that I

17 remember you were going to send to Chibono Magdalana,

18 C-H-I-B-O-N-O, Magdalana, M-A-G-D-A-L-A-N-A.

19 I remember that this is what I heard. I

20 heard him congratulate them and then, you know, I came

21 near them because Tolemaida had told me that I had to


55

1 be very attentive to whatever went on at the entryway

2 to the farm. And I was there posted at the entryway to

3 the farm because we were waiting for other people who

4 would come in. And the people we were waiting for were

5 executives from a Colombian transport company called

6 Copetra, C-O-P-E-T-R-A.

7 And I remember that the meeting did not

8 last long, you know, because for that U.S. citizen it

9 was very difficult for him to get there, to Vosconia,

10 V-O-S-C-O-N-I-A. And, you know, let's just say

11 practically that he had gone there clandestinely or,

12 you know, in disguise let us say.

13 The meeting with the U.S. citizen and with

14 Alfredo Araujo and Jaime BlancoJaime Blanco did not

15 last very long. This is what I remember. This is

16 what, when dawn they met, and exactly what they

17 discussed I would not know because I wasn't right there

18 next to them. But then Tolemaida came and told us, all

19 of us who were there, you know, for security, that

20 there were good things in our future for the front.

21 Q Can you tell us what Tolemaida explained


56

1 about that?

2 A Well, you know, he wouldn't give us an

3 exact explanation because we were his underlings. But,

4 you know, since we were close or, you know, there was a

5 lot of trust between us he would tell us about things.

6 And he mentioned that there would be more timely

7 payments, you know. And I remember that the payments

8 were to be received by an attorney now deceased by the

9 name Jose Dasa Ortiz who was then replaced by Javier

10 Lopez.

11 And they would now be in charge of

12 receiving the payments from the Drummond multinational

13 to the front. And that the bloc would have received or

14 was going to receive, I don't remember it very well

15 right now, a payment for either 1 million or

16 $1.5 million.

17 And then afterwards from then on the front

18 would stand to receive either a 100,000 or $150,000

19 periodically. And with this -- that with this the

20 front would thrive. You know, we would grow and expand

21 much more up to the Perija Mountains.


57

1 Q And this information about the payments,

2 how did you get that information?

3 A I was the third in command of the Juan

4 Andrés Álvarez Front. So I was someone who was very

5 important within the front and I had a lot of

6 information regarding the front. And, you know, before

7 when I used to be chief of security for Tolemaida, you

8 know, there was so much trust between us or closeness

9 that the only one of all of his bodyguards that lived

10 at his house was me. And, you know, he would tell me

11 practically everything. I was even, you know, a person

12 who carried monies for the front.

13 Q But the specific information -- the

14 specific information about the funding that would come

15 from Drummond, what was your source of that

16 information?

17 A Because alias Tolemaida told me.

18 Q After he told you that did you observe

19 changes in the front?

20 A Yes, of course. The war front had 70 men

21 including the Urbans. And when I left jail in


58

1 December, on December 10th, 2002 I found a front with

2 now 250 armed men.

3 And, you know, I remember that back then I

4 helped transport or carry from the municipality or the

5 small village of Azucar Buena, A-Z-U-C-A-R, Buena, and

6 here in Valledupar to a farm that we used to call

7 Latiajose, L-A-T-I-A-J-O-S-E, in El Danubio, E-L

8 D-A-N-U-B-I-O, and, you know, I would say more than 70

9 men to the municipality of I believe La Paz.

10 This happened between May -- April and May

11 of 2002 and it was the first group that I observed

12 arriving of men after those conversations. It was a

13 group of men. And I remember that their commander was

14 77 back then.

15 Q So at some point here after the new funding

16 arrived you went to jail, correct?


18 Q And you got out in December 2002; is that

19 correct?

20 A Yes.

21 Q And you had then a new position when you


59

1 got out, correct?

2 A Yes, of course.

3 Q Can you now tell us what that position was?

4 A I was now the commander for the zone or for

5 the area. I had the municipality of Becerril now under

6 my command. After that I had also the municipality of

7 La Jagua, L-A then J-A-G-U-A, La Loma de Potrerillo,

8 and then I was named third in command of the Juan

9 Andrés Álvarez Front.

10 Q Is that when you became the head of the

11 Urbanos or before?

12 A No, starting then.

13 Q When you -- when you said you were made the

14 commander that's when you became the head of the

15 Urbanos?

16 A Yes.

17 Q After that then can you tell us any

18 operations that you understood that you were performing

19 for Drummond?

20 A Well, directly, you know, operations for

21 Drummond after I received the command, the only one I


60

1 remember was, you know, security for the railroad line.

2 And, you know, let me just say it was like a sort of

3 commitment, you know, an agreement that there was

4 between the AUC and Drummond for -- so that the

5 guerillas, the FARC guerrillas would not make any

6 attempts against their facilities.

7 And then, you know, our understanding was

8 that any subversives or, you know, any such people that

9 were operating near the Drummond facilities we were to

10 kill them. And the area that I managed was the area

11 near the entryway to the railroad line, and, you know,

12 that corridor, you know, where the FARC was or the ELN

13 used to be, that was my area.

14 Q Can you name some of the towns that were

15 along that area and the corridor that you've just

16 described generally?

17 A I -- you know, my area where there were any

18 amount of subversives who could make a hit on Drummond

19 was the area of Becerril, that municipality, and

20 La Jagua until -- you know, basically that was my area.

21 And then, of course, there was also the Motilona Front


61

1 near Chiriguana, and that was my area. We also

2 encompassed all of the way to Bosconia.

3 Now, I know that there were other fronts

4 over there past that point, but I don't know what

5 agreement they had with Jorge Cuarenta or what orders

6 Jorge Forte had given them.

7 Q What did you understand your orders to be

8 in the areas you were working?

9 A My orders -- well, you know, before there

10 had been kidnappings there had been instances where the

11 railroad line had been blown up and our orders were to

12 keep that area safe, the areas near Drummond

13 multinational. And we had to fight against the

14 subversives, all of them. We could not leave small

15 pockets of them here and there. And so we used lethal

16 force. You know, we would just kill anyone who was

17 said to be a guerilla around those parts.

18 Q During the time that you became the head of

19 the Urbanos until you were captured in March of 2005 --

20 or was it April of 2005 -- April of 2005, roughly how

21 many people would you say your -- your group of Urbanos


62

1 killed along the Drummond rail line?

2 A I would not be able to say exactly but I do

3 know that there were many. We're talking about

4 hundreds. And, you know, I think that these statistics

5 speak for themselves. I don't remember the figures

6 exactly right now, but I know that there were hundreds

7 of people who were murdered in that area.

8 Q And in your mind why were they being

9 killed?

10 A Excuse me.

11 Q When you participated in killing these

12 people, why were you doing it?

13 A We were supposed to be combating the

14 guerrillas or subversives in the area. And we had to

15 provide military support to those companies that were

16 helping us out economically because the front I

17 belonged to, Juan Andrés Álvarez, was not created with

18 funds from drug trafficking. And we lived by the

19 contributions that were given to us by companies and by

20 friends in the area, including multinationals.

21 And, you know,that I remember that we had


63

1 considerable expenses because before my second capture

2 and my last we had about 600 men. And that is no small

3 penny.

4 And we could not take those monies from the

5 businesses in the area because, you know, after the

6 all-out war, you know, after the conflict, this was

7 poor municipalities. And so those businesses did not

8 have a lot of money. We could not take the money from

9 them.

10 And that is why those payments from

11 multinationals and specifically from Drummond

12 multinational to the front were so important for us for

13 our upkeep.

14 Q While you were working on patrolling the

15 railroad line area, did you ever coordinate with

16 private security working with Drummond?

17 A Well, coordinate as such I would not say

18 that, no; but let's say that they would report to us of

19 any strange ongoings or any strange people that were

20 hanging around the area.

21 Q And when you say that who are you referring


64

1 to? Is there a specific company or group that you have

2 in mind when you say they?

3 A Well, you know, security. I don't know

4 specifically what the security agency it was that

5 Drummond had hired but that one. And, you know, they

6 would call us and report to us of any strange ongoings

7 or any strange people that would be around the area.

8 Q And would you respond to those calls?

9 A Yes, of course. And, you know, the people

10 who could not justify their being there -- because, you

11 know, there were small communities around. If they

12 could not justify their being there they were

13 assassinated.

14 Q Do you recall the particulars of who called

15 whom? Was there somebody in your unit who would

16 receive these calls from Drummond's private security?

17 A No, I don't remember that exactly right

18 now. Well, you know, I don't remember exactly right

19 now. No, I don't know, but, you know, they were the

20 people in charge or, you know, the company that was

21 hired to provide security for the railroad line. Of


65

1 course with our consent because we were the ones who

2 were there.

3 Q During the time that you were doing the

4 operations up and down the Drummond rail corridor, did

5 you ever coordinate any activities with the official

6 Colombian military that was in the area?

7 A I did not coordinate in that area directly,

8 but I do know that the commander of the Bosconia area

9 did coordinate with both the military forces and the

10 police in that area.

11 Q What do you know about that?

12 A In my area I used to coordinate with a lot

13 with the public forces. You know, I would deal with

14 them a lot because -- well, I do remember coordinating

15 with them because, you know, they were hard hit by the

16 guerrillas and due to treaties and international rights

17 in our country they could not exert the same type of

18 force that we could.

19 So personally in my area I did a lot of

20 coordination with the Army. And, you know, they even

21 lent us arms. When I did not have the staff or the


66

1 personnel or the weapons available I could use the arms

2 of the public forces. And then, you know, all of the

3 coordination entailed in there not being any clashes

4 between the police and the AUC. You know, we had to

5 coordinate so that they would not have any conflicts.

6 Q And did you personally participate in that

7 kind of coordination?

8 A Yes, of course. I was the one who

9 undertook those arrangements.

10 Q What battalion of the military was in the

11 area where you were operating?

12 A Where I was at there were two battalions.

13 First there was a battalion, it was contra guerrillas.

14 It was against guerrillas. It was called Guajiros.

15 And the Plan Especial Energetico whose headquarters

16 were in La Jagua de Ibirico. And the Plan Especial

17 Energetico is plan as in English and then Especial,

18 E-S-P-E-C-I-A-L, and Energetico, E-N-E-R-G-E-T-I-C-O.

19 And also inside Drummond there was a

20 training facility within its own facility of the

21 military forces of course. And, of course, the police


67

1 which was in the center pretty much of the city, the

2 urban center on the city.

3 Q So you coordinated with all of these

4 establishments of the military or the police?

5 A Yes, yes.

6 Q And you said that you coordinated to avoid

7 clashing with each other. Can you explain that a

8 little bit more?

9 A Yes, of course. The agency, we were an

10 illegal group. We operated -- well, let's say that we

11 were the left arm of the state. We would do what the

12 public State forces would not do or could not do, the

13 State security forces that is.

14 Since we would provide safety so as to say

15 in that area where we used to operate the State

16 security forces were there and then we would coordinate

17 in order not to have any type of clashes between the

18 AUC and the military forces.

19 Moreover, the police forces are where those

20 municipalities where I used to operate. There

21 subversive forces have been grounded. They wouldn't


68

1 even leave their own stations because of our pressure

2 in the area against subversive forces. We had like

3 some kind of respect that we gained from the State

4 security forces towards us. That's why we always had

5 that type of coordination.

6 Moreover, many of those AUC are ex-military

7 and supposedly we were all against those subversive

8 forces since, however, we did not have any order to

9 fight against. That's where it stems, that

10 relationship between the State security forces and the

11 AUC so -- so to say that we kind of opened the space

12 for us to commit those killings -- killings of those

13 people that had links to the guerilla.

14 Plus actually there were made payments to

15 members of the State security forces and also what we

16 call here the false negatives which was the delivery of

17 people in order to justify whatever actions of those

18 State Police security forces.

19 MR. COLLINGSWORTH: A translator question.

20 He said false positive, not false negative, right?

21 THE INTERPRETER: Oh, I am sorry. Correct,


69

1 he did. False positive.


3 Q Can you explain what -- can you explain

4 what you mean by that, the false positive?

5 A In the area where the AUC operated, which

6 is the entire national territory, we the AUC did the

7 operations of cleaning like lethal actions in those

8 areas where we were at. In those areas where we did

9 these cleanup operations, the AUC, we, State, the State

10 security forces did not clash with us.

11 So then to justify our presence in the area

12 or to justify that, yes, they did fight us. In

13 exchange for safety for them not to pursue us we would

14 deliver to them people or ex-members of the AUC

15 themselves for them to be killed by the State security

16 forces of course.

17 Like how can I explain? Like the

18 justification that, yes, we were fighting against those

19 people that were in the sector, they would also deliver

20 people that they would pretend they were guerilla

21 members, and we ourselves, moreover, the AUC's would


70

1 give them weapons.

2 So they would pretend that there were these

3 clashes that maybe it was killed, an ex-AUC member or a

4 member of the guerilla was killed, and we would seize

5 this war material that, of course, was given and

6 delivered by the AUC themselves.

7 I am telling you this because I did that.

8 I participated in many of these cases. And I myself

9 delivered many of these people to these State security

10 forces in regards to these false positives.

11 Q So if I can understand -- thank you. So if

12 I can understand the economics of this, the military

13 received money based on how many of these false

14 positives were produced? Is that how it worked?

15 A Yes, of course, yes.

16 Q Where did they receive money?

17 A In the area of influence that we had, that

18 I had, you would meet in the municipalities or the

19 rural areas, wherever we would be. Rural areas,

20 municipalities, that was the area.

21 Q Who would give money to the military in


71

1 exchange for the evidence of the kills that were called

2 false positives?

3 A It was just for the safety of the members

4 that operated in the area.

5 THE INTERPRETER: And Interpreter needs to

6 play it back because Interpreter did not hear the first

7 part of the Witness's answer.

8 THE WITNESS: That I personally gave.

9 There were other members of the front that also gave

10 like alias Cebolla, and that is C-E-B-O-L-L-A, alias

11 Tolemaida, alias James, J-A-M-E-S, Javier Lopez Arza,

12 alias El Canoso, and Manuel Gregorio Gutierrez, alias

13 Christian. Those were practically the people that were

14 in charge of making the payments.

15 Q And you personally, you said, were very

16 involved in this process, in the false positive

17 process?

18 A Yes, of course. I have confessed to many

19 in the procedures that followed and in the process of

20 justice and peace.

21 Q Did the AUC in the area you were operating


72

1 in ever try to create a political party?

2 A Yes, of course.

3 Q What was the name of that party?

4 A G8.

5 Q Did -- to your knowledge, did Drummond ever

6 make a contribution to this party or its candidates?

7 MR. JEFFRESS: Objection, no foundation.

8 THE WITNESS: No, I don't remember that

9 Drummond had made any payments to the political party

10 that was of the AUC.


12 Q Any recollection of any individuals within

13 Drummond who made a contribution?

14 MR. JEFFRESS: Objection, foundation.

15 THE WITNESS: No, no, I don't remember.


17 Q As part of your coordination with the

18 military while you were the commander of the Urbanos,

19 did they ever -- did any military unit ever give you

20 arms?



73

1 Q Can you describe some situation in which

2 that occurred?

3 A At the municipality -- well, between

4 Becerril and La Jagua de Ibirico.

5 Q What happened?

6 A In an operation that I worked on together

7 with the Army -- I remember, actually as a matter of

8 fact, a sergeant, who right now is in custody because

9 of false positives, lent me a shotgun and three --

10 actually three rifles and also an M60. This was at an

11 instance where I went upwards to the place that is up

12 on the height that is called El Progreso, if I will

13 remember, and that is E-L P-R-O-G-R-E-S-O, where I had

14 confrontations with the guerilla which are the ELN,

15 also at the municipality of Becerril.

16 I had a base actually like some

17 headquarters near the police station of that

18 municipality. Of course, headquarters of the AUC's.

19 And that police chief would lend me those rifles. So I

20 would perform security duties around the police

21 station.


74

1 Q Did the any military unit loan you men for

2 any operations while you were commander of the Urbanos?

3 A No. Lending men? No, but we did joint

4 operations.

5 Q Can you think of any examples where you've

6 done a joint operation with the military during the

7 time you were the commander of the Urbanos?

8 A Yes, of course. As a matter of fact, I had

9 one when one of the AUC members died where I was with

10 some of the members of the Army were -- were part of

11 the Plan Especial Energetico of El Tocuy where I

12 actually lost a man because of these fights. I

13 remember that at that time we brought a lot of cattle,

14 a lot of cows, that they were on that highlands of

15 El Tocuy.

16 It's the one that I remember the most,

17 actually of many, of many. And, oh, I remember another

18 one. It was the massacre at the subdivision of

19 Yeraska.

20 Q When was that approximately?

21 A I remember it was in the year 2002. At the


75

1 beginning of the year 2002.

2 Just I want to clarify, I wasn't a

3 commander yet.

4 Q During the time that you were the commander

5 of the Urbanos, what entity was the largest supporter

6 of your front?

7 A Well, we all know that the strongest entity

8 that operated in the area where the Juan Andrés Álvarez

9 Front operated, it was Drummond, the multinational

10 Drummond. And it was the one that paid the most.

11 Q You described a meeting in roughly May 2001

12 where Alfredo Araujo was present with Jaime BlancoJaime

13 Blanco and this American along with Jorge Forte. After

14 that meeting did you ever see Alfredo Araujo again?

15 THE INTERPRETER: Counsel, could you repeat

16 the question? I am sorry, Interpreter missed it.

17 MR. COLLINGSWORTH: No problem.


19 Q After that meeting did you ever again see

20 Alfredo Araujo?

21 A No, I didn't see him again.


76

1 Q Did you ever see the Gringo again -- I am

2 sorry, the American again that was at that meeting that

3 you later thought you had identified?

4 A No, neither.

5 MR. COLLINGSWORTH: Your Honor, the

6 Plaintiffs are finished with their questioning and we

7 thank you for your patience during this process.

8 Now, in a break the Defendants and I

9 discussed that this might be the best time to take a

10 one-hour lunch break so that they can think about

11 what they're going to do, if that's okay with Your

12 Honor.

13 THE COURT: Okay. Let's take a

14 one-hour-and-a-half-hour break for lunch.

15 MR. COLLINGSWORTH: One-and-a-half hours.

16 THE COURT: It's 12:00 and we will be back

17 at 1:30 then.

18 MR. COLLINGSWORTH: I would like just to

19 add that when the Defendants are done, as is our

20 custom, I would like a few minutes for rebuttal, if

21 necessary.


77

1 THE COURT: Yes, of course, with pleasure.


3 THE INTERPRETER: We are going off the

4 record at 12:01.

5 (Recessed at 12:01 p.m. for lunch)

6 (Reconvened at 2:25 p.m.)

7 THE CLERK: By the Department of Colombia

8 [sic] good afternoon. It is 2:30 in the afternoon.

9 This is the Third Criminal Court of the Circuit of

10 Valledupar. We will begin again the proceedings to

11 listen to the -- continue listening to the deposition

12 of Mr. Alcides Manuel Mattos Tabares, alias El Samario,

13 in compliance with International Judicial Assistance

14 requirements which is our Letters Rogatories of the

15 Court of the District of the United States, Northern

16 District of Alabama, Southern Division of the Case

17 2:09-cv-1041-RDP of Claudia Balcero Giraldo against

18 Drummond Company, Inc., Drummond Limited, and the

19 president of Limited, Augusto Jimenez, who collectively

20 have been referred as to Drummond or Defendants.

21 THE COURT: Once again, in compliance with


78

1 all of the requirements that need to be done for this

2 proceeding and continue with instructions of the

3 Letters Rogatory, we shall allow attorney of Defendants

4 to ask questions. The witness is advised and continues

5 to be under a -- being under sworn. He's being still

6 sworn. So the Defendants' attorney has the word to ask

7 questions of the witness.

8 MR. JEFFRESS: May it please the Court.

9 EXAMINATION BY MR. JEFFRESS:

10 Q Mr. Mattos, I'm William Jeffress. I

11 represent the Drummond Defendants in this lawsuit. I

12 will ask you a number of questions this afternoon. And

13 if you do not understand my question, please, ask me to

14 repeat it or to clarify it.

15 Mr. Mattos, were you arrested in April of

16 2005?

17 A Yes.

18 Q By whom?

19 A National police.

20 Q Arrested for what?

21 A Paramilitarism.


79

1 Q Had you previously been arrested in the

2 year 2002?

3 A Yes.

4 Q Who were you arrested by on that occasion?

5 A The national Army.

6 Q The national Army?

7 A Yes.

8 Q What were you arrested for?

9 A Because of the same thing, paramilitarism.

10 Q Mr. Mattos, if you were coordinating with

11 the Army and with the police so there would be no

12 confrontations, why is it that you were arrested twice?

13 A In the year 2002 when I was captured for

14 the first time by the national Army I still did not

15 have tasks as of a commander within the structure of

16 the front. At that time there was no coordinators and

17 I don't know what happened.

18 And the second time, yes, I was already the

19 third subordinate in command of the front, southern

20 front. And I was not captured by the police of that

21 area, but I was captured by the police of another area,


80

1 of another sector, with whom I did not coordinate with.

2 Q Since that arrest in April 2005 have you

3 been in prison?

4 A Yes, of course.

5 Q How long do you expect to serve in prison?

6 A I don't know.

7 Q Mr. Mattos, were you -- did you accept

8 responsibility for participation in the murders of two

9 Drummond union leaders?


11 Q And did the criminal court in Bogotá

12 sentence you to almost ten years in prison for those

13 murders?

14 A Yes, around nine years. I'm still there

15 because of -- because of other processes together with

16 that one.

17 Q Have you been convicted -- prosecuted or

18 convicted for any of the murders you committed or

19 ordered to be committed other than the murders of the

20 union leaders?

21 A Yes.


81

1 Q What murders are those?

2 A An officer of the judicial branch of

3 Colombia, a judge.

4 Q Where -- where was the judge located?

5 A In Becerril, Cesar.

6 Q Why did you murder the judge?

7 A Order of the central command of the

8 self-defense forces.

9 Q Why was the order given by the central

10 command to murder that judge?

11 MR. COLLINGSWORTH: Objection, no

12 foundation. No foundation. Objection, no foundation.

13 THE COURT: Let that be recorded then such

14 objection.

15 BY MR. JEFFRESS:

16 Q You may answer.

17 A Seemingly because the judge -- well, the

18 judge had links to the self-defense forces. Also had

19 relationship with the FARC guerrillas. And because of

20 this the Northern Bloc of the AUC's ordered the killing

21 of such judge.


82

1 Q What year?

2 A 2003.

3 Q What sentence did you receive for the

4 murder of that judge?

5 A Forty years.

6 Q So you have 40 years for the murder of the

7 judge and 11 years for the murder of the union leaders.

8 Do you have any other sentences for other murders?

9 A Yes, another gentleman also, the killing of

10 another gentleman whose name is Luis Angel Manrique.

11 He is a cattle owner. And aside from that also some

12 others that I don't remember.

13 Q Why did you murder the cattle owner?

14 A Orders from the central command of the

15 bloc.

16 Q Why were those orders given?


18 foundation.

19 THE WITNESS: Well, because of the same

20 thing. I mean, how can I say, also because this man,

21 this man also had links with the FARC guerrillas.


83

1 BY MR. JEFFRESS:

2 Q Where did the cattle owner live?

3 A In Becerril, Cesar.

4 Q What year?

5 A 2003.

6 Q What sentence did you receive for the

7 murder of the cattle owner?

8 A I think 24 years.

9 Q Now, any other convictions?

10 A No, I have no other convictions.

11 Q You are participating in the justice and

12 peace process under Law 975, correct?


14 Q Do you hope to reduce your sentence to a

15 total of eight years?

16 A Yes.

17 Q And is any attorney helping you with that?

18 A At the present time, no, but as attorneys

19 the public defender's office.

20 Q Is Ivan Otero your attorney?

21 A Nowadays he's not. He used to be my


84

1 attorney sometime ago.

2 Q Is -- have you discussed with

3 Mr. Collingsworth or any lawyer representing the

4 Plaintiffs how they might assist in your receiving

5 benefits under the justice and peace law?

6 A Yes, I've spoken to them, but not what kind

7 of benefits will I have about the justice and peace

8 process because that is to no avail because whatever

9 benefit it will be issued and given by Colombian

10 authorities.

11 Q What conversations have you had with

12 Mr. Collingsworth about how he might help you in any

13 way?

14 A Well, help, no. But on one occasion I

15 spoke to Attorney Ivan Otero. He asked me if I was

16 willing to tell the truth because I had already

17 confessed in the process of justice and peace which is

18 a justice process of the Colombia justice proceedings.

19 MR. COLLINGSWORTH: I'm going to object

20 here that that's attorney-client privilege between him

21 and his attorney at the time and he needs to be


85

1 instructed. He doesn't need to answer that.

2 BY MR. JEFFRESS:

3 Q At the time of that discussion was

4 Mr. Otero your attorney?

5 A At that time he was.

6 Q Well, you have testified many times in the

7 justice and peace process; is that correct?

8 A Yes.

9 Q And do you remember on the 23rd of November

10 2009 testifying in a free version of the justice and

11 peace process about the murders of the union leaders?

12 A No, I have not gave any statements in the

13 process of justice and peace about the union leaders.

14 I think it was something temporary because at that

15 time, well, the prosecutor gives kind of a preference

16 to whatever is happening now. At any time -- at any

17 rate I have been condemned for that now.

18 Q All right. Let me ask you to look at a

19 video.

20 MR. JEFFRESS: Your Honor, we have a video

21 of Mr. Mattos's testimony on November 23rd, 2009. I'd


86

1 like him to look at it and identify if that's him

2 speaking and who is asking the questions.

3 THE COURT: Yes, of course it's allowed.

4 MR. COLLINGSWORTH: I'm going to object to

5 the lack of foundation of this video and no

6 identification of what it is.

7 THE INTERPRETER: He can't hear anything.

8 (Playing video.)

9 BY MR. JEFFRESS:

10 Q Mr. Mattos, do you recognize yourself in

11 that video?


13 Q And are you answering questions that are

14 being asked by someone?

15 A Yes. That is the justice and peace unit

16 here in Valledupar.

17 Q And did you answer the questions that were

18 asked of you on that day?


20 Q And do you remember now that those

21 questions did involve the murder of the union leaders?


87

1 A Yes. But, once again, it was something

2 superficial. But the justice -- justice administrator

3 here in Colombia didn't pay much attention to that.

4 Well, it's not that he didn't pay attention to that and

5 didn't give it importance since, but I have already

6 been condemned. Therefore...

7 Q Did you tell the truth to the prosecutor?

8 A Yes, whatever I was able to tell him since

9 I didn't speak much, hoping new versions of new

10 proceedings that could take place in the future since

11 my justice and peace process has not finished here in

12 Colombia.

13 Q Were you asked by the prosecutor in that

14 testimony whether you knew why the AUC and specifically

15 its commander ordered the death of the two men and who

16 else collaborated in this act? Do you remember being

17 asked that question?

18 THE INTERPRETER: Counsel, could you repeat

19 it for the Interpreter, please?

20 BY MR. JEFFRESS:

21 Q Yes. Do you remember being asked by the


88

1 prosecutor, do you know why the AUC, specifically the

2 front commander, ordered the death of these two men,

3 how they prepared the operation, who else collaborated

4 in this act?

5 A Yes, I do remember. I also remember what I

6 said.

7 Q Do you remember saying that it had been

8 rumored within the front that it had something to do

9 with the cafeteria inside Drummond and some Drummond

10 directors, but I am not certain of that; I did not

11 see -- I did not see whether it was true or not true?

12 Was that your testimony?

13 A I said that at that time that there were no

14 guarantees about my statements. I remember having said

15 that as well. Also I remember in a trial that this was

16 advanced to Mr. Rodrigo Tovar from the United States, I

17 also asked for guarantees to be able to testify here in

18 Colombia.

19 MR. JEFFRESS: I move to strike the last

20 part as nonresponsive.

21 BY MR. JEFFRESS:


89

1 Q My question to you, Mr. Mattos, was whether

2 you told the prosecutor on the 23rd of November 2009

3 that you did not know whether it was true or not true

4 that the murder of the union leaders had anything to do

5 with Drummond.

6 A Once again, I did say it's true about the

7 union leaders. And I also said that I had asked for

8 guarantees to be able to testify later on in a free

9 version of the case.

10 MR. JEFFRESS: We're having some trouble

11 with the audio on -- on the disk. So I'm not sure you

12 can hear the audio.

13 Could I give Mr. Mattos headphones?

14 MR. COLLINGSWORTH: I would, of course,

15 object to the form of this as apparently he's going to

16 ask questions based on some mysterious testimony that

17 none of us are going to be able to hear.

18 THE COURT: Let it be recorded the

19 objection by the Plaintiffs' attorney.

20 THE INTERPRETER: Who prepared the

21 operation?


90

1 MR. JEFFRESS: Okay. Let the record

2 reflect -- I'm going to stop this for now. Let record

3 show I just tried to play through the earphones on the

4 microphone the voice of Mr. Mattos.

5 BY MR. JEFFRESS:

6 Q Could you hear that, Mr. Mattos?

7 A Yes, of course.

8 MR. JEFFRESS: And could you hear, the

9 Interpreters? You could hear?

10 THE INTERPRETER: The Interpreter was able

11 to hear, but when she started interpreting for the

12 Court Reporter the Interpreter was not able to hear

13 anymore because she was overlapping. So she did

14 interpret, though, whatever she heard which was part of

15 a question.

16 MR. JEFFRESS: What I'm going to do is I am

17 going to play the prosecutor's question.

18 (Playing tape.)

19 BY MR. JEFFRESS:

20 Q Mr. Mattos, I'm going to come back to that

21 when I get our equipment working well.


91

1 A Fine. No problem.

2 Q It is true, Mr. Mattos, that in testifying

3 to the prosecutor on the 23rd of November 2009 you

4 didn't say one thing about Alfredo Araujo or Jim Adkins

5 or anyone else specifically from Drummond, correct?

6 A No. That, yes, I did not mention anything.

7 And that is, the reason for that is so much I, as my

8 family, we have been receiving threats that are very

9 well-known here in the Colombian justice system.

10 That's why my family is being protected by the state.

11 Q Go ahead. I'm sorry.

12 A I remember that at that time the prosecutor

13 was not Jorge Humberto, but was Izardo Barreto when the

14 justice and peace process was just beginning here in

15 Valledupar. And also in my interviews. And you do

16 have the video, however, I don't know why you do not

17 have the interviews where I speak about the threats.

18 And that it is difficult for me to testify openly in

19 the justice -- the justice and peace process at that

20 time because of the lack of the security that we had so

21 much I, as my family.


92

1 Q So because of these concerns you lied in

2 your testimony on November 23rd?

3 MR. COLLINGSWORTH: Object to the form.

4 THE WITNESS: Once again, I did not lie.

5 And I -- once again, I will tell you that I did not lie

6 because there were no security safety guarantees,

7 immunity guarantees. Since there were no protection

8 for my family, that's why I said that maybe in the

9 future I could testify about some things, some events.

10 And still, there is still at this very moment there are

11 no safety and security guarantees so as to be able to

12 testify in this transitional process.

13 Cases like, for instance, the

14 disappearance of my CD of interviews of mine,

15 complaints by other candidates in regards to attacks

16 on my family that maybe you don't know about. That

17 is, though, set forth in the Colombian judicial

18 system.

19 That's why they don't want not only me

20 but many other candidates of the justice and peace

21 process for us to testify, that it would be very


93

1 hurtful to many people.

2 MR. JEFFRESS: I move to strike all of the

3 answer beyond when he answered, when he attempted to

4 answer my question, did you tell the truth.

5 BY MR. JEFFRESS:

6 Q So, Mr. Mattos, just clearly and simply,

7 did you or did you not tell the whole truth to the

8 prosecutor in answer to his questions or the questions

9 on that day?

10 MR. COLLINGSWORTH: I object to the form,

11 and asked and answered, argumentative.

12 THE WITNESS: Once again, I will tell you

13 the same thing, I said no and I asked for guarantees.

14 I said, once again, to the prosecutor no and I asked

15 for guarantees in order to be able to testify with no

16 issues.

17 BY MR. JEFFRESS:

18 Q Mr. Mattos, exactly two weeks later you

19 signed a sworn declaration for Mr. Collingsworth that

20 you have previously identified in this court today. Do

21 you remember that?


94

1 A Yes, of course. And the process or the

2 proceeding was not here in Colombia.

3 Q Mr. Mattos, what guarantees or promises did

4 you receive between the 23rd of November and the 4th of

5 December of 2009 regarding your testimony?

6 A What I mentioned before, I did not have any

7 guarantees of protection. What I'm saying and what I

8 know is that that proceeding took place not here in

9 Colombia but abroad.

10 Q So you were not afraid that signing that

11 declaration could subject you to any harm?

12 A Well, you know, yes, of course I was

13 afraid. But, you know, by then I already had some

14 security. It wasn't a lot of security that I had for

15 my family, but by Colombian authorities. But, of

16 course, as far as I understood it the proceeding was

17 not to take place here in Colombia.

18 Q Did you receive those promises of security

19 between the 23rd of November and the 4th of December,

20 2009?

21 A Yes. Well, by Colombian -- the Colombian


95

1 justice system. And I remember that I made the

2 statement before the prosecutor for the justice and

3 peace process and I required or I asked for guarantees.

4 And I think that even before that I had already been

5 tried through the regular justice system where I also

6 required security or safety guarantees for my family

7 before the 12th prosecutor's office of the human rights

8 unit. Where even before giving that testimony I

9 denounced the threats that had already taken place

10 against my family.

11 Q Are you describing something you claimed to

12 have said in your testimony on the 23rd of November?

13 A Let me repeat once more, I did not say this

14 in the free version. I said this at an interview that

15 was recorded. That's where I said it. At the same

16 office, of course.

17 Q Do you remember, Mr. Mattos, telling the

18 prosecutor on the 23rd of November 2009 that I don't

19 know if Drummond had something to do with the murder of

20 these two unionists? Do you remember saying that?

21 A Once again, yes, I do remember.


96

1 Q Was it true?

2 A Excuse me.

3 Q Was that testimony true?

4 A No, it was not.

5 Q So you lied?

6 A Let me repeat once again, in that interview

7 on that same day I said that I was not going to talk

8 about anything that I knew about. And the official

9 within the Colombian process of justice and peace was

10 already and had already been forewarned of that because

11 I had already told him about the threats against my

12 family.

13 Q Who was that person in justice and peace

14 that you warned that you intended to lie in your

15 testimony?

16 MR. COLLINGSWORTH: I object to the form of

17 the question, mischaracterizes the testimony,

18 argumentative.

19 THE WITNESS: Once again, let me just say,

20 I never told the justice administrator that I was

21 thinking of lying in my testimony. Let me just make


97

1 that very clear. I forewarned him of all of the

2 problems that would be coming to me when I started

3 saying my testimony and of the threats and offers that

4 I had received in order not to be a witness in that

5 process.

6 And I remember that the justice

7 administrator very wisely said at that moment, look,

8 I cannot force you to testify because you are

9 afraid. And he said, well, I don't know if then

10 maybe later on. You know, because you still have

11 not finished with the free version proceedings maybe

12 you will confess later on.

13 MR. JEFFRESS: I move to strike everything

14 after his answer that he never told anybody he intended

15 to lie.

16 BY MR. JEFFRESS:

17 Q Did you -- in your testimony on the 23rd of

18 November 2009 you told the prosecutor that you were

19 aware Tolemaida and Jaime BlancoJaime Blanco had had

20 several meetings before the murder of the union

21 leaders. Do you remember that?


98


2 for the Interpreter?

3 BY MR. JEFFRESS:

4 Q Yes. You told the prosecutor that you were

5 aware of meetings between Jaime BlancoJaime Blanco and

6 Tolemaida before the murder of the union leaders.

7 A Outside the view of the camera. Off camera

8 I did tell him.

9 Q Well, you also told him on camera, did you

10 not?

11 A Yes, of course, I had already given him my

12 reasons.

13 Q And did you tell the prosecutor in this

14 testimony that you don't know whether the meetings were

15 for planning these murders, you were not certain, you

16 were not certain of this? Did you tell the prosecutor

17 that?

18 MR. COLLINGSWORTH: Object to the form and

19 asked and answered.

20 THE WITNESS: Could you repeat that,

21 please?


99

1 BY MR. JEFFRESS:

2 Q Yes. Did you tell the prosecutor that you

3 didn't know if these meetings between Tolemaida and

4 Jaime BlancoJaime Blanco were for planning the murders;

5 you were not certain of this?

6 MR. COLLINGSWORTH: Same objection as to

7 form.

8 THE WITNESS: Yes, I do remember. And I

9 also told him my objections as to why I said that.

10 BY MR. JEFFRESS:

11 Q If you told him that, would it be on the

12 videotape of the testimony?

13 A Excuse me.

14 Q If you told the prosecutor what you just

15 said, would it appear on the videotape of the

16 testimony?

17 A About the threats, no. About the

18 objections that I had in order to testify during the

19 process, no, because that happened during the

20 interview.

21 Q What interview?


100

1 A An interview that I gave in that same

2 courtroom or in that same facility before the -- one of

3 the administrators or officials of the justice and

4 peace process.

5 Q Well, did you testify also in the criminal

6 trial against Jairo de Jesus Charris?

7 A Yes, of course.

8 Q And that was on the 23rd of April 2009?

9 A Of course.

10 Q And when you testified did you say --

11 strike that.

12 Were you under oath when you testified in

13 that trial?


15 Q And did you tell the Court under oath when

16 Tolemaida arrived at these meetings they separated; I

17 do not know what they talked about as I was separated

18 providing security? Did you say that to the Court?

19 A Yes. And I also told that same Court that

20 I was not going to speak and I was not going to testify

21 until I obtained the guarantees for the protection of


101

1 my family. I told this to that same Court.

2 Q Were you -- did you lie about your

3 knowledge of Jaime BlancoJaime Blanco or Tolemaida in

4 your testimony in that case?

5 MR. COLLINGSWORTH: Object to form and

6 mischaracterizes, argumentative.

7 THE WITNESS: Excuse me, I didn't

8 understand the question.

9 BY MR. JEFFRESS:

10 Q You understood the -- did you get the

11 objection or --

12 A The question.

13 Q Okay. The question.

14 The question was: Did you tell the Court

15 under oath on the 23rd of April of 2009 that when

16 Tolemaida arrived at meetings they separated; I do not

17 know what they talked about as I was separated

18 providing security?

19 A To the prosecutor or to the judge?

20 Q To the judge in the trial.

21 A At the trial, no, I don't remember right


102

1 now.

2 Q I'm going to show you the official record.

3 Yes, the official record of your testimony on the 23rd

4 of April of 2009 which is in Spanish.

5 MR. JEFFRESS: May I approach the witness,

6 Your Honor?

7 THE COURT: Yes, sir.

8 (Defendants' Exhibit 2 was marked for


10 MR. JEFFRESS: I've marked it as Defense

11 Exhibit 2.

12 THE COURT: Would you have a copy so that I

13 can have it here?

14 (Handing a copy to the Judge.)

15 BY MR. JEFFRESS:

16 Q Turn, Mr. Mattos, to the page in

17 handwriting at the top of 9. I'm sorry, it's page 8.

18 Do you see the testimony --

19 MR. JEFFRESS: May we have a moment, Your

20 Honor? I'm sorry. I'm sorry. Your Honor, I

21 apologize.


103

1 BY MR. JEFFRESS:

2 Q And if you would look at the page that has

3 97 at the top and it's right here. Mr. Mattos, I

4 pointed you to testimony you gave in the trial of

5 Mr. Charris in which you said that when Tolemaida and

6 Jaime BlancoJaime Blanco met they did so in private.

7 No one heard their conversations. I do not know what

8 they talked about.

9 Do you see that?


11 Yes, of course.

12 Q Was that true?

13 A We can say that once only.

14 Q Excuse me, you can say what once only?

15 A At the meeting where the U.S. citizen was

16 present at a farm in Bosconia. But at the others he

17 would either tell me or sometimes I would hear it.

18 Q On which occasions do you now claim that

19 you heard a conversation between Jaime BlancoJaime

20 Blanco and Tolemaida?

21 A Well, you know, in the ones that I've


104

1 always said I did hear, you know, in this particular

2 occasion because Tolemaida told me so and because

3 Charris told me so. And at the other meeting which was

4 held right outside the facilities of the Drummond

5 multinational there I did hear.

6 Q Now, so when you told the Court that you do

7 not know what Tolemaida and Jaime BlancoJaime Blanco

8 talked about at these meetings that was false?

9 MR. COLLINGSWORTH: Objection to form and

10 mischaracterizes, argumentative.

11 THE WITNESS: Well, you know, back then the

12 proceeding at trial was not against Jaime BlancoJaime

13 Blanco but against Jaime -- Jairo de Jesus Charris

14 Castro and the judge did not ask me that.

15 BY MR. JEFFRESS:

16 Q Didn't ask you what?

17 A The judge was not emphatic or did not

18 underscore the issue about the meetings. You know, of

19 course, I always explained to him or rather to her

20 because it was a woman judge my objections regarding

21 the security guarantees.


105

1 Q Look at the next question a little bit

2 further down on the same page.

3 Do you remember being asked, did you meet

4 anyone in particular who accompanied Mr. Jaime Blanco

5 to meetings that he had with Tolemaida?

6 Do you see that question?

7 A No, I do not.

8 MR. JEFFRESS: May I, Your Honor?

9 THE COURT: Yes.

10 BY MR. JEFFRESS:

11 Q Jaime Blanco, have you found that question?

12 A Yes.

13 Q And did you respond, sometimes I saw

14 Mr. Charris but I was always outside? And then you

15 mentioned a casino worker and another young guy by the

16 name of Peinado, who later joined AUC.

17 Do you see that?

18 A Well, you know, I don't know here, excuse

19 me, if this was an error or mistake in transcription,

20 but I remember specifically that I said that the person

21 who remained outside was Charris, not me.


106

1 Q So you believe that you told the Court in

2 Charris's trial that you actually heard the

3 conversations between Jaime BlancoJaime Blanco and

4 Tolemaida?

5 A No.

6 Q And it is true, is it not, Mr. Mattos, that

7 at no time in your testimony in the Charris trial did

8 you ever mention that any meetings between Tolemaida

9 and Jaime BlancoJaime Blanco were attended by Alfredo

10 Araujo?

11 A I was never asked.

12 Q You were asked who else attended, correct?

13 A Yes, I do remember that.

14 Q And you didn't mention Mr. Araujo or

15 Mr. Adkins, correct?

16 A Well, I don't think that I had to mention

17 them at that trial. You know, it was a trial against

18 Jairo de Jesus Charris Castro. I think, you know, that

19 it was up to him to make that clear within his own

20 proceeding, his own trial. As a matter of fact I

21 believe he did so later.


107

1 Q What -- Mr. Mattos, what happened between

2 the 23rd of April 2009 and December 4th of 2009 when

3 you signed your declaration that made you remember that

4 Alfredo Araujo was at one of these meetings?

5 A Well, you know, nothing happened. As a

6 matter of fact nothing happened. Simply, you know, I

7 knew that the trial was not going to take place here in

8 Colombia. And what happened, nothing. But I've always

9 had that clear in my mind. I've always been aware of

10 that. The only inconvenience I've ever had has been

11 due to safety.

12 Well, you know, perhaps you don't know this

13 because you've been a citizen of another country, but

14 you don't know that in Colombia everything can die.

15 And I've seen many deaths that all of a sudden occurred

16 because the person knew too much. Simply because of

17 that.

18 And, you know, in this process, let's say

19 that a lot of things will surface. You know, many

20 people who previously did not want to testify, they

21 will want to in the future. Well, you know, people who


108

1 were abroad, who were free, and who are no longer free,

2 and who are slowly coming to the realization that they

3 should testify, and they will. You know, just like me,

4 the time will come when we will go before the Colombian

5 justice system and provide a full testimony.

6 Q Did you also state under oath on

7 April 23rd, 2009 that you were never close enough to

8 Tolemaida and Jaime BlancoJaime Blanco in these

9 meetings to listen to what was said?

10 MR. COLLINGSWORTH: Objection to form,

11 asked and answered.

12 BY MR. JEFFRESS:

13 Q Did you say that?

14 A Let me say once again that I did request

15 protection guarantees within the proceeding against

16 Mr. Charris because this proceeding was not against

17 Mr. Jaime BlancoJaime Blanco.

18 Q So did you not feel obligated to tell the

19 truth about Jaime BlancoJaime Blanco?

20 A Not to say the truth, but to testify during

21 that proceeding.


109

1 Q You mentioned this morning in your

2 testimony Aristides Peinado. That's Jose Aristides

3 Peinado, correct?

4 A Yes, of course.

5 Q And Mr. Peinado worked for Jaime Blanco,

6 correct?

7 A Yes, and for the AUC.

8 Q Well, did he work for both of them at the

9 same time or did he work for Jaime BlancoJaime Blanco

10 and then later AUC?

11 A For both at the same time.

12 Q Okay. And he was a good friend of Jairo de

13 Jesus Charris, correct?

14 A Of course.

15 Q And Jairo de Jesus Charris became a close

16 friend of yours, correct?


18 Q Do you have a cell phone in prison?

19 A Currently, no.

20 Q Have you had a cell phone in prison from

21 time to time?


110

1 A Yes, I had an authorization for it on

2 behalf of the administration -- administrator of the --

3 of the judicial system.

4 Q Have you spoken to Mr. Charris?

5 A No. And let us say that when I had the

6 opportunity authorized by the government to have such

7 communication, well, let's just say that Jairo de Jesus

8 Charris was not in jail. I remember that the only time

9 I spoke to Jairo de Jesus Charris was at his trial, the

10 one hour that the judge gave us.

11 Q So you have not spoken to him by telephone

12 or otherwise since his trial?

13 A No. No, I've never spoken to him but at

14 the trial.

15 Q Have you spoken to Jose Aristides Peinado?

16 A Yes, of course. And currently we're in the

17 same cell block.

18 Q So you've discussed this case against

19 Drummond with Mr. Peinado?

20 A You know, we were militants for the same

21 front. So, you know, we have an obligation to


111

1 communicate. You know, sometimes he helps me remember

2 things. Yes, we are.

3 Q And Mr. Peinado, you testified this morning

4 that he would often provide information to the AUC

5 about people that he believed were subversives,

6 correct?

7 MR. COLLINGSWORTH: Object as to form,

8 mischaracterizes.

9 BY MR. JEFFRESS:

10 Q Pardon me if I'm wrong.

11 A No. This morning I didn't say that he

12 would bring information -- information about what he

13 thought. He would bring information that was given to

14 him that he received.

15 Q Now, was this while he worked for Jaime

16 BlancoJaime Blanco?

17 A During, yes, and afterwards also.

18 Q And where did he go to work after he left

19 Jaime BlancoJaime Blanco?

20 A Let's just say that he then went directly

21 to work for the AUC.


112

1 Q Did you mention this morning that you

2 thought he worked for a security contractor?

3 A No, excuse me, that I thought that he

4 worked? No. That he worked for Jaime BlancoJaime

5 Blanco.

6 Q I misunderstood you.

7 Are you -- you've mentioned that you are

8 receiving some protection or your family is receiving

9 some protection from the state, from the Colombian

10 State, correct?


12 Q What other monies or support are you or

13 your family receiving from any source today?

14 A Well, let's just say that right now I'm

15 under no obligation to tell you how my family is being

16 supported. I think it's a very personal matter.

17 Q Does your wife receive monies from any

18 organization in Colombia such as the Colectivo Alvear

19 Restrepo or any other lawyer's organization?

20 A I did not know of this Colectivo Alvear

21 Restrepo. And she doesn't receive any other types of


113

1 monies.

2 Q She -- you deny that she receives monies

3 from persons that are supporting the Plaintiffs in this

4 lawsuit?

5 A Totally. She doesn't receive monies

6 from -- you know, let me just say I don't receive money

7 from anyone. Well, you know, in the way that they

8 support themselves, you know, that's something that is

9 up to me that is -- that I reserve for myself to know.

10 And, you know, how she makes a living or where she goes

11 to work, as long as she's not hurting anyone or doing

12 anything illegal, that's up to us.

13 Q When did you -- were you first approached

14 by Mr. Collingsworth or persons working with

15 Mr. Collingsworth to give testimony in this matter?

16 A I don't remember the date exactly, but it

17 was in Barranquilla. And that in passing when they did

18 ask me if I could provide my testimony, I thought about

19 it for like eight months while I was in Barranquilla.

20 Q Who was present at that first interview

21 between yourself and Mr. Collingsworth in Barranquilla?


114

1 A Let's just say that it wasn't a meeting.

2 You know, they arrived at an interview. I had an

3 interview with my attorney and an interpreter because I

4 don't speak English. And then my attorney back then

5 who was Mr. Ivan Otero, he was the one helping me with

6 my case, he asked me if I wanted to bring my testimony.

7 You know, they would not force me, but did I want to

8 lend testimony about or regarding what I knew between

9 Drummond the multinational and the AUC.

10 Well, you know, and I was scared because

11 you know, imagine it was against the Drummond

12 multinational and I know how things were handled then.

13 You know, I was a commander of the AUC. And I told

14 them that I would think about it. It was nothing

15 direct or immediate like that. And that we would talk

16 later. And since he was my attorney then I would

17 communicate with him.

18 MR. JEFFRESS: Well, I move to strike all

19 testimony that's unresponsive to my question which is

20 who accompanied Mr. Collingsworth.

21 THE WITNESS: And Can I repeat it once


115

1 again because I already told you, Dr. Ivan Otero who

2 back then was my attorney.

3 BY MR. JEFFRESS:

4 Q And did Mr. -- what did Mr. Collingsworth

5 say to you in that interview other than what you've

6 said?

7 A Once again, what the interpreter said

8 because I do not speak English, I was told about a

9 process that is undergoing in the United States. If I

10 didn't hear correctly it was in Alabama, State of

11 Alabama. He told me that by conversations that he had

12 had with my attorney that he had knowledge of what had

13 happened to some of us, that we have been demobilized,

14 some that participated in the AUC, between the

15 relationship between the multinational Drummond and the

16 AUC. He asked me if I was willing to testify or give

17 my testimony. At that time I remember I did not

18 provide an answer.

19 I spoke to my attorney and told him that I

20 would think about it. At that meeting that's what

21 pretty much went down, that's what we spoke about.


116

1 Besides in that meeting was also Mr. Esquivel Cuadrado.

2 El Tigre was also present at that meeting.

3 Q El Tigre, you, Ivan Otero, and

4 Mr. Collingsworth were present at that meeting?

5 A Yes. Once again, it was not a meeting. It

6 was an interview in jail.

7 Q And you decided not to provide testimony to

8 Mr. Collingsworth at that time?

9 A No, no. Neither -- El Tigre did neither.

10 Q When did you change your mind?

11 A I'd say like a year or so later. I don't

12 remember exactly when it went, but let's say that it

13 was like a long year after.

14 Q Do you remember the date of the meeting you

15 had with Mr. Collingsworth and El Tigre in

16 Barranquilla?

17 A No, no, I don't remember it exactly.

18 Q When did you -- when were you transferred

19 from the Barranquilla prison to the Valledupar prison?

20 A If I'm not mistaken I think -- believe that

21 it was in October of 2008.


117

1 Q Now, how many times since that first

2 meeting have you met either with Mr. Collingsworth or

3 Francisco Ramirez?

4 A No, I don't remember. It's been many.

5 Q Many?

6 A No, they're not many.

7 Q Not many?

8 A Not many. Maybe two, three times.

9 Q Have you met with Mr. Collingsworth in the

10 past two weeks?

11 A Yes, he was -- a week ago. And he was here

12 in Colombia and he asked me if I was still willing to

13 provide my testimony. And I told him that I was.

14 Q And did he -- what did he say to you about

15 other information that Mr. Collingsworth had obtained?

16 THE INTERPRETER: I'm sorry, Counsel could

17 you repeat that question for the Interpreter?

18 BY MR. JEFFRESS:

19 Q What did Mr. Collingsworth say to you about

20 other information he had obtained?

21 MR. COLLINGSWORTH: Objection as to form,


118

1 no foundation.

2 BY MR. JEFFRESS:

3 Q You can answer.

4 A Could you repeat the question, please? I

5 didn't understand it.

6 Q What did Mr. Collingsworth tell you about

7 other information he had obtained?

8 MR. COLLINGSWORTH: Same objection as to

9 form.

10 THE WITNESS: I don't understand -- well,

11 actually I do understand that you're asking me if I --

12 about some other information that Mr. Terry had

13 obtained or I myself had obtained? I mean, I don't --

14 BY MR. JEFFRESS:

15 Q Have you seen declarations that were given

16 by other witnesses in the Drummond case?

17 A No, I don't know them.

18 Q Have you seen the complaint that

19 Mr. Collingsworth filed on behalf of Plaintiffs in this

20 case?

21 MR. COLLINGSWORTH: Object as to form, time


119

1 frame.

2 THE WITNESS: No.

3 BY MR. JEFFRESS:

4 Q Do you have the declaration that was marked

5 as Exhibit 1 this morning?

6 A No, I don't have it.

7 MR. COLLINGSWORTH: Now he does have it.

8 BY MR. JEFFRESS:

9 Q Would you look at the attachment to that

10 declaration. That's a list of names of persons and

11 municipalities, 250 persons.

12 A Yes, this morning I have done that already.

13 Q Where did you -- who prepared that

14 document?

15 A I mean, what, the list --

16 Q The attachment.

17 A -- or the document?

18 No. This is a database with which we, the

19 candidates to the justice and peace process, have

20 worked with in the transitional peace process, justice

21 process that I provided to Mr. Terry.


120

1 Q And who prepares that database? Who is

2 responsible for preparing that?

3 A These are -- these are facts. Actually

4 these are complaints. These are all that have been

5 submitted to the prosecutor's office related to the

6 justice and peace process.

7 Q Is it not just yourself but other former

8 paramilitaries in the AUC who have contributed to this

9 database?

10 A No. Once again, this -- this list, it's

11 provided to the candidates and it's provided by the

12 justice administration about the facts that are

13 attributable to the AUC forces who did militing around

14 in those areas. This is to see which of those killings

15 we participated in, which of those killings we directly

16 participated, the AUC, directly.

17 Q And who decides whether to put a name on

18 that list or not?

19 A All of those names are family members of

20 victims. No, I'm sorry. All of those names are people

21 that have been killed or have been disappeared. All of


121

1 those people have already been killed or disappeared.

2 Q Forgive me, what I'm trying to learn is who

3 makes the decision that someone was killed or

4 disappeared.

5 A I don't understand the question.

6 Q Who decided to put any particular name on

7 that list?

8 A I will respond to whatever I understand.

9 This list is supplied to us. The justice

10 administration of Colombia supplies this list to us,

11 the candidates. And all of these people have been

12 killed by the AUC.

13 Q That's what the justice administration

14 tells you, that all of these people were killed by the

15 AUC?

16 A No. Well, yes, the justice administration

17 helps us to remember. Remember yourself, this is a

18 hard process, difficult process where I participated

19 not in one, in two, in three, but in a number of facts

20 that this -- I don't necessarily remember in all of

21 them.


122

1 And since this transitional process, it's

2 been delayed, and so there is victims and killers and

3 other sort of people that pertain to that process. So

4 we want for them to be acknowledged, all of those

5 people that have been killed by the -- all of these

6 people by the AUC in any -- in any of these criminal

7 acts or killings or whatsoever acts.

8 Q Well, let me, do you have personal

9 knowledge, Mr. Mattos, that each person listed on that

10 document was killed by the AUC?

11 A Yes, of course. But personal knowledge of

12 all of the people on that list, no. But, yes, in many.

13 Q How many people did you kill?

14 A I don't remember at this very moment, but I

15 know that there were many.

16 Q Did you personally kill more than a hundred

17 people?

18 A I believe so.

19 Q Why did you kill those people?

20 A Let's say because of the ideology that we

21 were all living at that time and because of the


123

1 conflict that we were undergoing here in Colombia.

2 Q Have you spoken, Mr. Mattos, either

3 personally or by telephone within the last three years

4 with Jaime BlancoJaime Blanco?

5 A No.

6 Q Have you spoken with Tolemaida?

7 A Yes, in Barranquilla.

8 Q And did Mr. -- did you discuss with

9 Tolemaida the murder of the Drummond union leaders?

10 A Yes. We had our differences because he did

11 not want me to testify. Moreover he threatened me. He

12 told me that he had enough money to buy all of the

13 witnesses. Exactly he told me that Drummond had given

14 him money to fix the process.

15 Q This is something he told you supposedly?

16 A Supposedly, no. He did tell me.

17 Q Isn't it true, Mr. Mattos, that you arrived

18 in the Cesar, the zone of Cesar after March of 2001?

19 A No, I came long before.

20 Q You testified in the trial of Charris that

21 the murder of the union leaders was at approximately


124

1 7:15 a.m. on the morning of March 12, correct?

2 A Yes. I said that I wasn't sure if it had

3 been in the morning or afternoon, but it had been

4 almost dark outside.

5 Q Do you deny, Mr. Mattos, that you testified

6 in the trial of Charris that you got a call about 4:30

7 in the morning of March 12 and the murder was carried

8 out about 7:15 a.m.?

9 A Once again, that I wasn't sure that it was

10 maybe in the morning hours or in the afternoon hours.

11 That should be -- that should be written somewhere.

12 Q We'll find that later.

13 MR. JEFFRESS: Could we take a short break

14 here, Your Honor?

15 THE COURT: Yes, of course, please do.

16 THE VIDEOGRAPHER: Going off the record

17 at 3:57.

18 (Deposition recessed at 3:57 p.m.)

19 (Deposition resumed at 4:15 p.m.)

20 THE COURT: The Defense has the floor once

21 again. Thank you.


125

1 BY MR. JEFFRESS:

2 Q Mr. Mattos, you testified this morning to a

3 meeting attended by Jorge Forte in April or May of 2001

4 that you say was attended by a U.S. businessman,

5 correct?


7 mischaracterizes.

8 THE WITNESS: Yes.

9 BY MR. JEFFRESS:

10 Q And, Mr. Mattos, did this American speak

11 Spanish?

12 A I don't remember, but I don't think so.

13 But I don't remember.

14 Q Okay. Look at your declaration that you

15 signed which is the Plaintiffs' Exhibit Number 1. You

16 have that?

17 A Yes.

18 Q Okay. And look at paragraph 14.

19 Did you say in your declaration that you

20 gave to Mr. Collingsworth that the American from

21 Drummond did not speak Spanish?


126

1 A Yes, of course. Now that I see it, yes.

2 Q And for that reason Niki, alias Niki had to

3 translate for the American?

4 A Yes. Niki was a gentleman who being a

5 member of the AUC had been in jail abroad. I think

6 maybe in Orlando in the U.S. And had thereby learned

7 English.

8 Q Another subject. You testified,

9 Mr. Mattos, that the Juan Andrés Álvarez Front did not

10 obtain money from narcotics trafficking, correct?

11 A Yes.

12 Q Did the Bloc Norte obtain money from drug

13 trafficking?

14 A I would not be able to say. I operated

15 under the Juan Andrés Álvarez Front. I don't know

16 about the other members of the blocs if -- if they

17 obtained money from drug trafficking or not.

18 Q Did Jorge Forte control the money for the

19 Juan Andrés Álvarez Front as well as the entire Bloc

20 Norte?

21 MR. COLLINGSWORTH: Object as to form and


127

1 foundation.

2 THE WITNESS: No, no. Each front was

3 self-sustaining. Now, of course, there were very small

4 fronts that also Jorge Cuarenta would provide for.

5 BY MR. JEFFRESS:

6 Q Where did the money come from that paid

7 your salary as an agency member?

8 A Yes. Well, we would get money at the Juan

9 Andrés Álvarez Front from, you know, different sources,

10 from cattle growers, from businesses. You know, we had

11 access to politics. So from mayor's offices, from

12 hospitals. And, yes, that's how we would get the money

13 to stain ourselves.

14 Q And are you aware that Jorge Forte,

15 Salvatore Mancuso, and Jose Gelvez Albarracin had all

16 been indicted in the United States for narcotics

17 trafficking?


19 Q And how do you know that monies supplied to

20 the Juan Andrés Álvarez Front did not come from

21 narcotics trafficking?


128

1 A Yes, because, once again, I repeat that we

2 were self-staining in passing. We would even send

3 money to Jorge Forte.

4 Q So you had more money than you needed?

5 A Yes. Let us say that we had enough money

6 to support the front and, you know, some months we had

7 extra money that we could send to Jorge Forte, but you

8 know we --

9 THE INTERPRETER: The Interpreter is

10 requesting that the witness repeat the last part.

11 THE WITNESS: And we had to provide an

12 accounting monthly of these monies and pay for our

13 costs, our expenses.

14 BY MR. JEFFRESS:

15 Q Did you provide the accounting, Mr. Mattos?

16 A Yes -- no. Let's say that each commander

17 in his own area would do the accounting. Yes, I did my

18 own accounting.

19 Q You mean for the group of Urbanos?

20 A Yes, for the Urbanos group and also a rural

21 group that I had under my command as well.


129

1 Q That's after 2003?

2 A Yes, of course.

3 Q Now, Mr. Mattos, I was asking you before we

4 broke about your testimony on the time of day that the

5 murders occurred. Do you remember that?

6 A I know that it was in March of 2001. But

7 right now I don't remember if it was Monday, Tuesday,

8 or Wednesday. Right now I don't remember.

9 Q Do you have Exhibit 2 which is your

10 testimony at the Charris trial?

11 Let me ask a question first. Mr. -- okay.

12 Mr. Mattos, look at the handwritten page 100. All

13 right. And starting -- would you read your testimony

14 starting with the line como a las 4:00. Yes. If you

15 would read that testimony down through 9:00 in the

16 morning. Just read that to yourself.


18 Q Have you read it through where it says

19 9:00 a.m.?

20 A Yes.

21 Q So isn't it true, Mr. Mattos, that in the


130

1 trial of Mr. Charris that you testified you received a

2 call at 4:00 or 4:30 in the morning that you arrived at

3 Casa de Zinc and got a call at 7:00 or 7:15 a.m. and it

4 was approximately 9:00 a.m. in the morning that the

5 buses arrived?

6 A Well, you know, excuse me, but I really

7 don't know why it's drafted in this way because I never

8 said that I received a phone call at 4:30 in the

9 morning or that I went to anyone's house named Zinc.

10 Casa de Zinc is a small community, a rural community.

11 Q You deny that you told the Court in the

12 trial of Mr. Charris that the murder of these union

13 murders occurred early in the morning on March 12?


15 for the Interpreter? Sorry.

16 BY MR. JEFFRESS:

17 Q Yes. Do you deny that you told the Court

18 that the murder of these union leaders occurred early

19 in the morning on March 12?

20 MR. COLLINGSWORTH: Object to the form and

21 mischaracterizes.


131

1 THE WITNESS: Yes. And I don't -- and I

2 did say at the trial that it was at around 7:15, either

3 in the morning or at night, in the afternoon. And I

4 don't know why it's not registered here as I said it.

5 You know, and I even remember that the

6 judge, she said to me, do you remember if this was

7 in the afternoon. And I remember saying back to

8 her, well, you know, if you say that it was in the

9 afternoon it must have been. You know, it can

10 happen to me in several other proceedings.

11 BY MR. JEFFRESS:

12 Q Well, Mr. Mattos, this appears to be the

13 entire official record of your testimony in the Charris

14 trial authenticated by the Court assistant Nancy

15 Edelmirea Lara Diaz, correct?

16 A Yes.

17 Q You have no doubt that that's the official

18 record of your testimony that day, right?

19 A Well, I can't say that it's complete

20 because I think that a lot of things that I said are

21 missing also.


132

1 Q Mr. Mattos, I asked you earlier whether

2 you -- it's not true that you arrived in the Juan

3 Andrés Álvarez Front after the murder of these union

4 leaders and you said that's not true, correct?

5 A Yes. Way before.

6 Q You say that you arrived in the San Juan --

7 I am sorry, the Juan Andrés Álvarez Front in what

8 month?

9 A I don't remember well, but it was between

10 August and September of the year 2000.

11 Q Have you ever testified in justice and

12 peace that, in fact, you arrived in Cesar in 2001?

13 A I don't remember, no. I don't remember.

14 Q I'm going to play an excerpt from testimony

15 that you gave in the justice and peace program on --

16 we'll find that date and put it in the record, but let

17 me -- let me ask you to look at your -- it is May 24th,

18 2010.

19 (Playing video.)

20 BY MR. JEFFRESS:

21 Q Do you recognize that as you appearing to


133

1 testify?

2 A Yes. That free version had no validity --

3 validity because I had no counsel and there was even a

4 problem between Tolemaida and I. And I remember in

5 passing that after that proceeding there was a huge

6 problem because of the threats he made to me.

7 Q Did you lie in your testimony that day?

8 A Once again, I repeat, that proceeding was

9 not legally valid.

10 Q Did you lie in the proceeding?

11 A That proceeding did not exist. It was

12 legally invalid. I had no legal counsel. And then

13 during that free version there was a huge problem with

14 Dr. Daisy Jaramillo Rivera. And, you know, I don't

15 know if you have it there, but, you know, she had a

16 problem with the victims because of, I don't know,

17 issues with lack of respect proffered against them.

18 MR. JEFFRESS: I move to strike three --

19 his answers all three times to my question.

20 BY MR. JEFFRESS:

21 Q My question is very simple, Mr. Mattos:


134

1 Did you lie in that testimony?

2 A I cannot say that I lied regarding a

3 testimony that was never valid.

4 Q All right. I want you to watch this

5 transcript and you were asked --

6 A Pardon. Look, I don't even know if you

7 know this, but this process was manipulated to such an

8 extent that towards the end, I don't know if you can

9 see him, but there was a person there who was hired by

10 Tolemaida who was passing or make himself pass as an

11 attorney, but was not an attorney. And they denounced

12 this later and he was put in jail.

13 MR. JEFFRESS: Move to strike.

14 BY MR. JEFFRESS:

15 Q Mr. Mattos, do you lie when it's convenient

16 to you?


18 argumentative.

19 THE WITNESS: No. This is the truth of

20 what happened during this proceeding which ended in

21 havoc. Well, you know, and maybe since you are leading


135

1 a defense perhaps it's convenient to you to show what

2 is convenient to you.

3 BY MR. JEFFRESS:

4 Q Well, let me show you the actual transcript

5 of this testimony, the actual tape of this testimony.

6 And I'm going to ask you to listen to the tape from

7 where you were asked by the interviewer, did you know

8 why the AUC, specifically the front commander, order

9 the death of these two men, how they prepared the

10 operation, who else collaborated in this act. I want

11 you to watch your answer to that question.

12 MR. JEFFRESS: Play the question and

13 answer.

14 MR. COLLINGSWORTH: Object as to form and

15 no foundation.

16 MR. JEFFRESS: I withdraw the question. I

17 was reading from the wrong transcript.

18 BY MR. JEFFRESS:

19 Q All right. What I'm going to ask you here

20 is where you are testifying about your background in

21 the AUC and when you arrived in Cesar. I'm going to


136

1 ask you, after you listen to this video, isn't it true

2 that you told the case attorney that you arrived in the

3 Bloc Norte in 2001.

4 MR. JEFFRESS: Play it.

5 (Playing video.)

6 MR. COLLINGSWORTH: I object to the form of

7 this entire line of questioning. We can't even discern

8 what's been said. And that transcription you've just

9 handed her, is that private transcription or is that

10 certified?

11 MR. JEFFRESS: Not certified.

12 I would like to mark the disk of this

13 video as Exhibit 3, Defense Exhibit 3.



16 BY MR. JEFFRESS:

17 Q Having listened to that testimony,

18 Mr. Mattos, do you agree that you did tell the

19 questioner on that occasion that you arrived in 2001?

20 A Yes, of course, I do remember it.

21 Q And Tolemaida was present at that time, was


137

1 he not?

2 A Yes, of course.

3 Q And he knew the truth, didn't he?

4 MR. COLLINGSWORTH: Object to form,

5 argumentative, no foundation.

6 BY MR. JEFFRESS:

7 Q When you first arrived you became a

8 bodyguard for Tolemaida, correct?

9 A Yes, sir.

10 Q So Tolemaida would know when that happened?

11 THE INTERPRETER: I'm sorry.

12 BY MR. JEFFRESS:

13 Q Tolemaida would know when that happened?

14 MR. COLLINGSWORTH: Again, object as to

15 form and no foundation.

16 BY MR. JEFFRESS:

17 Q Correct?


19 Q Change the subject. In your testimony this

20 morning you mentioned that the union leaders before

21 their deaths had been threatening a strike against


138

1 Drummond. Do you remember that?

2 A Yes, of course.

3 Q Who told you that?

4 A Well, there was no -- well, as a matter of

5 fact at the front we knew that, almost all of us, the

6 ones that were close to Tolemaida.

7 Q Tolemaida told you?

8 A Yes, of course.

9 Q In fact, the union's complaint at that time

10 was about food service being provided by Jaime Blanco,

11 correct?


13 foundation.

14 THE WITNESS: I didn't know about the

15 complaint of the union nor before whom it was

16 submitted.

17 BY MR. JEFFRESS:

18 Q So you don't know one way or another

19 whether the complaint was about Jaime Blanco's food

20 service?

21 A Exactly about the complaint I don't know.


139

1 I don't know if they -- I really don't know exactly how

2 they submitted or filed or what.

3 Q You also have testified several times today

4 about things that Tolemaida told you, things that

5 occurred at meetings, or things that he told you about

6 Drummond.

7 A Yes, of course.

8 Q And do you remember testifying, again in

9 the trial of Charris, that Tolemaida said practically

10 nothing to me, as a guard I never asked questions in

11 that organization? Do you remember testifying to that?

12 A Bodyguard, yes. I wouldn't ask him. He

13 would tell us.

14 Q Did you testify that Tolemaida said

15 practically nothing to you --

16 A Yes. At that time I remember that

17 Tolemaida would tell us -- would tell us many things.

18 We wouldn't ask anything, but, yes, he would tell us

19 many things because of the close relationship that we

20 had at the time.

21 MR. JEFFRESS: May I approach, Your Honor?


140

1 THE COURT: Yes.

2 BY MR. JEFFRESS:

3 Q Again, do you have Exhibit 2 in front of

4 you which is the Spanish language transcript of your

5 testimony in the Charris trial?

6 A Yes, of course.

7 Q Turn to handwritten page 98. And I'll ask

8 you to read from the word Preguntado -- Preguntado to

9 the question and the answer.


11 Q Now, Mr. Mattos having read that, is it

12 true that in your testimony at the trial under oath you

13 were asked this question and you gave this answer?

14 Question: When you accompanied alias

15 Tolemaida to meet at the casino on one or two occasions

16 what did Tolemaida say to you was the purpose of the

17 meeting at that location?

18 And your answer was: Tolemaida said

19 practically nothing to me. As a guard I never asked

20 questions in that organization.

21 Did you say that under oath?


141

1 A Yes, of course.

2 Q Is it true?

3 A Yes. Once again, we didn't ask, but, yes,

4 he would tell us things.

5 Q You just said he wouldn't -- said

6 practically nothing. He told you practically nothing.

7 That was your testimony.

8 And is that true?

9 A Yes, of course. It was not Jaime Blanco's

10 process.

11 Q It was not Jaime Blanco's what?

12 A Process. Jaime Blanco's proceeding.

13 Q And if you look at -- look at the bottom of

14 the same page, Mr. Mattos. And it says Preguntado.

15 The question is: Did Tolemaida say at the end of the

16 meetings what conclusion was reached or what the

17 objective of the meetings was?

18 Do you see that question?

19 And your answer, Mr. Mattos, was: They did

20 not talk to me like that.

21 Is that testimony true?


142

1 A Yes, of course, that is my answer.

2 Q And was it true?

3 A Let's say that, no, it was not totally

4 true.

5 Q You lied?

6 A Let's say I did not look at my answer.

7 Q Did you lie?

8 A No.

9 Q But you didn't tell the truth?

10 A Practically, I wasn't asked. Well,

11 practically, the judge didn't ask me that I had to

12 specify everything.

13 Q Mr. Mattos, just think carefully here.

14 Tell us each and every time you saw someone from

15 Drummond provide money to someone from the AUC.

16 A Is that the question?

17 Q That's a question.

18 A Well, directly that I have seen? I mean,

19 I'm sorry --

20 Q Yes, you personally, you personally saw it.

21 A -- Drummond?


143

1 No, I never saw personally Mr. Drummond

2 giving money to the AUC.

3 Q All right. Now, let me ask you: Any

4 person who worked for Drummond -- put aside Jaime

5 Blanco. Any person who worked for Drummond, tell us

6 every time you saw someone who worked for Drummond give

7 money to the AUC.

8 A No, I never saw anybody. Personally seen

9 somebody giving money, no.

10 Q You mentioned an agreement with El Tigre

11 that you had heard about later. Where did you hear

12 about that?

13 THE INTERPRETER: Counsel, Interpreter can

14 clarify, you said agreement?

15 MR. JEFFRESS: Yes, I said agreement.

16 THE WITNESS: Let's say that after I

17 started at the Front Juan Andrés Álvarez that agreement

18 would be knowledge of El Tigre.

19 BY MR. JEFFRESS:

20 Q Was El Tigre in prison when you started

21 with the Juan Andrés Álvarez Front?


144

1 A Yes, of course.

2 Q Did you talk to him about Drummond?

3 A Before being in prison?

4 Q Before being in prison.

5 A No, never.

6 Q So this is something you and El Tigre

7 talked about while you were in prison together?

8 A No.

9 THE INTERPRETER: Counsel, could you come

10 closer to your microphone.

11 MR. JEFFRESS: Sorry.

12 BY MR. JEFFRESS:

13 Q So when did you and El Tigre discuss this?

14 A No, I have not spoken to El Tigre about

15 this. This is something that was known inside the

16 front.

17 Q Who told you?

18 A All the people that were close to Tolemaida

19 knew that in the front. Moreover, the people that were

20 in charge of receiving the money, they were very close

21 to me.


145

1 Q Who was in charge of receiving the money?

2 A At the beginning was José Dasa Ortiz --

3 José Dasa Ortiz. That's with a D. And then José [sic]

4 Lopez Arza, alias El Canoso.

5 Q Where is José Dasa today?

6 A José Dasa was killed in the year 2009 here

7 in Valledupar.

8 Q Killed by who?

9 A No, I don't know. I was deprived from my

10 freedom.

11 Q And José -- did you say José Gelvez?

12 A No. Javier Lopez.

13 Q And his nickname was El Canoso?

14 A El Canoso, yes.

15 Q Did you know another El Canoso?

16 A No, I only knew him.

17 Q Where is Javier Lopez today?

18 THE INTERPRETER: I'm sorry, Counsel?

19 BY MR. JEFFRESS:

20 Q Where is Javier Lopez today?

21 A He was killed in the year 2008.


146

1 Q Where do the multinationals do business in

2 the Department of Cesar?


4 foundation.

5 THE WITNESS: Multinationals and such? I

6 mean, in their totality, the ones that were in the

7 area?

8 BY MR. JEFFRESS:

9 Q In the area.

10 A All of them would pay.

11 Q Speaking of the murders of the two union

12 leaders, what did the -- anyone from the Colombian Army

13 have to do with that, with those murders?

14 A No. I don't remember it having any link

15 whatsoever. I don't know if it maybe had some type of

16 coordination task or something.

17 Q But you don't know that personally?

18 A No, I don't know it.

19 Q You talked this morning about false

20 positives. Do you remember that?



147

1 Q Would you explain who is it that you

2 would -- you or your men would kill?

3 A Well, people. Right?

4 Q You just murdered people at random?

5 A I don't understand.

6 Q How did you select the people that you

7 killed, that you murdered?

8 A Well, we had guides who would provide us

9 information. Sometimes it was corroborated. Sometimes

10 it was not.

11 Q Information about what?

12 A About guerilla members, subversive forces.

13 Q All right. So your organization murdered

14 people who were thought to be subversives, correct?

15 A Let's say that, yes, and many times we

16 exchanged information with the State security forces.

17 Q Well, in the false positives' situation,

18 what did you do with the bodies of the people that you

19 murdered?

20 A With those false positives, well, we didn't

21 do anything with the bodies. The bodies were in charge


148

1 of the State forces as guerilla members or as AUC that

2 have been put down, hit.

3 Q Well, how did the military get involved?

4 A To explain it to you, well, I wouldn't

5 know. There was a certain -- we had a certain common

6 thread that they fought the subversive forces and we

7 fought the subversive forces.

8 Q Were you allowing the military to claim

9 credit for killing subversives?


11 Q And what particular military officers did

12 you work with on these false positive events?

13 A Well, there were many officers, but I think

14 it's not the case to mention their names here today.

15 It's not a proceeding against them. I think I'd give

16 those names to the Colombian justice system.

17 Q Well, I must insist on an answer to that

18 question because it's an issue that's relevant in the

19 lawsuit.

20 A Once again, I will give the names to the

21 Colombian justice system. I've been giving them names.


149

1 I don't think I have the need to tell you the names of

2 those militaries that worked with me here at this

3 instance.

4 Q Well, you refuse to answer my question in

5 the proceeding, correct?

6 A No. I just believe that it's really not

7 convenient for me to tell you or to name the militaries

8 that had a relationship with me. They are Colombian

9 militaries and I believe that the Colombian justice

10 system needs to try them.

11 Q Well, will you tell me today the names of

12 those officers or will you not?

13 A No.

14 Q Now, you said something about members of

15 your group talking to security personnel of Drummond.

16 A No, I never gave that order. Tolemaida

17 would give us those orders to those of us that had

18 duties within the front.

19 Q Did you, Mr. Mattos, yourself ever receive

20 a communication from a Drummond employee suggesting

21 that you or your group kill somebody in particular?


150

1 A No.

2 Q You mentioned a time when you worked with

3 the Army and an Army officer lent you a shotgun, an

4 M60, and three rifles which you took to El Progreso.

5 Do you remember that?

6 A Yes, of course.

7 Q Will you tell me the name of the -- will

8 you tell me the name of the military officer who

9 provided you those weapons?

10 A No. As I said before, right now, this

11 proceeding is not about me giving you the names of the

12 military personnel that worked with me.

13 Q Where is El Progreso?

14 A It's between Becerril and La Jagua de

15 Ibirico. It's up in the highlands of Berija.

16 Q Of what?

17 A Berija, B-E-R-I-J-A.

18 Q It's not near the Drummond mine or the drum

19 railroad, correct?

20 A No. Let us just say no. Well, you know,

21 but it was the area where the guerrillas would descend


151

1 to the part within the plan.

2 THE INTERPRETER: Could the Interpreter

3 inquire of the Witness what he means by El Plan?

4 THE WITNESS: To the lower part. You know,

5 away from the highland, the flatland.

6 MR. JEFFRESS: May I have one moment, Your

7 Honor?

8 THE COURT: Yes.

9 (A short break was taken.)

10 THE COURT: Though we here in the Court

11 have no problems with continuing with the interrogation

12 until, you know, whichever hour. INPEC, which is the

13 agency in charge of transporting and provide security

14 for the witness, has certain protocols regarding

15 security. And so based on that they can only be here

16 until quarter to 6:00. In other words 5:45.

17 So my question to Counsel would be:

18 How, much, more or less, he will take with the rest

19 of his interrogation?

20 MR. JEFFRESS: We will finish by quarter of

21 6:00.


152

1 THE COURT: Without making you feel in any

2 way pressured to finish abruptly.

3 MR. JEFFRESS: Thank you.

4 MR. COLLINGSWORTH: And I need at least

5 five minutes.

6 MR. JEFFRESS: I'll leave that for you.

7 THE COURT: He needs five minutes?

8 MR. COLLINGSWORTH: Yes.

9 THE COURT: So then he would have -- so in

10 order to comply with the protocol for INPEC, then you

11 would be done at 20 to and then we would give him his

12 five minutes.

13 MR. JEFFRESS: Fine.

14 BY MR. JEFFRESS:

15 Q Mr. Mattos, what was Alfredo Araujo's

16 position at Drummond?

17 A I don't remember well, but back then I

18 think he was chief of personnel. I don't remember

19 well.

20 Q You said in your declaration that you

21 signed December 4th, 2009 that he was the manager of


153

1 community relations for the Drummond company.

2 Do you remember that?

3 A Yes, something like that.

4 Q Who told you that?

5 A Well, you know, I -- I knew that, but, you

6 know, let's say sometimes you forget because some

7 things are just, you know, irrelevant.

8 Q You said in your declaration in

9 paragraph 10 that Araujo was a friend from childhood of

10 Jorge Forte and they were very well-acquainted. How

11 did you know that?

12 A Well, you know, this is something that is

13 very well-known by everyone who is a part of the AUC

14 here. You know, the childhood relationship of

15 Jorge Forte here in Valledupar.

16 Q So you've heard it from who?

17 A Well, you know, that is something that was

18 well-known amongst all of the people that were a part

19 of the AUC. You know, Tolemaida, myself, all the

20 people who had a command.

21 Q I would like now to show you the video that


154

1 I tried to show you earlier but failed.

2 MR. JEFFRESS: I'm sorry, I don't have

3 another copy of the transcription.

4 THE INTERPRETER: Thank you so much anyway.

5 BY MR. JEFFRESS:

6 Q Mr. Mattos, I'm going to play the video of

7 your appearance and testimony on November -- the 23rd

8 of November 2009.

9 And I will start with the question by the

10 interviewer that says: Did you know why the AUC,

11 specifically the front commander, ordered the death of

12 those two men, how they prepared the operation, who

13 else collaborated in this act? And I'll ask you to

14 listen to the question and the answer.

15 (Playing video.)

16 BY MR. JEFFRESS:

17 Q So did you listen to your answer to that

18 question?

19 A Yes.

20 Q And in no part of that answer did you

21 mention Alfredo Araujo or Jim Adkins or any other


155

1 officer or employee of Drummond, correct?

2 MR. COLLINGSWORTH: I'm going to object to

3 the form of the question, no foundation. The question

4 is not in the record.


6 BY MR. JEFFRESS:

7 Q And you did say in your answer to that

8 question I don't know if Drummond played a role in the

9 assassination of those two union members, correct?


11 Q And that was exactly two weeks before you

12 signed a clarification that Mr. Collingsworth presented

13 to you, correct?


15 foundation, mischaracterizes the record.

16 BY MR. JEFFRESS:

17 Q Who typed that declaration?

18 A Which statement, mine?

19 Q The statement that you signed, yes.

20 A No. That statement was not prepared by

21 anyone.


156

1 Q I'm afraid I've confused things. I'm

2 asking you about Plaintiffs' Exhibit 1, the declaration

3 that Mr. Collingsworth or someone presented to you to

4 sign after you talked with Mr. Collingsworth.

5 A Oh, okay.

6 Q Who prepared that declaration for you to

7 sign?

8 A Yes. I remember that Ivan Otero was there

9 with Dr. Terry and they had a laptop. They printed it

10 and I signed it.

11 MR. JEFFRESS: That's all of the questions

12 I have, Your Honor. Oh, excuse me, I am sorry. I wish

13 to mark the video that we played, the disk of the video

14 as Defendant's Exhibit 4.



17 THE COURT: Which disk? I believe it's

18 this one.

19 MR. JEFFRESS: It's right here.


21 I will now have a few questions to follow up on some


157

1 points that the Defendants made.

2 THE COURT: Yes, sir. You have the floor

3 to do the redirect as it is called.

4 MR. COLLINGSWORTH: Thank you.

5 EXAMINATION BY MR. COLLINGSWORTH:

6 Q Mr. Mattos, you testified that a man named

7 Niki was at the May 2001 meeting where you saw

8 Mr. Araujo and someone you believe was Mr. Adkins,

9 correct?


11 Q What happened to him?

12 A He was -- he was made to disappear, you

13 know. He was executed by the AUC themselves.

14 Q How long after the May 2001 meeting before

15 Niki was executed?

16 A No, I don't remember, but I think he was

17 made to disappear when I was in jail the first time.

18 Q Was there a man named Adinael on the

19 operation to kill the union leaders?


21 Q What happened to him after that operation


158

1 to kill the union leaders?

2 A He was murdered and then they disappeared

3 the body afterwards.

4 Q And do you know who ordered his murder?

5 A I believe Tolemaida.

6 Q And you mentioned another gay named Omega

7 who killed some of the union leaders, correct?

8 A Yes, of course.

9 Q And what happened to him after these union

10 murders occurred?

11 A He was the commander of the Resistencia

12 Motilona Front and after the demobilization he was also

13 murdered.

14 Q A lot of your friends and colleagues in the

15 AUC were murdered, right?

16 A Yes.

17 Q And some of their family members were

18 murdered, correct?

19 A Yes, also.

20 Q And when you were answering Mr. Jeffress'

21 questions that in the April 23rd, 2009 Charris


159

1 testimony and in the November 23rd, 2009 justice and

2 peace testimony you said you wanted some conditions.

3 What were you concerned about?

4 A Yes.

5 Q What were you concerned about?

6 A The war has only left me my family. And,

7 you know, as I have always said in the free versions I

8 will never trade truth for death. And, you know, the

9 life of my family comes above all else because I know

10 how things go down here in Colombia. I was in the

11 inside once. And so I received many, many threats.

12 Q And, in fact, at the April 23rd, 2009

13 testimony of Charris you specifically told the

14 prosecutor and the judge that there were things that

15 you were not going to talk about unless you were given

16 protection.

17 MR. JEFFRESS: Objection, leading.

18 THE WITNESS: I have mentioned this on

19 several occasions before the OIT, during the

20 proceedings for Judge 11. And I said this to the judge

21 during the proceeding for Mr. Charris and also before


160

1 the prosecutor at the justice and peace process.


3 Q What did you tell each of these tribunals

4 or judges that you have mentioned was your concern?

5 MR. JEFFRESS: Objection, compound.


7 Q Let me break it down so we don't have a

8 problem. On the April 29th -- April 23rd, 2009

9 testimony for Charris what did you tell the prosecutor

10 and the judge about your testimony?

11 A The safety of my family because they had

12 been threatened.

13 Q Did the prosecutor or judge respond to your

14 concern?

15 A Well, before then, before the prosecutor

16 number 12, before the human rights Court, I had

17 denounced that situation.

18 Q What situation are you referring to?

19 A To death threats. I made -- I denounced

20 this, you know, all the way from Barranquilla during

21 one of the free versions before I believe Judge Daisy


161

1 Jaramillo. I denounced the fact that an attorney hired

2 by Tolemaida had gone -- I think his name was Cesar

3 Vaca -- to the model penitentiary to threaten me.

4 And that I remember this was something that

5 happened to an extent that the guards had to react

6 because I got very angry when I received these threats

7 from Tolemaida.

8 Q And what was the nature of the threat?

9 A The testimony. You know, the testimony

10 that I was beginning to provide during the justice and

11 peace process and this was way before this.

12 Q Was there something that either Tolemaida

13 himself or his lawyer Vagas or Vaca told you not to

14 say?

15 A Yes. They didn't want me to testify. You

16 know, they just didn't want me to provide testimony

17 during the entire justice and peace process.

18 Q Testimony about what?

19 A Anything that pertained to the relationship

20 between society and the AUC; anything pertaining to the

21 death of the woman judge; anything pertaining to the


162

1 link between the military and the AUC; anything

2 pertaining to the deaths of the Drummond union leaders;

3 anything pertaining to the politics, the relationship

4 between politics and the front; anything pertaining to

5 the creation of a political group for the front.

6 Q And you told Mr. Jeffress earlier that when

7 you were in the jail in Barranquilla the same time as

8 Tolemaida he offered you money; is that correct?

9 A (Speaking Spanish).

10 Q Let me ask another question then.

11 A Yes, and also --

12 Q What did he tell you exactly?

13 A Well, in Barranquilla Tolemaida offered all

14 of us who were there in Barranquilla, all of the

15 members of the front, money.

16 He even proposed that I retract all of the

17 statements that I had previously given because he had

18 received monies -- and he told me just like this, he

19 had received monies from Drummond and that he was going

20 to give everyone some money.

21 And then after this apparently he had


163

1 problems with everyone at the front because apparently

2 he didn't give money to anyone. And in spite of this

3 he was taking luxuries inside the jail and, of course,

4 people got angry. Like, for example, building a door

5 for the cell that costs 2 or 3 million pesos.

6 Q Did Tolemaida ever threaten you directly

7 about the Drummond testimony?

8 A Yes, of course.

9 Q Can you tell me what he said?

10 A I remember that after a collective free

11 version that was invalid legally for the reasons that I

12 gave before, we had a small skirmish, you know, with me

13 and one of the other candidates. And, you know, he

14 practically told us that we had families outside and

15 that he had money to -- with which to do whatever he

16 wanted.

17 And, you know, that free version that was

18 shown on the video lasted 6 or 12 weeks, but I was only

19 there twice. And other candidates were only in

20 attendance two or three days.

21 Q Were you present when Tolemaida either


164

1 offered money to or threatened any of the other members

2 of the Juan Andrés Álvarez Front besides you?

3 A Yes, of course.

4 Q Can you tell me who?

5 A Francisco Gaviria.

6 Q Anybody else?

7 A No. I only remember Francisco Gaviria and

8 he denounced this.

9 Q On April -- on the April 23rd, 2009

10 testimony you gave for Charris you mentioned -- based

11 on what Mr. Jeffress asked you in the testimony

12 transcript -- you mentioned Tolemaida and Jaime Blanco,

13 but you did not mention Alfredo Araujo; is that

14 correct?

15 A No, I did not mention him.

16 Q And why not? Why didn't you mention him at

17 that time?

18 A Well, Alfredo Araujo is a very powerful

19 person here in El Cesar and I had prior threats. And

20 so I limited myself to the proceedings for Mr. Charris.

21 Q And you told the prosecutor you were doing


165

1 that?

2 MR. JEFFRESS: Objection, leading, no

3 foundation.

4 THE WITNESS: I didn't understand the

5 question.


7 Q Did you tell the prosecutor in the Charris

8 proceeding that you were limiting your testimony?

9 A Yes, of course.

10 Q You told Mr. Jeffress that you weren't

11 present when Drummond or anyone from Drummond gave the

12 money to the AUC, but you did testify that you were

13 present when the money was discussed; is that correct?

14 MR. JEFFRESS: Objection, objection,

15 leading.



18 Q And you told me all of the -- you told me

19 and the Court and everyone else all of the instances

20 that you recall of money being discussed in your

21 testimony this morning; is that correct?


166

1 A Yes, of course.

2 Q In the last year, just in the last year,

3 have you been threatened about your testimony that you

4 were giving about Drummond?

5 A No. In these past two months of the

6 current year, no, I have not received any type of

7 threats. I've actually been very much relegated or

8 aside from everything outside. And, moreover, I

9 decided not to testify anything with the Colombian

10 justice.

11 MR. COLLINGSWORTH: I have no further

12 questions, Your Honor. Thank you very much.

13 MR. JEFFRESS: Could I just ask one

14 further, one other?

15 THE COURT: Yes, you can, sir.

16 EXAMINATION BY MR. JEFFRESS:

17 Q So when Tolemaida told you that he got

18 money from Drummond and he was going to share it with

19 you, did you tell him you don't want any?

20 A Yes, of course. At that time I already had

21 issues with him. I already had received threats.


167

1 Sometime ago before the transitional justice process

2 begun I received a visit in the judicial jail. That

3 was like around in 2006.

4 MR. JEFFRESS: Move to strike as

5 nonresponsive what you told Tolemaida.

6 THE WITNESS: Well, but I believe I did

7 respond to your question.

8 MR. JEFFRESS: That's all.

9 THE COURT: Having complied with the

10 requirements of the Letters Rogatory we will officially

11 then conclude these proceedings. As required in the

12 Letters Rogatory we will return all pertinent material

13 in a timely manner.

14 Then the proceedings have hereby been

15 declared as ended. And thank you all for your time.

16 MR. JEFFRESS: Thank you, Your Honor.


18 THE VIDEOGRAPHER: This concludes the

19 video-recorded deposition at 5:44.

20 (Hearing adjourned at 5:44 p.m.)

21


168

1 District of Columbia, to wit:

2

3 I, Steven Poulakos, Registered Professional

4 Reporter and Notary Public of the District of Columbia,

5 do hereby certify that the within-named witness

6 personally appeared before me at the time and place

7 herein set out, and after having been duly sworn by me,

8 according to law, was examined by counsel.

9 I further certify that the examination was

10 recorded stenographically by me and this transcript is

11 a true record of the proceedings.

12 I further certify that I am not of counsel

13 to any of the parties, nor in any way interested in the

14 outcome of this action.

15 As witnessed my hand this 27th day of March,

16 2012.

17 _________________________

18 Steven Poulakos

19 Notary Public

20 My Commission Expires:

21 May 31, 2013

Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.

Letters Rogatory Video Hearing - Vol. 1March 12, 2012

$

$1.5 (1) 56:16$150,000 (1) 56:18

[

[sic] (3) 12:1;77:8;145:3

0

05 (2) 50:10;54:2078 (1) 20:12084 (2) 19:20;20:13

1

1 (6) 22:3,4;56:15;119:5; 125:15;156:21:30 (1) 76:1710 (1) 153:910:50 (1) 52:16100 (1) 129:12100,000 (1) 56:1810th (2) 12:9;58:111 (2) 82:7;159:2011:07 (1) 52:1711th (2) 11:11,1512 (8) 5:18;8:19;124:1,7; 130:13,19;160:16; 163:1812:00 (1) 76:1612:01 (2) 77:4,51299 (1) 3:912th (2) 9:17;95:714 (1) 125:181996 (1) 11:111997 (1) 10:20

1999 (1) 11:4

2

2 (7) 34:12,16;102:8,11; 129:9;140:3;163:52:09-cv-1041-RDP (2) 9:16;77:172:25 (1) 77:62:30 (1) 77:820 (1) 152:112000 (7) 12:21;13:1,2;26:5; 33:16,17;132:1020004 (1) 3:102001 (16) 48:3,3;49:1,6,19;52:9; 53:4;75:11;123:18; 125:3;129:6;132:12; 136:3,19;157:7,142002 (13) 12:4,6,9,17;13:5; 37:11;58:1,11,18;74:21; 75:1;79:2,132003 (5) 12:11;14:16;82:2; 83:5;129:12005 (6) 14:16;61:19,20,20; 78:16;80:22006 (2) 11:15;167:32008 (2) 116:21;145:212009 (24) 20:4;21:1;85:10,21; 89:2;91:3;94:5,20; 95:18;97:18;100:8; 101:15;102:4;107:2,2; 108:7;145:6;152:21; 154:8;158:21;159:1,12; 160:8;164:92010 (1) 132:182012 (1) 9:17202-639-7700 (1) 3:11202-639-7890 (1) 3:1223rd (21) 85:9,21;89:2;91:3; 92:2;94:4,19;95:12,18; 97:17;100:8;101:15; 102:3;107:2;108:7; 154:7;158:21;159:1,12; 160:8;164:9

24 (1) 83:824th (1) 132:17250 (2) 58:2;119:1129th (1) 160:8

3

3 (4) 136:13,13,14;163:53:57 (2) 124:17,18

4

4 (2) 156:14,154:00 (2) 129:14;130:24:15 (1) 124:194:30 (3) 124:6;130:2,840 (2) 51:11;82:64th (6) 20:4;21:1;94:4,19; 107:2;152:21

5

5:44 (2) 167:19,205:45 (1) 151:16

6

6 (2) 8:19;163:186:00 (2) 151:16,21600 (1) 63:2

7

7:00 (1) 130:37:15 (4) 124:1,8;130:3;131:270 (2) 57:20;58:877 (1) 58:1478 (1) 25:14

8

8 (1) 102:1784 (1) 25:1484.082.05.28 (1) 5:10

9

9 (1) 102:179:00 (3) 129:15,19;130:49:14 (1) 9:1797 (1) 103:3975 (2) 21:12;83:1298 (1) 140:7

A

able (15) 15:15,18;23:10;33:11; 42:3;62:2;87:8;88:17; 89:8,17;90:10,12;92:11; 93:15;126:14above (2) 8:21;159:9abroad (3) 94:9;108:1;126:5abruptly (1) 152:2accept (3) 6:7;24:15;80:7access (1) 127:11accompanied (3) 105:4;114:20;140:14accordance (5) 22:14,18;23:1,12,18according (6) 8:11;21:12;22:13,16; 23:7;47:12accounting (4) 128:12,15,17,18accredited (1) 7:4acknowledged (1) 122:4act (5) 43:20;87:16;88:4; 135:10;154:13acted (1) 15:16actions (2) 68:17;69:7active (1) 11:2activities (1) 65:5

acts (2) 122:7,7actual (4) 16:20;21:3;135:4,5actually (12) 20:14;28:12;68:14; 73:7,10,16;74:12,17; 106:2;118:11;120:3; 166:7add (2) 25:6;76:19addition (1) 10:13address (1) 5:5Adinael (5) 43:9,10;45:11,20; 157:18A-D-I-N-A-E-L (1) 43:10adjourned (1) 167:20Adkins (4) 91:4;106:15;154:21; 157:8administration (5) 110:2;120:12;121:10, 13,16administrator (4) 87:2;96:20;97:7;110:2administrators (1) 100:3admit (2) 22:1;24:15admitted (1) 21:17advanced (1) 88:16advised (1) 78:4afford (2) 7:19;9:3afraid (4) 94:10,13;97:9;156:1afternoon (9) 46:19;77:8,8;78:12; 124:3,10;131:3,7,9afterwards (3) 56:17;111:17;158:3again (35) 20:9;25:13;30:16; 31:16;43:19;75:14,19, 21;76:1,2;77:10,21; 87:1;89:6;92:4,5;93:12, 14;95:21;96:6,19; 108:14;115:1,7;116:5; 120:10;124:9,21;128:1; 133:8;137:14;139:8; 140:3;141:3;148:20against (25) 8:14,14,15;16:7;60:6; 61:13;66:14;68:2,7,9; 69:18;77:17;95:10;

Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com

(169) $1.5 - against



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24:11Alvarez (7) 12:19;13:6,17;21:21; 26:10;31:20;32:5

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Álvarez (22) 11:6;12:18;31:12; 39:18;41:7;43:12;52:7; 53:8;57:4;59:9;62:17; 75:8;126:9,15,19;127:9, 20;132:3,7;143:17,21; 164:2

A

ALVEAR (4) 3:20;7:6;112:18,20always (8) 15:14;68:4;104:1,19; 105:14;107:8,9;159:7Amacho (1) 50:10Amador (1) 49:9American (8) 50:15,21;54:2;75:13; 76:2;125:10,20;126:3among (1) 52:1amongst (1) 153:18amount (1) 60:18Andrés (21) 11:6;31:12;39:18; 41:7;43:12;52:7;53:8; 57:4;59:9;62:17;75:8; 126:9,15,19;127:9,20; 132:3,7;143:17,21;164:2Angel (1) 82:10angry (2) 161:6;163:4answered (4) 93:3,11;98:19;108:11anymore (1) 90:13apologize (1) 102:21apparently (3) 89:15;162:21;163:1appear (1) 99:15appearance (1) 154:7APPEARANCES (1) 3:1appearing (1) 132:21appears (1) 131:12

approach (5) 19:9,12;34:10;102:5; 139:21approached (1) 113:13approval (1) 36:2approximately (5) 9:17;49:1;74:20; 123:21;130:4April (18) 14:16;58:10;61:20,20; 78:15;80:2;100:8; 101:15;102:4;107:2; 108:7;125:3;158:21; 159:12;160:8,8;164:9,9Araujo (17) 38:4,10;50:12;54:3; 55:14;75:12,14,20;91:4; 106:10,14;107:4;153:9; 154:21;157:8;164:13,18A-R-A-U-J-O (1) 34:6Araújo (14) 34:6,19,20;35:3,11; 36:5,7,16,16,20,21; 37:15,17,21Araujo's (1) 152:15area (43) 30:21;31:7;43:12; 47:17;59:5;60:10,10,13, 15,17,19,20;61:1,12; 62:7,14,20;63:5,15,20; 64:7;65:6,7,8,10,12,19; 66:11;67:15;68:2;69:5, 11;70:17,20;71:4,21; 75:8;79:21,21;128:17; 146:7,9;150:21areas (13) 14:7;15:2,5,5,6;19:2; 61:8,12;69:8,8;70:19,19; 120:14argumentative (6) 93:11;96:18;101:6; 104:10;134:18;137:5Aristides (7) 39:13;41:1,10;47:6; 109:2,2;110:15arm (1) 67:11armed (3) 46:9;47:1;58:2arms (5) 19:3;42:4;65:21;66:1; 72:20Army (15) 15:12,16,17;16:7,12; 65:20;73:7;74:10;79:5, 6,11,14;146:12;150:3,3around (9) 61:17;63:20;64:7,11; 73:20;80:14;120:13;

131:2;167:3arrangements (1) 66:9arrest (1) 80:2arrested (6) 78:15,20;79:1,4,8,12arrived (14) 58:16;100:16;101:16; 114:2;123:17;130:2,5; 132:2,6,12;135:21; 136:2,19;137:7arriving (1) 58:12Arza (2) 71:11;145:4aside (4) 25:20;82:11;143:4; 166:8assassinate (4) 18:9;33:13;43:14; 44:17assassinated (1) 64:13assassination (1) 155:9assist (1) 84:4assistance (3) 7:16;22:19;77:13assistant (1) 131:14assumed (1) 37:12attachment (2) 119:9,16attacks (1) 92:15attempted (1) 93:3attempts (1) 60:6attendance (1) 163:20attended (4) 106:9,12;125:3,4attention (3) 51:6;87:3,4attentive (1) 55:1attorney (20) 56:8;78:3,6;83:17,20; 84:1,15,21;85:4;89:19; 114:3,4,16;115:2,12,19; 134:11,11;136:2;161:1attorney-client (1) 84:20attorneys (1) 83:18attributable (1) 120:13attributed (2) 21:13,20

AUC (77) 10:7,19,20,21;14:4,19, 21;15:8,19,20;16:3,9,10, 11;17:4,12,14,16;18:11, 14,16;30:12,13;31:10; 37:10,13,17;39:7,9,21; 41:7;60:4;66:4;67:18; 68:6,11;69:5,6,9,14; 70:6;71:21;72:10;74:9; 87:14;88:1;105:16; 109:7,10;111:4,21; 114:9,13;115:14,16; 120:8,13,16;121:12,15; 122:6,10;126:5;135:8, 21;142:15;143:2,7; 148:1;153:13,19; 154:10;157:13;158:15; 161:20;162:1;165:12AUC's (4) 38:9;69:21;73:18; 81:20audio (2) 89:11,12August (3) 13:2;23:9;132:10Augusto (1) 77:19authenticated (1) 131:14authentication (1) 22:10authorities (4) 8:18;23:1;84:10;94:15authority (2) 12:7;18:7authorization (1) 110:1authorized (1) 110:6Auto (1) 11:7avail (1) 84:8available (2) 18:7;66:1Avenue (1) 3:9avoid (1) 67:6aware (7) 47:15;48:18,19;97:19; 98:5;107:9;127:14away (3) 35:16;46:14;151:5Azucar (1) 58:5A-Z-U-C-A-R (1) 58:5

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back (16) 12:9;15:21;38:19;


(170) age - back



40:17;46:6;49:16;58:3, 14;71:6;76:16;90:20; 104:11;114:4;115:2; 131:7;152:17background (1) 135:20bad (1) 30:5Badelco (3) 44:13;45:7;46:12B-A-D-E-L-C-O (1) 44:13Baden (1) 44:8B-A-D-E-N (1) 44:8Baker (1) 3:8Balcero (2) 9:12;77:17Barranquilla (10) 113:17,19,21;116:16, 19;123:7;160:20;162:7, 13,14Barreto (1) 91:13base (1) 73:16based (4) 70:13;89:16;151:15; 164:10basically (1) 60:20battalion (2) 66:10,13battalions (1) 66:12BCB (2) 11:4;54:16became (5) 59:10,14;61:18; 109:15;137:7Becerril (11) 12:7,15,15;13:9;59:5; 60:19;73:4,15;81:5; 83:3;150:14B-E-C-E-R-R-I-L (2) 12:8,15begin (6) 5:2;6:14;9:7;35:9,15; 77:10beginning (4) 75:1;91:14;145:2; 161:10begins (1) 20:11begun (1) 167:2BEHALF (4) 3:3;9:21;110:2;118:19believes (1) 23:13belong (1)

21:14belonged (1) 62:17benefit (1) 84:9benefits (2) 84:5,7Berija (2) 150:15,17B-E-R-I-J-A (1) 150:17Besides (2) 116:1;164:2best (3) 6:19;54:5;76:9beyond (2) 23:3;93:3bit (4) 49:16;51:11;67:8; 105:1Blanco (39) 26:11,12,15;27:20; 28:19,20;31:13;32:10; 38:10;50:12;52:10,10; 54:4;55:14;75:13;97:19; 98:5;99:4;101:3;103:6, 20;104:7,13;105:4,11; 106:3,9;108:8,17,19; 109:5,9;111:16,19; 112:5;123:4;138:10; 143:5;164:12B-L-A-N-C-O (1) 26:15BlancoJaime (20) 55:14;75:12;97:19; 98:5;99:4;101:3;103:6, 19;104:7,12;106:3,9; 108:8,17,19;109:9; 111:16,19;112:4;123:4Blanco's (4) 138:19;141:9,11,12Bloc (16) 11:1,20;12:20;13:3; 14:21;37:7,10,10,13,13; 56:13;81:20;82:15; 126:12,19;136:3block (1) 110:17blocs (1) 126:16blondish (1) 51:3blown (1) 61:11blurry (1) 34:19Boca (2) 47:8,13B-O-C-A (1) 47:13bodies (3) 147:18,21,21body (1)

158:3bodyguard (3) 50:18;137:8;139:12bodyguards (1) 57:9Bogotá (1) 80:11Bolívar (1) 11:1Borri (3) 47:7,8,11B-O-R-R-I (1) 47:11borrowed (1) 43:9Bosconia (4) 49:7;61:2;65:8;103:16B-O-S-C-O-N-I-A (1) 49:7both (4) 35:20;65:9;109:8,11bottom (2) 19:19;141:13Botts (1) 3:8boys (2) 54:12,13branch (1) 81:2brand (1) 28:15break (8) 52:14;53:2;76:8,10, 14;124:13;151:9;160:7bring (4) 40:16;111:12,13; 114:6bringing (2) 39:18;40:1broke (1) 129:4brother (1) 26:20Brothers (2) 10:1,3brought (1) 74:13BRYAN (2) 3:5;7:11Buena (2) 58:5,5building (5) 38:20;39:3,6;40:18; 163:4bus (10) 44:1;45:17,17,20,21; 46:1,7,8,9;47:1buses (2) 45:15;130:5business (1) 146:1businesses (3) 63:5,7;127:10

businessman (1) 125:4buy (2) 42:3;123:12

C

cafeteria (1) 88:9call (13) 27:5;28:2,7;45:14; 51:3;54:8;58:6;64:6; 68:16;124:6;130:2,3,8called (16) 8:3;11:5;28:19;38:20; 44:8,19;45:8;48:12; 49:8;54:9;55:5;64:14; 66:14;71:1;73:12;157:3calls (2) 64:8,16came (8) 12:9;28:17,18,20; 54:16,20;55:18;123:19camera (4) 5:13;98:7,7,9Can (56) 10:18;11:16,19;12:16; 14:14;16:16;17:9;19:13; 20:2;21:4,5;24:21;25:2, 8,13;26:17;28:3;31:19; 33:21;34:16;39:14; 42:11,13;43:14;44:5; 50:7,21;51:1;55:21; 59:3,17;60:14;67:7; 69:3,3,17;70:11,12;73:1; 74:5;76:10;82:20;89:12; 102:13;103:13,14; 107:14;114:21;118:3; 131:9;134:8;143:13; 151:15;163:9;164:4; 166:15candidates (8) 72:6;92:15,20;119:19; 120:11;121:11;163:13, 19Canoso (5) 71:12;145:4,13,14,15capture (3) 11:9;18:8;63:1captured (8) 12:6,17;18:6;31:11; 61:19;79:13,20,21carefully (1) 142:13Carlos (2) 54:9,10carried (2) 57:12;124:7carry (1) 58:4Casa (2) 130:3,10Case (11)

9:16;22:20;77:16; 89:9;101:4;110:18; 114:6;118:16,20;136:2; 148:14cases (2) 70:8;92:13casino (7) 27:5;28:3,4,18;29:2; 105:15;140:15Castro (8) 27:11,14,16;28:18; 29:18;40:4;104:14; 106:18C-A-S-T-R-O (1) 27:17cattle (6) 74:13;82:11,13;83:2, 7;127:10CD (1) 92:14Cebolla (1) 71:10C-E-B-O-L-L-A (1) 71:10cedula (1) 5:10cell (4) 109:18,20;110:17; 163:5center (2) 67:1,2Central (5) 10:21;14:20;81:7,9; 82:14certain (8) 14:7;88:10;98:15,16; 99:5;148:5,5;151:14certified (2) 136:10,11Cesar (11) 12:7,8;81:5;83:3; 123:18,18;132:12; 135:21;146:2;161:2; 164:19C-E-S-A-R (1) 12:8cetera (1) 5:6chairs (2) 28:15,16change (2) 116:10;137:19changes (1) 57:19Channel (1) 5:18charge (12) 14:6;15:4;43:1;50:3; 51:19;56:11;64:20; 71:14;144:20;145:1; 147:21;151:13Charrez (2) 27:11,13


(171) background - Charrez



C-H-A-R-R-E-Z (1) 27:13Charris (37) 27:20;28:17;29:18; 32:10;40:4,15;41:1,11; 100:6;103:5;104:3,13; 105:14,21;106:7,18; 108:16;109:13,15;110:4, 8,9;123:20;124:6; 129:10;130:1,12; 131:13;139:9;140:5; 158:21;159:13,21; 160:9;164:10,20;165:7C-H-A-R-R-I-S (1) 27:15Charris's (1) 106:2Chibono (1) 54:17C-H-I-B-O-N-O (1) 54:18chief (13) 12:2,5;26:9;29:19; 30:13;36:14,15,18;37:5; 40:12;57:7;73:19; 152:18childhood (3) 37:18;153:9,14children (1) 37:20Chiriguana (1) 61:1Christian (1) 71:13church (1) 28:13Circuit (2) 9:20;77:9citizen (6) 50:3;54:2;55:8,13; 103:15;107:13citizens (2) 6:9;49:13city (2) 67:1,2civil (1) 16:4claim (2) 103:18;148:8claimed (1) 95:11clandestinely (1) 55:11clarification (2) 29:12;155:12clarify (4) 45:1;75:2;78:14; 143:14clarifying (1) 12:16clash (1) 69:10clashes (3)

66:3;67:17;70:3clashing (1) 67:7Claudia (2) 9:12;77:17clean (1) 15:6cleaning (1) 69:7cleanup (1) 69:9clear (9) 23:19;24:21;30:19; 31:19;35:8;36:19;97:1; 106:19;107:9clearly (1) 93:6CLERK (1) 77:7close (9) 40:5;50:20;56:4; 108:7;109:15;138:6; 139:19;144:18,20closeness (2) 51:17;57:8closer (1) 144:10co-counsel (2) 7:1,2Codazzi (1) 13:13C-O-D-A-Z-Z-I (1) 13:13Colectivo (2) 112:18,20collaborated (4) 87:16;88:3;135:10; 154:13colleagues (1) 158:14collective (1) 163:10collectively (1) 77:19COLLINGSWORTH (105) 6:5,15,16;9:6;10:4; 11:18;16:15,17;18:15; 19:8,11,14,18;22:1,7; 24:7;25:6,12;26:16; 27:8,15,18;28:21;30:15; 32:3,8;34:9,14;38:18; 47:14;52:15,21;53:1; 68:19;69:2;72:11,16; 75:17,18;76:5,15,18; 77:2;81:11;82:17;84:3, 12,19;86:4;89:14;92:3; 93:10,19;96:16;98:18; 99:6;101:5;104:9; 108:10;111:7;113:14,15, 21;114:20;115:4;116:4, 8,15;117:2,9,15,19,21; 118:6,8,19,21;119:7; 125:6,20;126:21;

130:20;134:17;135:14; 136:6;137:4,14;138:12; 146:3;152:4,8;155:2,12, 14;156:3,4,20;157:4,5; 160:2,6;165:6,17; 166:11;167:17Colombia (25) 8:8;9:20;10:11;15:7; 17:7;20:5;22:15;26:21; 44:2;77:7;81:3;84:18; 87:3,12;88:18;94:2,9,17; 107:8,14;112:18; 117:12;121:10;123:1; 159:10Colombian (19) 12:7;15:11;55:5;65:6; 84:9;91:9;92:17;94:15, 21,21;96:9;108:4;112:9; 146:12;148:16,21;149:8, 9;166:9Colorada (2) 46:16,18C-O-L-O-R-A-D-A (1) 46:18colored (1) 44:10combating (1) 62:13coming (3) 17:8;97:2;108:2command (12) 14:20;54:13;57:3; 59:6,8,21;79:19;81:7,10; 82:14;128:21;153:20commanded (2) 37:11;48:12Commander (38) 12:1,2,3,13,14;13:8, 10,17;14:18,19;15:1; 31:20;32:5;37:9,12; 41:2,16;45:20;51:18; 52:5,7;58:13;59:4,14; 65:8;72:18;74:2,7;75:3, 4;79:15;87:15;88:2; 114:13;128:16;135:8; 154:11;158:11commanders (1) 40:8comments (2) 16:14;41:17commit (1) 68:12commitment (2) 10:16;60:3committed (2) 80:18,19common (2) 17:13;148:5communicate (2) 111:1;114:17communication (3) 45:10;110:7;149:20communications (1)

40:15communities (1) 64:11community (3) 130:10,10;153:1como (1) 129:14companies (2) 62:15,19Company (8) 9:13;36:21;42:18; 55:5;64:1,20;77:18; 153:1compelled (1) 8:14competent (3) 8:18;18:7;25:2complaint (5) 118:18;138:9,15,19,21complaints (2) 92:15;120:4complete (1) 131:19compliance (3) 7:15;77:13,21complied (1) 167:9comply (1) 152:10compound (1) 160:5concern (2) 160:4,14concerned (2) 159:3,5concerns (1) 92:1conclude (1) 167:11concludes (1) 167:18conclusion (1) 141:16condemned (2) 85:17;87:6conditions (1) 159:2conduct (1) 36:2conducted (1) 47:4confess (1) 97:12confessed (2) 71:18;84:17conflict (4) 15:7;17:7;63:6;123:1conflicts (1) 66:5confrontations (2) 73:14;79:12confused (1) 156:1

congratulate (1) 54:20congratulated (2) 53:9,16congratulations (1) 54:10consent (1) 65:1consider (1) 23:6considerable (1) 63:1Considering (1) 8:21construction (1) 28:11contact (1) 18:20continue (4) 25:9;52:18;77:11;78:2CONTINUED (1) 3:1continues (1) 78:4continuing (1) 151:11contra (1) 66:13contract (1) 26:19contractor (2) 26:18;112:2contributed (1) 120:8contribution (2) 72:6,13contributions (1) 62:19control (1) 126:18convenient (4) 134:15;135:1,2;149:7conversation (1) 103:19conversations (5) 58:12;84:11;103:7; 106:3;115:11conveys (1) 8:19convicted (3) 44:2;80:17,18convictions (2) 83:9,10cooperate (1) 35:20cooperation (2) 35:20;47:15coordinate (9) 63:15,17;65:5,7,9,12; 66:5;67:16;80:1coordinated (2) 67:3,6coordinating (2)


(172) C-H-A-R-R-E-Z - coordinating



65:14;79:10coordination (6) 65:20;66:3,7;68:5; 72:17;146:16coordinators (1) 79:16Copetra (1) 55:6C-O-P-E-T-R-A (1) 55:6copy (4) 19:12;102:12,14; 154:3correction (2) 11:13;44:13correctly (1) 115:10corridor (3) 60:12,15;65:4corroborated (1) 147:9costs (2) 128:13;163:5Counsel (16) 5:20;6:14,16;25:7; 32:1;75:15;87:18;98:1; 117:16;130:14;133:3, 12;143:13;144:9; 145:18;151:17country (7) 8:10;15:10;16:2;18:3; 22:15;65:17;107:13course (109) 10:20;13:18;16:5,8, 15;17:5,21;19:7;20:1,8; 21:9;25:18;26:13;29:17, 19,20;31:10;32:3,7,13; 33:2;34:1,8,11;35:1; 36:3,10;40:11;42:10; 44:4;45:4,12;48:20; 53:6,18;57:20;58:17; 59:2;60:21;64:9;65:1; 66:8,21,21;67:9;69:16; 70:5,15;71:18;72:2,21; 73:18;74:8;77:1;80:4, 10;83:13;86:3,12,19; 89:14;90:7;94:1,12,16; 95:16;98:11;100:7,9,14; 103:11;104:19;109:4,14, 17;110:16;112:11; 122:11;124:15;126:1; 127:3,18;129:2;136:20; 137:2,18;138:2,8;139:7; 140:6;141:1,9;142:1; 144:1;146:21;148:10; 150:6;155:5,10;157:10, 20;158:8;163:3,8;164:3; 165:9,16;166:1,20COURT (75) 5:2,3,16,19;6:3,7,12; 7:3,14;8:6,12;9:3,9,10, 14,20;10:2;19:10,13; 22:11;23:6,13,18;24:10,

12,14,18;25:11;26:14; 34:11;51:4;52:12,13,18; 76:13,16;77:1,9,15,21; 78:8;80:11;81:13;86:3; 89:18;90:12;93:20; 100:15,18,19;101:1,14; 102:7,12;104:6;105:9; 106:1;124:15,20;130:11, 17;131:14;140:1;151:8, 10,10;152:1,7,9;156:17; 157:2;160:16;165:19; 166:15;167:9courtroom (3) 5:13;6:19;100:2Court's (1) 24:11cows (1) 74:14create (2) 42:17;72:1created (1) 62:17creation (1) 162:5credit (1) 148:9crew (1) 47:3criminal (5) 43:20;77:9;80:11; 100:5;122:6cross (1) 7:20Cuadrado (1) 116:1Cuarenta (12) 11:7;37:9,12;49:21; 50:1,8,9,20;53:7;54:1; 61:5;127:4Cuarenta's (1) 37:18Cuatro (1) 45:8C-U-A-T-R-O (1) 45:9Cuellar (1) 7:1current (1) 166:6currently (3) 5:11;109:19;110:16custody (1) 73:8custom (1) 76:20

D

Daisy (2) 133:14;160:21Danubio (1) 58:7D-A-N-U-B-I-O (1)

58:8dark (2) 33:11;124:4darkly (1) 46:3Dasa (5) 56:9;145:2,3,5,6database (3) 119:18;120:1,9date (6) 9:16;11:10;20:2; 113:16;116:14;132:16DAVIS (3) 3:6;7:9,9dawn (1) 55:16day (8) 20:4,6;86:18;93:9; 96:7;129:4;131:18; 133:7days (1) 163:20DC (1) 3:10de (20) 13:10;26:6;28:17; 29:17;40:4;41:10;49:14; 59:7;66:16;73:4;100:6; 104:13;106:18;109:12, 15;110:7,9;130:3,10; 150:14D-E (2) 13:12;27:13deal (1) 65:13dealt (2) 43:16;53:12death (7) 87:15;88:2;135:9; 154:11;159:8;160:19; 161:21deaths (3) 107:15;137:21;162:2deceased (1) 56:8December (10) 12:9;20:4;21:1;58:1,1, 18;94:5,19;107:2; 152:21decided (3) 116:7;121:6;166:9decides (1) 120:17decision (1) 121:3declaration (13) 21:3;93:19;94:11; 107:3;119:4,10;125:14, 19;152:20;153:8; 155:17;156:2,6declarations (1) 118:15declared (1)

167:15DEFENDANTS (12) 3:3;7:3,8,10,12,20; 76:8,19;77:20;78:3,11; 157:1Defendant's (1) 156:14Defendants' (4) 78:6;102:8;136:14; 156:15defender's (1) 83:19defensas (1) 11:7Defense (4) 102:10;124:20;135:1; 136:13definitely (1) 42:2Del (3) 38:11,21;39:2D-E-L (1) 38:13delayed (1) 122:2deliver (2) 69:14,19delivered (2) 70:6,9delivery (1) 68:16demobilization (4) 10:17;11:10,14; 158:12demobilized (1) 115:13denounced (6) 95:9;134:11;160:17, 19;161:1;164:8deny (4) 113:2;124:5;130:11, 17Department (2) 77:7;146:2deposition (8) 9:18;52:16,17,19; 77:11;124:18,19;167:19depositions (1) 8:7deprived (1) 145:9descend (1) 150:21describe (4) 28:3;50:21;51:10;73:1described (6) 14:4;24:21;34:21; 38:3;60:16;75:11describing (3) 32:9;38:21;95:11details (2) 35:8,19develop (1)

42:1Diaz (1) 131:15die (1) 107:14died (2) 19:1;74:9difference (3) 16:18;17:2,5differences (1) 123:10different (2) 13:5;127:9difficult (3) 55:9;91:18;121:18dining (1) 27:6direct (3) 31:13;50:2;114:15direction (1) 41:13directly (7) 59:20;65:7;111:20; 120:15,16;142:18;163:6directors (1) 88:10disappear (2) 157:12,17disappearance (1) 92:14disappearances (2) 21:14,16disappeared (4) 120:21;121:1,4;158:2discern (1) 136:7discuss (3) 26:2;123:8;144:13discussed (12) 27:1;30:1;32:14; 33:19;35:2;41:12;55:17; 76:9;84:2;110:18; 165:13,20discussion (5) 32:21;42:6,9;45:21; 85:3disguise (1) 55:12disk (4) 89:11;136:12;156:13, 17District (4) 9:14,15;77:15,16Division (2) 9:15;77:16document (16) 19:20;20:17,19;21:6; 22:2,10,16;25:20;34:15, 18;103:10;119:14,17; 122:10;129:17;140:10done (10) 22:14;23:14;24:2,5; 33:12;74:6;76:19;78:1;


(173) coordination - done



119:12;152:11door (1) 163:4doubt (1) 131:17down (8) 18:8;65:4;105:2; 115:21;129:15;148:2; 159:10;160:7Dr (3) 115:1;133:14;156:9drafted (1) 130:7drug (3) 62:18;126:12,17drum (1) 150:18Drummond (110) 9:13;26:3,19,20;29:7, 11,15;30:4,18,21;31:1,4, 9,16,18;33:1,10;34:3,6; 35:6,15,17;37:3,6,16; 39:4,10,12,17,20;40:3,6, 7,18;41:6,21;42:2,15; 43:2,13;44:20;48:5,7; 49:3,13;50:3;51:20; 53:14;54:11;56:12; 57:15;59:19,21;60:4,9, 18;61:12;62:1;63:11,16; 64:5;65:4;66:19;72:5,9, 13;75:9,10;77:18,18,20; 78:11;80:9;88:9,9;89:5; 91:5;95:19;104:4; 110:19;114:9,11; 115:15;118:16;123:9, 13;125:21;138:1;139:6; 142:15,21;143:1,4,5,6; 144:2;149:15,20; 150:18;152:16;153:1; 155:1,8;162:2,19;163:7; 165:11,11;166:4,18Drummond's (1) 64:16due (4) 8:9;24:14;65:16; 107:11duly (1) 8:3During (20) 13:16,20;14:12;15:7; 61:18;65:3;74:6;75:4; 76:7;99:18,19;108:20; 111:17;133:13;134:20; 159:19,21;160:20; 161:10,17duties (3) 6:8;73:20;149:18duty (1) 6:9

E

earlier (4)

37:7;132:1;154:1; 162:6early (2) 130:13,18earphones (1) 90:3economically (1) 62:16economics (1) 70:12Edelmirea (1) 131:15Edgardo (1) 26:21effectively (1) 39:21efficient (1) 6:20eight (2) 83:15;113:19either (11) 11:12;18:8;47:16; 56:15,18;103:17;117:2; 123:2;131:2;161:12; 163:21El (41) 13:14;30:14;31:4,6, 11,15,19;32:4,6;38:11, 20;39:2;47:7,8,8,11,12; 58:7;71:12;73:12;74:11, 15;77:12;116:2,3,9,15; 143:10,18,20;144:6,13, 14;145:4,13,14,15; 150:4,13;151:3;164:19E-L (5) 38:12;47:11,13;58:7; 73:13ELN (2) 60:12;73:14else (14) 27:21;38:5,6;47:3; 50:6;87:16;88:3;91:5; 106:12;135:10;154:13; 159:9;164:6;165:19Email (1) 3:13EMEDAN-LAUTEN (1) 3:17emphatic (1) 104:17employee (2) 149:20;155:1encompassed (1) 61:2end (3) 42:19;134:8;141:15ended (2) 134:20;167:15Energetico (4) 66:15,17,18;74:11E-N-E-R-G-E-T-I-C-O (1) 66:18English (7)

19:15;20:10;52:3; 66:17;114:4;115:8; 126:7enough (3) 108:7;123:12;128:5entailed (1) 66:3entire (9) 13:16;33:5;37:13; 43:15;69:6;126:19; 131:13;136:7;161:17entity (2) 75:5,7entrance (2) 28:18;34:4entryway (3) 55:1,2;60:11equal (1) 16:8equipment (1) 90:21error (1) 105:19escort (2) 11:21;34:5Especial (4) 66:15,16,17;74:11E-S-P-E-C-I-A-L (1) 66:18ESQUIRE (5) 3:4,5,6,7,20Esquivel (1) 116:1establishments (1) 67:4et (3) 5:6;9:13,14even (17) 17:9,10;22:20;24:18; 41:11;44:1;57:11;65:20; 68:1;95:4,8;128:2; 131:5;133:3;134:6; 136:7;162:16events (4) 10:6;43:6;92:9;148:12everyone (4) 153:13;162:20;163:1; 165:19evidence (4) 22:2;23:11,11;71:1ex (1) 30:13exact (1) 56:3exactly (23) 12:21;14:10;16:21; 26:5;34:3;36:13;37:3; 43:5;49:10;55:16;62:2, 6;64:17,18;93:18; 113:16;116:12,17; 123:13;138:21;139:1; 155:11;162:12EXAMINATION (6)

10:4;22:14,17;78:9; 157:5;166:16examined (1) 8:5example (1) 163:4examples (1) 74:5ex-attorney (1) 26:21ex-AUC (1) 70:3except (1) 49:14excerpt (1) 132:14exchange (2) 69:13;71:1exchanged (1) 147:16exclude (1) 23:11ex-commander (2) 31:13;48:12Excuse (10) 36:20;62:10;96:2; 99:13;101:7;103:14; 105:18;112:3;130:6; 156:12excused (1) 5:15execute (1) 15:3executed (2) 157:13,15executioners (1) 14:9executions (1) 43:4executives (4) 35:14;40:5,8;55:5exert (1) 65:17Exhibit (17) 22:3,4;34:10,12,16; 102:8,11;119:5;125:15; 129:9;136:13,13,14; 140:3;156:2,14,15exist (1) 133:11ex-members (1) 69:14ex-military (1) 68:6expand (1) 56:20expect (1) 80:5expenses (2) 63:1;128:13explain (6) 67:7;69:3,3,17;147:1; 148:4

explained (2) 55:21;104:19explanation (1) 56:3extent (2) 134:8;161:5extra (1) 128:7extradited (1) 11:1eyes (1) 51:7

F

facilities (7) 28:5;34:2;40:2;49:13; 60:6,9;104:4facility (3) 66:20,20;100:2Facsimile (1) 3:12fact (10) 19:2;73:8;74:8; 106:20;107:6;132:12; 138:5,9;159:12;161:1facts (5) 21:13,20;120:3,12; 121:19faculty (2) 24:18,20failed (1) 154:1false (15) 68:16,20,20;69:1,4; 70:10,13;71:2,16;73:9; 104:8;146:19;147:17, 20;148:12families (1) 163:14family (19) 36:16;91:8,10,21; 92:8,16;94:15;95:6,10; 96:12;101:1;112:8,13, 15;120:19;158:17; 159:6,9;160:11far (3) 29:3;50:13;94:16FARC (4) 60:5,12;81:19;82:21farm (6) 49:6,8;55:2,3;58:6; 103:16feel (2) 108:18;152:1few (2) 76:20;156:21fight (7) 16:9;17:3,4,18;61:13; 68:9;69:12fighting (2) 18:11;69:18fights (1)


(174) door - fights



74:12figures (1) 62:5filed (2) 118:19;139:2final (1) 35:8find (5) 15:18;29:20;48:11; 124:12;132:16fine (3) 24:8;91:1;152:13finish (2) 151:20;152:2finished (4) 20:18;76:6;87:11; 97:11First (20) 5:4;6:12;8:3;12:6; 26:1;44:1;45:17;48:1; 49:2;53:15;58:11;66:13; 71:6;79:14;113:13,20; 117:1;129:11;137:7; 157:17fitting (1) 8:8five (3) 152:5,7,12fix (1) 123:14flatland (1) 151:5flexibility (1) 6:18floor (2) 124:20;157:2follow (2) 7:17;156:21followed (1) 71:19following (2) 5:4;7:17follows (1) 8:5follow-up (1) 53:13food (6) 26:19;29:4;30:5,5; 138:10,19footing (1) 16:8force (5) 18:2;61:16;65:18; 97:8;114:7forces (33) 11:21;12:2;16:6; 17:10;50:11;54:1;65:9, 13;66:2,21;67:12,13,16, 18,19,21;68:2,4,8,10,15, 18;69:10,16;70:10;81:8, 18;120:13;147:12,16; 148:1,6,7Ford (1)

44:11forewarned (2) 96:10;97:1forget (1) 153:6Forgive (1) 121:2form (23) 18:12;89:15;92:3; 93:10;96:16;98:18;99:7; 101:5;104:9;108:10; 111:7;117:21;118:9,21; 125:6;126:21;130:20; 134:17;135:14;136:6; 137:4,15;155:3formalizes (1) 9:8former (3) 17:12,14;120:7Forte (15) 11:8;37:8,8,21;53:16; 54:6;61:6;75:13;125:3; 126:18;127:14;128:3,7; 153:10,15forth (3) 24:4,19;92:17Forty (1) 82:5fought (3) 16:19;148:6,7found (3) 13:20;58:1;105:11foundation (19) 22:9;27:3;72:7,14; 81:12,12,12;82:18;86:5; 118:1;127:1;135:15; 137:5,15;138:13;146:4; 155:3,15;165:3foundational (1) 23:17fourth (1) 8:16frame (1) 119:1Francisco (4) 7:1;117:3;164:5,7free (12) 85:10;89:8;95:14; 97:11;108:1,1;133:2,13; 159:7;160:21;163:10,17freedom (1) 145:10friend (4) 29:18;109:12,16; 153:9friends (3) 37:19;62:20;158:14Front (78) 11:6;12:3,12,18,19; 13:6,17;14:13;21:14,21; 26:10,10;31:11,20;32:5; 34:3;35:19;39:18;40:8, 12;41:2,7,17,21;42:2;

43:12;48:11;51:18;52:8; 53:8;55:20;56:13,17,20; 57:4,5,6,12,19,20;58:1; 59:9;60:21;62:16;63:12; 71:9;75:6,9;79:16,19,20; 88:2,8;110:21;126:9,15, 19;127:2,9,20;128:6; 132:3,7;135:8;138:5; 140:3;143:17,21;144:16, 19;149:18;154:11; 158:12;162:4,5,15; 163:1;164:2fronts (3) 35:21;61:3;127:4full (2) 13:19;108:5function (1) 29:1funding (2) 57:14;58:15funds (1) 62:18further (3) 105:2;166:11,14future (4) 55:20;87:10;92:9; 107:21

G

G8 (1) 72:4gained (1) 68:3gave (15) 15:19,21;71:8,9; 85:12;100:1;103:4; 110:10;125:20;132:15; 140:13;149:16;163:12; 164:10;165:11Gaviria (2) 164:5,7gay (1) 158:6Gelvez (2) 127:15;145:11general (1) 26:21generally (1) 60:16generate (1) 30:6generation (1) 8:16gentleman (5) 6:8;46:1;82:9,10; 126:4Giraldo (2) 9:12;77:17given (12) 61:6;62:19;70:5;81:9; 82:16;84:9;98:11; 111:13;118:15;123:13;

159:15;162:17gives (1) 85:15giving (7) 19:5;95:8;143:2,9; 148:21;150:11;166:4goes (3) 20:12;45:16;113:10Good (7) 6:15;10:5;25:4;29:18; 55:20;77:8;109:12Gore (2) 10:1,3governed (2) 18:3,5government (1) 110:6granted (1) 12:10gray (1) 33:10green (2) 44:10;46:2GREGORIO (3) 3:20;7:6;71:12Gringo (1) 76:1grounded (1) 67:21group (13) 13:8;50:9;58:11,13; 61:21;64:1;67:10; 128:19,20,21;149:15,21; 162:5groups (4) 12:13,14;13:9;14:5grow (3) 42:1,2;56:20growers (1) 127:10Guajiros (1) 66:14guarantees (15) 88:14,17;89:8;92:6,7, 11;93:13,15;94:3,7;95:3, 6;100:21;104:21;108:15guard (2) 139:10;140:19guards (1) 161:5guerilla (7) 61:17;68:13;69:20; 70:4;73:14;147:12; 148:1guerillas (1) 60:5guerrillas (8) 60:5;62:14;65:16; 66:13,14;81:19;82:21; 150:21guidelines (1) 14:20guides (1)

147:8GUIOMAR (1) 3:17Gustavo (1) 48:16Gutierrez (1) 71:12guy (1) 105:15

H

Hacha (1) 5:10Hacken (1) 52:4Hackins (1) 52:4hair (1) 51:7haired (1) 51:3half (3) 12:21;26:20;53:21handed (2) 34:15;136:9Handing (1) 102:14handled (1) 114:12handwriting (1) 102:17handwritten (2) 129:12;140:7hanging (1) 63:20happen (1) 131:10happened (23) 29:8;31:10;35:5;38:7, 16;47:19;53:4;58:10; 73:5;79:17;99:19;107:1, 5,6,8;115:13;134:20; 137:10,13;157:11,21; 158:9;161:5happening (2) 42:20;85:16hard (2) 65:15;121:18harm (1) 94:11havoc (1) 134:21head (9) 14:11,12,15;43:8,10; 53:8;59:10,14;61:18headphones (1) 89:13headquarters (4) 39:4;66:15;73:17,18headquarter's (1) 40:18hear (15)


(175) figures - hear



38:1;71:6;86:7;89:12, 17;90:6,8,9,11,12; 103:17;104:1,5;115:10; 143:11heard (10) 22:13;37:19;54:19,20; 90:14;103:7,19;106:2; 143:11;153:16Hearing (1) 167:20hearsay (1) 22:10height (1) 73:12held (5) 11:20;38:10;39:6; 40:18;104:4help (3) 19:15;84:12,14helped (1) 58:4helping (3) 62:16;83:17;114:5helps (2) 111:1;121:17hereby (1) 167:14higher (1) 35:14highland (1) 151:5highlands (3) 13:9;74:14;150:15himself (6) 35:12;40:10;41:11; 50:1;134:10;161:13hired (4) 64:5,21;134:9;161:1history (1) 10:18hit (6) 14:5,6,9;60:18;65:15; 148:2hold (1) 40:6Honor (27) 5:12;6:6,16;9:6;19:8, 11;24:7;25:5;34:9; 52:15,21;76:5,12;77:2; 85:20;102:6,20,20; 105:8;124:14;139:21; 151:7;156:12,20; 166:12;167:16,17hope (1) 83:14hoping (1) 87:9hospitals (1) 127:12hour (2) 110:10;151:12hours (4) 46:19;76:15;124:10,

10house (2) 57:10;130:9huge (2) 133:5,13human (3) 18:4;95:7;160:16Humberto (1) 91:13hundred (1) 122:16hundreds (2) 62:4,6hurtful (1) 93:1hurting (1) 113:11

I

Ibirico (5) 13:11,12;66:16;73:4; 150:15I-B-I-R-I-C-O (1) 13:12ideals (1) 33:7identification (6) 22:5;34:13;86:6; 102:9;136:15;156:16identified (7) 22:3;27:20;38:20; 52:10;53:2;76:3;93:20identify (5) 5:4,7;21:5;34:16;86:1ideology (1) 122:20ill (1) 18:19illegal (2) 67:10;113:12imagine (1) 114:11immediate (1) 114:15immunity (1) 92:7implies (1) 23:7importance (1) 87:5important (3) 49:12;57:5;63:12Inc (1) 77:18including (2) 57:21;62:20inconvenience (1) 107:10Incorporated (1) 9:13indicted (1) 127:16

individuals (1) 72:12inequalities (1) 16:2inequality (1) 15:11infiltrated (1) 39:9influence (1) 70:17inform (1) 6:9information (25) 39:18;40:2,10,13,16; 41:1,4,14;57:1,2,6,13,14, 16;111:4,12,12,13; 117:15,20;118:7,12; 147:9,11,16informational (1) 21:11initial (1) 31:8Initially (4) 7:18,20;27:4;37:10INPEC (2) 151:12;152:10inquire (1) 151:3inside (7) 40:1,9;66:19;88:9; 144:15;159:11;163:3insist (1) 148:17instance (3) 73:11;92:13;149:3instances (2) 61:10;165:19instructed (1) 85:1instruction (1) 41:16instructions (2) 6:13;78:2intended (2) 96:14;97:14intercepted (1) 45:15international (5) 7:16;18:3;22:19; 65:16;77:13interpret (1) 90:14INTERPRETER (50) 5:17;11:17;16:13,13; 26:14;27:12,16;28:8; 30:9,9;32:1,2;38:12; 44:12,12;47:11,12; 52:11;68:21;71:5,5,6; 75:15,16;77:3;86:7; 87:18,19;89:20;90:10, 10,12;98:1,2;114:3; 115:7;117:16,17;128:9, 9;130:14,15;137:11;

143:13,13;144:9; 145:18;151:2,2;154:4Interpreters (2) 3:18;90:9interpreting (2) 25:9;90:11interrogate (1) 9:4interrogating (1) 7:19interrogation (2) 151:11,19interrupted (1) 13:4interview (10) 95:14;96:6;99:20,21; 100:1;113:20;114:2,3; 115:5;116:6interviewer (2) 135:7;154:10interviews (3) 91:15,17;92:14into (4) 19:2;22:2;39:9;46:6introducing (1) 6:14invade (1) 6:18invalid (2) 133:12;163:11involve (1) 86:21involved (2) 71:16;148:3irrelevant (1) 153:7I-S (1) 27:15issue (4) 11:13;52:12;104:18; 148:18issued (1) 84:9issues (6) 29:9,10;30:5;93:16; 133:17;166:21Ivan (6) 83:20;84:15;114:5; 115:1;116:3;156:8Izardo (1) 91:13

J

Jagua (7) 13:10,11;59:7;60:20; 66:16;73:4;150:14J-A-G-U-A (2) 13:11;59:7jail (12) 5:11;8:19;57:21; 58:16;110:8;116:6; 126:5;134:12;157:17;

162:7;163:3;167:2Jaime (43) 26:10,12;27:20;28:19, 19;31:13;32:10;38:10; 50:12;52:10,10;54:4; 55:14;75:12;97:19;98:5; 99:4;101:3;103:6,19; 104:7,12,13;105:4,11; 106:3,9;108:8,17,19; 109:5,9;111:15,19; 112:4;123:4;138:10,19; 141:9,11,12;143:4; 164:12Jairo (14) 27:11,12;28:17;29:17; 30:14;40:4;41:10;100:6; 104:13;106:18;109:12, 15;110:7,9J-A-I-R-O (1) 27:12James (1) 71:11J-A-M-E-S (1) 71:11January (2) 12:11;14:16Jaramillo (2) 133:14;161:1Javier (5) 56:9;71:11;145:12,17, 20JEFFRESS (114) 3:4;5:12,21;6:11;7:7, 7;18:12;22:6,9;24:10, 17;25:4;27:2;72:7,14; 78:8,9,10;81:15;83:1; 85:2,20;86:9;87:20; 88:19,21;89:10;90:1,5,8, 16,19;93:2,5,17;97:13, 16;98:3;99:1,10;101:9; 102:5,10,15,19;103:1; 104:15;105:8,10; 108:12;111:9;114:18; 115:3;117:18;118:2,14; 119:3,8;124:13;125:1,9; 127:5;128:14;130:16; 131:11;132:20;133:18, 20;134:13,14;135:3,12, 16,18;136:4,11,16; 137:6,12,16;138:17; 139:21;140:2;143:15, 19;144:11,12;145:19; 146:8;151:6,20;152:3,6, 13,14;154:2,5,16;155:6, 16;156:11,19;159:17; 160:5;162:6;164:11; 165:2,10,14;166:13,16; 167:4,8,16Jeffress' (1) 158:20Jesus (13) 27:11,13;28:17;29:17; 40:4;41:10;100:6;


(176) heard - Jesus



104:13;106:18;109:13, 15;110:7,9J-E-S-U-S (1) 27:13Jhon (2) 30:14,14Jim (2) 91:4;154:21Jimenez (1) 77:19job (5) 14:2;15:19,21;39:19; 54:10jobs (1) 15:17JOHN (2) 3:16;9:21join (2) 15:8;17:16joined (11) 10:20;11:21;12:20; 15:11,20;16:3;17:12,14, 15;31:11;105:16joint (2) 74:3,6Jorge (29) 11:7,8;37:8,8,9,11,18, 21;49:21;50:1,8,9,20; 53:7,16;54:1,6;61:5,6; 75:13;91:13;125:3; 126:18;127:4,14;128:3, 7;153:10,15JOSE (7) 3:7;7:13;13:21;56:9; 109:2;110:15;127:15José (7) 145:2,3,3,5,6,11,11JR (1) 3:4Juan (32) 11:6;12:18,19;13:5, 16;21:21;26:10;31:11, 20;32:5;39:18;41:7; 43:12;52:7;53:8;54:9, 10;57:3;59:8;62:17; 75:8;126:9,15,19;127:8, 20;132:2,6,7;143:17,21; 164:2judge (25) 81:3,4,6,10,17,18,21; 82:4,7;101:19,20; 102:14;104:14,17,20; 110:10;131:6;142:11; 159:14,20,20;160:10,13, 21;161:21judges (1) 160:4judicial (6) 8:13;77:13;81:2; 92:17;110:3;167:2June (2) 49:9,10jurisdiction (5)

23:1,4,12,16;25:2jurisdictional (1) 22:15justice (49) 10:10,14;13:21;71:20; 83:11;84:5,7,17,18,18; 85:7,10,13;86:15;87:2,2, 11;91:9,14,19,19;92:20; 95:1,2,5;96:9,13,20; 97:6;100:3;108:5; 119:19,20;120:6,12; 121:9,13,16;132:11,15; 148:16,21;149:9;159:1; 160:1;161:10,17; 166:10;167:1justification (1) 69:18justify (5) 64:10,12;68:17;69:11, 12

K

keep (1) 61:12Kener (3) 34:5;38:5;50:11K-E-N-E-R (1) 34:5kidnappings (1) 61:10kill (11) 19:3;33:12;60:10; 61:16;122:13,16,19; 147:2;149:21;157:19; 158:1killed (24) 35:18,18;44:6;45:3; 46:10,15;48:10;62:1,9; 69:15;70:3,4;120:21; 121:1,3,12,14;122:5,10; 145:6,8,21;147:7;158:7killers (1) 122:2killing (7) 44:19;48:4;53:10; 62:11;81:20;82:9;148:9killings (10) 21:15,17;35:9;47:21; 48:7;68:12,12;120:14, 15;122:7kills (1) 71:1kind (5) 66:7;68:3,11;84:6; 85:15KISIC (1) 3:18knew (15) 38:8;40:20;44:18; 45:4;49:17;87:14;96:8; 107:7,16;114:8;137:3; 138:5;144:19;145:16;

153:5knowledge (9) 22:10;31:8,12;72:5; 101:3;115:12;122:9,11; 143:18known (2) 11:5;144:15knowthat (1) 62:21

L

La (12) 13:10,15;26:5;28:7; 49:14;58:9;59:7,7; 60:20;66:16;73:4; 150:14L-A (3) 13:11;26:6;59:7lack (6) 15:10,15;27:2;86:5; 91:20;133:17language (1) 140:4laptop (1) 156:9Lara (1) 131:15large (1) 16:10largest (1) 75:5las (1) 129:14last (10) 35:8;38:17;55:8,15; 63:2;88:19;123:3; 128:10;166:2,2lasted (3) 15:21;16:1;163:18late (1) 33:15later (18) 25:8;36:14;44:18; 51:15,16;76:3;89:8; 93:18;97:10,12;105:16; 106:21;109:10;114:16; 116:11;124:12;134:12; 143:11Latiajose (1) 58:7L-A-T-I-A-J-O-S-E (1) 58:7Law (4) 21:12;22:15;83:12; 84:5lawsuit (3) 78:11;113:4;148:19lawyer (2) 84:3;161:13lawyer's (1) 112:19lead (1)

42:17leaders (35) 29:10,15;30:3;33:9, 14;35:10,16,18;43:11; 46:21;48:1,5,7,10;53:10; 80:9,20;82:7;85:11,13; 86:21;89:4,7;97:21; 98:6;123:9,21;130:18; 132:4;137:20;146:12; 157:19;158:1,7;162:2leadership (1) 33:5leading (5) 43:1;134:21;159:17; 165:2,15learn (2) 36:1;121:2learned (2) 17:6;126:6least (1) 152:4leave (3) 61:14;68:1;152:6Leete (1) 6:21left (7) 44:8;45:7;46:15; 57:21;67:11;111:18; 159:6legal (5) 6:8;7:15;22:19;23:21; 133:12legally (3) 133:9,12;163:11legislation (1) 8:11lend (3) 19:3;73:19;114:8Lending (1) 74:3lent (4) 43:9;65:21;73:9;150:3less (3) 46:19;47:9;151:18lethal (2) 61:15;69:7Letters (10) 22:12,13,18;23:4,8; 24:19;77:14;78:3; 167:10,12letting (1) 6:18lie (10) 92:4,5;96:14;97:15; 101:2;133:7,10;134:1, 15;142:7lied (4) 92:1;96:5;134:2;142:5life (1) 159:9light (3) 51:3,7,7liked (1)

15:12Limited (3) 77:18,19;164:20limiting (1) 165:8LINARES (3) 3:7;7:13,13Linda (3) 46:16,17,17L-I-N-D-A (1) 46:17line (9) 53:14;60:1,11;61:11; 62:1;63:15;64:21; 129:14;136:7link (3) 31:13;146:14;162:1links (3) 68:13;81:18;82:21list (12) 21:4,8,10,16;119:10, 15;120:10,18;121:7,9, 10;122:12listed (1) 122:9listen (6) 77:11;108:9;135:6; 136:1;154:14,17listened (1) 136:17listening (1) 77:11little (5) 19:15;49:16;51:11; 67:8;105:1live (1) 83:2lived (2) 57:9;62:18living (2) 113:10;122:21LLP (1) 3:8loan (1) 74:1Locarno (5) 38:17;42:12;43:4; 44:3;49:2located (2) 39:4;81:4location (1) 140:17Loma (9) 13:15;26:6;28:7; 46:15,16,17,17;49:14; 59:7L-O-M-A (3) 26:7;46:17,18long (10) 16:20;21:4;35:5;55:8, 15;80:5;113:11;116:13; 123:19;157:14longer (1)


(177) J-E-S-U-S - longer



108:1look (16) 21:4;25:13;85:18; 86:1;97:7;103:2;105:1; 119:9;125:14,18; 129:12;132:17;134:6; 141:13,13;142:6Lopez (6) 56:10;71:11;145:4,12, 17,20Lorraine (1) 6:21losses (1) 30:6lost (1) 74:12lot (16) 17:10;18:20;19:1; 41:18;56:5;57:5;63:8; 65:12,14,19;74:13,14; 94:14;107:19;131:20; 158:14lots (1) 17:14lower (1) 151:4Luis (1) 82:10lunch (3) 76:10,14;77:5luxuries (1) 163:3lying (1) 96:21

M

M60 (2) 73:10;150:4Macario (1) 11:1Machoman (1) 50:10Magdalana (2) 54:17,18M-A-G-D-A-L-A-N-A (1) 54:18Magdalena (2) 44:9;46:13M-A-G-D-A-L-E-N-A (1) 44:9main (1) 42:16makes (2) 113:10;121:3making (3) 24:8;71:14;152:1man (15) 15:12;40:2;46:1,6; 49:8,11,11;50:2;51:2,7; 74:12;82:20,21;157:6,18managed (1) 60:10

manager (1) 152:21Mancuso (2) 37:11;127:15mango (1) 28:12manipulated (1) 134:7manner (2) 5:4;167:13Manrique (1) 82:10Manuel (8) 5:5,8,9;8:2;9:19; 52:19;71:12;77:12many (30) 38:9;61:21;62:3;68:6; 70:8,9,13;71:18;74:17, 17;85:6;92:20;93:1; 107:15,19;117:1,4,5,6,7, 8;122:12,13,15;139:17, 19;147:15;148:13; 159:11,11March (15) 9:16;11:11,15;48:2,3, 3;49:1;53:10;61:19; 123:18;124:1,7;129:6; 130:13,19MARIA (1) 3:18mark (2) 136:12;156:13marked (10) 19:20;22:2,4;34:12, 16;102:8,10;119:4; 136:14;156:15massacre (1) 74:18material (2) 70:5;167:12matter (10) 6:17;9:12;19:1;73:7; 74:8;106:20;107:6; 112:16;113:15;138:4matters (1) 53:12Mattos (55) 5:9;8:2;9:19;10:5; 19:5;20:19;22:3;25:13, 20;34:15;52:19;77:12; 78:10,15;79:10;80:7; 86:10;89:1,13;90:4,6,20; 91:2;93:6,18;94:3; 95:17;102:16;103:3; 106:6;107:1;122:9; 123:2,17;124:5;125:2, 10;126:9;128:15;129:3, 12,21;131:12;132:1; 133:21;134:15;136:18; 140:11;141:14,19; 142:13;149:19;152:15; 154:6;157:6Mattos's (1)

85:21may (27) 5:12,14;12:6,17;19:8, 11;25:6;34:9;49:9,10, 19;52:9;53:4;58:10,10; 75:11;78:8;81:16;102:5, 19;105:8;125:3;132:17; 139:21;151:6;157:7,14Maya (6) 26:11,12,15,21;27:20; 28:19M-A-Y-A (1) 26:15maybe (12) 22:12;49:14;70:3; 92:8,16;97:10,11;117:8; 124:10;126:6;134:21; 146:15mayor's (1) 127:11mean (16) 14:9;17:19;18:1,17; 30:21;31:16;33:8;49:18; 50:1;69:4;82:20;118:13; 119:15;128:19;142:18; 146:6means (2) 28:10;151:3media (1) 5:14medium (1) 20:5meet (4) 26:8;70:18;105:3; 140:15meeting (61) 26:1,11;27:1,4,19; 28:2;29:8,16;30:2;32:9, 15,17,20;33:3,15,18,21; 34:21;35:2,5,12;36:1,4, 6,8,12;38:3,7;49:3,12, 17,18,21;50:1,6,8;52:9; 53:3,5,6,11;55:7,13; 75:11,14,19;76:2; 103:15;104:3;114:1; 115:20;116:1,2,4,5,14; 117:2;125:3;140:17; 157:7,14meetings (23) 38:9,20;39:6;40:7,17, 19,21;41:3;97:20;98:5, 14;99:3;100:16;101:16; 104:8,18;105:5;106:8; 107:4;108:9;139:5; 141:16,17member (8) 10:7;16:11;39:8,21; 70:3,4;126:5;127:7members (26) 38:16;39:6;41:8; 43:19,21;44:17;45:3,5, 18;46:5;54:11;68:15; 69:21;71:3,9;74:9,10;

120:19;126:16;147:12; 148:1;149:14;155:9; 158:17;162:15;164:1men (16) 14:6,6,9;57:20;58:2,9, 12,13;63:2;74:1,3; 87:15;88:2;135:9;147:2; 154:12mention (10) 91:6;106:8,14,16; 112:1;148:14;154:21; 164:13,15,16mentioned (20) 31:3;32:11,16,18; 37:7;42:11;50:15;56:6; 94:6;105:15;109:1; 112:7;137:20;143:10; 150:2;158:6;159:18; 160:4;164:10,12met (4) 55:16;103:6;117:2,9microphone (4) 11:17;52:20;90:4; 144:10mid-2000 (1) 11:9might (4) 25:6;76:9;84:4,12MIGUEL (1) 3:7militant (3) 10:21;11:5,6militants (2) 40:11;110:20militaries (3) 149:2,7,9military (33) 15:14;16:6,19,20; 17:3,10,13,14,17,20; 18:2,11,19;47:17;62:15; 65:6,9;66:10,21;67:4,18; 70:12,21;72:18,19;74:1, 6;148:3,8,11;150:8,12; 162:1militing (1) 120:13million (3) 56:15,16;163:5mind (4) 62:8;64:2;107:9; 116:10mine (5) 29:18;36:20;92:14; 150:18;155:18minutes (4) 76:20;152:5,7,12mischaracterizes (7) 96:17;101:6;104:10; 111:8;125:7;130:21; 155:15misleading (1) 23:19missed (1)

75:16missing (2) 50:17;131:21mistake (2) 46:6;105:19mistaken (2) 46:16;116:20misunderstood (1) 112:6model (1) 161:3moment (6) 38:19;92:10;97:7; 102:19;122:14;151:6Monday (1) 129:7money (35) 63:8,8;70:13,16,21; 113:6;123:12,14;126:10, 12,17,18;127:6,8,12; 128:3,4,5,7;142:15; 143:2,7,9;144:20;145:1; 162:8,15,20;163:2,15; 164:1;165:12,13,20; 166:18monies (11) 57:12;63:4;112:12,17; 113:1,2,5;127:19; 128:12;162:18,19Mono (1) 51:3M-O-N-O (1) 51:4month (1) 132:8monthly (1) 128:12months (4) 42:7;113:19;128:6; 166:5more (15) 11:19;23:5;42:3,4,4; 46:19;47:9;56:6,21; 58:8;67:8;95:13;122:16; 128:4;151:18Moreover (6) 67:19;68:6;69:21; 123:11;144:19;166:8morning (24) 6:15;10:5,14;109:1; 111:3,11;112:1;119:5, 12;124:1,3,7,10;125:2; 129:16;130:2,4,9,13,19; 131:3;137:20;146:19; 165:21most (3) 41:5;74:16;75:10Motilona (5) 48:12,13,14;60:21; 158:12M-O-T-I-L-O-N-A (1) 48:14Mountains (1)


(178) look - Mountains



56:21move (10) 22:1;24:9;25:7;88:19; 93:2;97:13;114:18; 133:18;134:13;167:4moved (1) 46:14movements (1) 39:11much (18) 51:2,5,5,6,15;56:21; 57:8;67:1;87:3,9;91:7, 21;107:16;115:21; 151:18;154:4;166:7,12multinational (35) 28:5;29:4,5,7,11,15; 30:7,12,16,18;31:9,14, 17;33:10;34:3;35:6,15; 37:3,6,16;39:4;40:6; 41:6;42:15;44:21;48:8; 50:4;56:12;61:13;63:12; 75:9;104:5;114:9,12; 115:15multinationals (5) 30:20;62:20;63:11; 146:1,5municipalities (6) 14:7;63:7;67:20; 70:18,20;119:11municipality (20) 12:15;13:9,10,13,14, 15;28:7;44:8,14;45:8; 46:12;49:7;58:4,9;59:5, 6;60:19;73:3,15,18murder (25) 33:13;41:8;43:18; 45:5;48:15;49:1;81:6, 10;82:4,6,7,13;83:7; 86:21;89:4;95:19;97:20; 98:6;123:9,21;124:7; 130:12,18;132:3;158:4murdered (13) 33:6;42:16;43:21; 48:19;62:7;147:4,7,13, 19;158:2,13,15,18murders (19) 38:16;42:5,8,13;44:3; 80:8,13,18,19;81:1;82:8; 85:11;98:15;99:4;129:5; 130:13;146:11,13; 158:10must (5) 11:12;24:5,11;131:9; 148:17myself (7) 34:4;50:12;70:8; 113:9;118:13;153:19; 164:20mysterious (1) 89:16

N

name (21) 5:8,17;6:16;9:21; 13:19,21;30:14;51:13, 14,20;56:9;60:14;72:3; 82:10;105:16;120:17; 121:6;149:7;150:7,8; 161:2named (5) 59:8;130:9;157:6,18; 158:6names (14) 7:4;21:4;38:17;42:12; 119:10;120:19,20; 148:14,16,20,21;149:1, 11;150:11Nancy (1) 131:14narcotics (3) 126:10;127:16,21national (5) 69:6;78:19;79:5,6,14nature (1) 161:8near (9) 45:13;49:6;54:21; 60:9,11;61:1,12;73:17; 150:18necessarily (2) 49:10;121:20necessary (2) 6:2;76:21need (5) 32:18;78:1;85:1; 149:1;152:4needed (1) 128:4needs (7) 9:7;30:9;44:12;71:5; 84:21;149:10;152:7negative (1) 68:20negatives (1) 68:16Negra (2) 28:7,9N-E-G-R-A (1) 28:9neither (3) 76:4;116:9,9new (6) 19:2,2;58:15,21;87:9, 9news (2) 5:14,18next (2) 55:18;105:1N-I (1) 50:18nickname (1) 145:13night (1) 131:3Niki (8)

50:18;52:2;54:3; 126:2,2,4;157:7,15nine (1) 80:14nobody (1) 38:6none (1) 89:17nonresponsive (2) 88:20;167:5nor (1) 138:15normally (1) 8:9Norte (3) 126:12,20;136:3Northern (9) 9:15;11:20;12:20; 13:2;37:7,10,13;77:15; 81:20November (15) 26:4;33:17;85:9,21; 89:2;91:3;92:2;94:4,19; 95:12,18;97:18;154:7,8; 159:1Nowadays (1) 83:21number (7) 5:10;9:16;53:3;78:12; 121:19;125:15;160:16numbering (2) 19:21;20:12NW (1) 3:9

O

oath (7) 10:13;100:12,15; 101:15;108:6;140:12,21object (18) 5:12;84:19;86:4; 89:15;92:3;93:10;96:16; 98:18;101:5;111:7; 118:21;126:21;130:20; 135:14;136:6;137:4,14; 155:2objected (1) 46:10objection (29) 6:5;18:12;22:6,8;24:3; 27:2;72:7,14;81:11,12, 14;82:17;89:19;99:6; 101:11;104:9;108:10; 117:21;118:8;125:6; 134:17;138:12;146:3; 155:14;159:17;160:5; 165:2,14,14objections (10) 23:14,17;24:12,15; 25:1,8,10;99:9,18; 104:20objective (1)

141:17obligated (1) 108:18obligation (2) 110:21;112:15Obra (1) 28:7O-B-R-A (1) 28:9observe (1) 57:18observed (1) 58:11obtain (2) 126:10,12obtained (7) 100:21;117:15,20; 118:7,13,13;126:17occasion (4) 79:4;84:14;104:2; 136:19occasions (3) 103:18;140:15;159:19occur (2) 11:14;42:5occurred (16) 10:7;11:10;33:15; 34:2;47:16;48:1,18; 53:10,20;73:2;107:15; 129:5;130:13,18;139:5; 158:10October (1) 116:21off (6) 45:19;46:8;49:8;77:3; 98:7;124:16offered (3) 162:8,13;164:1offers (1) 97:3office (4) 83:19;95:7,16;120:5officer (4) 81:2;150:3,8;155:1officers (3) 148:11,13;149:12offices (1) 127:11official (8) 34:6;49:3;65:5;96:8; 102:2,3;131:13,17officially (1) 167:10officials (2) 31:14;100:3often (1) 111:4OIT (1) 159:19older (1) 51:8Omega (2) 48:13;158:6

O-M-E-G-A (1) 48:13once (26) 43:19;77:21;87:1; 89:6;92:4,5;93:12,14; 95:13,21;96:6,19; 103:13,14;108:14; 114:21;115:7;116:5; 120:10;124:9,20;128:1; 133:8;141:3;148:20; 159:11one (54) 13:11,11,12;15:18; 17:15;21:7;26:6;27:13; 29:3;31:8;35:19;38:12, 13,13;40:14;43:5,18; 44:9,10,10;46:8,8,11; 47:1;50:16,17;51:18; 54:16;57:9;59:21;64:5; 66:8;74:9,9,16,18;75:10; 80:16;84:14;91:4;100:2; 103:7;107:4;110:10; 114:5;121:19;138:18; 140:15;151:6;156:18; 160:21;163:13;166:13, 14One-and-a-half (1) 76:15one-hour (1) 76:10one-hour-and-a-half-hour (1) 76:14ones (11) 21:12,12;28:13;33:11; 43:1;47:9;50:13;65:1; 103:21;138:6;146:6ongoings (2) 63:19;64:6only (16) 6:1;9:1;50:17;57:9; 59:21;92:19;103:13,14; 107:10;110:8;145:16; 151:15;159:6;163:18, 19;164:7onto (1) 44:1open (2) 6:6;28:11opened (1) 68:11openly (1) 91:18operate (2) 67:15,20operated (8) 17:8,9;67:10;69:5; 71:4;75:8,9;126:14operating (5) 30:20;31:7;60:9; 66:11;71:21operation (15) 36:2;43:15,17;44:19; 45:4;47:4,16;73:6;74:6;


(179) move - operation



88:3;89:21;135:10; 154:12;157:19,21operations (10) 26:2;35:15;53:13; 59:18,20;65:4;69:7,9; 74:2,4operatives (1) 18:21opportunity (2) 7:20;110:6Orcasita (5) 38:16;42:12;43:4; 44:3;49:2order (17) 7:17;17:16;24:12; 35:16;42:19;45:5;67:17; 68:8,17;81:7,9;93:15; 97:4;99:18;135:8; 149:16;152:10ordered (7) 54:14;80:19;81:20; 87:15;88:2;154:11; 158:4orders (7) 61:5,7,9,11;82:14,16; 149:17organization (6) 37:1;112:18,19; 139:11;140:20;147:13original (1) 19:16Orlando (1) 126:6Ortiz (3) 56:9;145:2,3Oscar (1) 13:21Ospino (3) 13:20;14:1;52:8O-S-P-I-N-O (1) 14:1Otero (7) 83:20;84:15;85:4; 114:5;115:1;116:3; 156:8others (2) 82:12;103:16otherwise (1) 110:12ourselves (2) 69:21;127:13out (15) 13:4,20;15:6;17:8; 28:20;29:20;44:16;46:1; 47:19;48:11;49:14; 58:18;59:1;62:16;124:8outcome (1) 33:3outgoing (1) 30:13outset (1) 19:16outside (11)

15:16;28:6;34:2;35:5; 98:7;104:4;105:14,21; 124:4;163:14;166:8outskirts (1) 28:6Ovalle (1) 49:9over (4) 31:21;32:6;51:11;61:4overlapping (1) 90:13own (8) 20:13;23:3;66:20; 68:1;106:19,20;128:17, 18owner (4) 82:11,13;83:2,7

P

pace (1) 20:13Pacheco (3) 13:20;14:1;52:8P-A-C-H-E-C-O (1) 14:1page (10) 19:20;20:11,12; 102:16,17;103:2;105:2; 129:12;140:7;141:14pages (1) 25:14paid (2) 75:10;127:6PALOMINO (3) 3:20;7:6,6paragraph (3) 9:8;125:18;153:9paramilitaries (1) 120:8Paramilitarism (2) 78:21;79:9Pardon (2) 111:10;134:6PARR (3) 3:5;7:11,11part (23) 7:5;13:13,14;15:17; 16:5,6,10;17:17;33:11; 43:6,15,20;71:7;72:17; 74:10;88:20;90:14; 128:10;151:1,4;153:13, 18;154:20participant (1) 11:7participate (7) 21:19;43:3;48:4,6,21; 49:3;66:6participated (7) 50:12;62:11;70:8; 115:14;120:15,16; 121:18participating (1)

83:11participation (2) 10:19;80:8particular (5) 104:1;105:4;121:6; 148:11;149:21particulars (1) 64:14parties (1) 6:2parts (1) 61:17party (6) 6:4,14;72:1,3,6,9Paso (1) 13:14pass (2) 41:2;134:10passed (1) 45:15passing (4) 113:17;128:2;133:5; 134:10past (3) 61:4;117:10;166:5pathway (2) 45:16,16patience (1) 76:7patrolling (1) 63:14patrolman (1) 39:8pay (5) 51:5;87:3,4;128:12; 146:10paying (1) 42:3payment (5) 41:6,9,12;53:13;56:15payments (9) 41:21;56:7,7,12;57:1; 63:10;68:14;71:14;72:9Paz (1) 58:9peace (29) 10:10,14;13:21;71:20; 83:12;84:5,7,17;85:7,11, 13;86:15;87:11;91:14, 19;92:20;95:3;96:9,13; 100:4;119:19,20;120:6; 132:12,15;159:2;160:1; 161:11,17Peinado (16) 39:13,16;40:10,15; 41:1,10;47:5,6,6;105:16; 109:2,3,5;110:15,19; 111:3P-E-I-N-A-D-O (1) 39:15penalty (1) 8:19penitentiary (1)

161:3Pennsylvania (1) 3:9penny (1) 63:3people (50) 19:1,4;39:11;40:9; 42:4,16,21;52:1;55:3,4; 60:8;61:21;62:7,12; 63:19;64:7,9,20;68:13, 17;69:14,19,20;70:9; 71:13;93:1;107:20,21; 111:5;120:20;121:1,11, 14;122:3,5,6,12,13,17, 19;144:18,19;147:3,4,6, 14,18;153:18,20;163:4perceived (1) 46:7Perfect (1) 9:10perform (1) 73:20performing (1) 59:18Perhaps (3) 5:14;107:12;135:1Perija (1) 56:21periodically (2) 40:7;56:19person (20) 27:6,9,10;39:17,19; 40:12;43:14;44:1;45:10; 46:4;50:7;57:11;96:13; 105:20;107:16;122:9; 134:9;143:4,5;164:19personal (4) 22:9;112:16;122:8,11personally (14) 37:20;53:7,9;65:19; 66:6;71:8,15;122:16; 123:3;142:20,20;143:1, 8;146:17personnel (7) 6:2;36:15;37:5;66:1; 149:15;150:12;152:18persons (5) 53:3;113:3,14;119:10, 11pertain (1) 122:3pertained (1) 161:19pertaining (5) 161:20,21;162:2,3,4pertinent (2) 23:11;167:12pesos (1) 163:5phone (4) 45:11;109:18,20; 130:8phonetically (1)

47:12photograph (2) 34:16,17picture (1) 50:6place (11) 5:6;8:8;23:8;27:5; 45:6;73:11;87:10;94:8, 17;95:9;107:7Plaintiff (4) 6:13;7:18;9:4;52:19Plaintiffs (6) 6:3,17;76:6;84:4; 113:3;118:19Plaintiffs' (6) 22:3,4;34:12;89:19; 125:15;156:2Plan (6) 66:15,16,17;74:11; 151:1,3planning (2) 98:15;99:4plastic (1) 28:16platform (1) 21:11play (7) 71:6;90:3,17;132:14; 135:12;136:4;154:6played (2) 155:8;156:13Playing (5) 86:8;90:18;132:19; 136:5;154:15Please (17) 5:7;6:14;7:3;10:18; 11:19;21:4;24:6,10; 30:21;39:14;50:5;78:8, 13;87:19;98:21;118:4; 124:15pleasure (1) 77:1Plus (1) 68:14pm (5) 77:5,6;124:18,19; 167:20pockets (1) 61:15point (6) 32:6;47:9;50:14,19; 58:15;61:4pointed (1) 103:4points (1) 157:1police (15) 28:14;47:17;65:10; 66:4,21;67:4,19;68:18; 73:17,19,20;78:19; 79:11,20,21political (3) 72:1,9;162:5


(180) operations - political



politics (3) 127:11;162:3,4poor (2) 15:10;63:7Portal (4) 38:11,12,20;39:2P-O-R-T-A-L (1) 38:13portion (1) 53:15pose (1) 24:21posed (5) 22:18,21;23:15,20; 24:3posing (1) 23:2position (9) 12:10;13:5,7;36:19; 37:4,12;58:21;59:3; 152:16positions (1) 11:20positive (5) 68:20;69:1,4;71:16; 148:12positives (6) 70:10,14;71:2;73:9; 146:20;147:20positives' (1) 147:17posted (1) 55:2postulated (1) 21:12Potrerillo (5) 26:6,7;27:6;49:15; 59:7P-O-T-R-E-R-I-L-L-O (1) 26:7Poulakos (1) 10:2powerful (1) 164:18practically (13) 35:7;53:21;55:11; 57:11;71:13;139:9,15; 140:19;141:6,6;142:10, 11;163:14precisely (4) 12:5;14:14;33:6;49:8preference (1) 85:15Preguntado (3) 140:8,8;141:14prepared (7) 88:3;89:20;119:13; 135:9;154:12;155:20; 156:6prepares (1) 120:1preparing (1) 120:2

presence (1) 69:11PRESENT (28) 3:16;23:10;24:12; 26:11;27:7,10;35:3; 38:4,8;39:5,7;47:20; 49:4,21;53:7,19;54:1,4; 75:12;83:18;103:16; 113:20;116:2,4;136:21; 163:21;165:11,13presented (2) 155:12;156:3president (5) 42:14,14;44:20,20; 77:19pressure (1) 68:1pressured (1) 152:2pretend (2) 69:20;70:2pretty (7) 29:18;40:5;46:3;51:1, 6;67:1;115:21previous (2) 16:14;30:7previously (4) 79:1;93:20;107:20; 162:17print (1) 20:7printed (1) 156:9prior (5) 31:3;32:12,17;36:4; 164:19prison (12) 20:5;80:3,5,12; 109:18,20;116:19,19; 143:20;144:3,4,7private (6) 5:20;6:1;63:16;64:16; 103:6;136:9privilege (1) 84:20problem (9) 31:2;33:9;75:17;91:1; 133:4,6,13,16;160:8problems (5) 29:14;32:21;97:2; 151:11;163:1procedure (5) 6:20;23:9,21,21;24:4procedures (1) 71:19proceed (1) 5:3proceeding (24) 5:20;6:1,6;8:13;78:2; 94:2,8,16;104:12; 106:20;108:15,16,21; 133:5,8,10,11;134:20; 141:12;148:15;149:5;

150:11;159:21;165:8PROCEEDINGS (15) 5:1;7:5,16,18;9:8; 25:9;77:10;84:18;87:10; 97:11;131:10;159:20; 164:20;167:11,14process (43) 10:11,14;13:21;71:16, 17,19;76:7;83:12;84:8, 17,18;85:7,11,13;87:11; 91:14,19;92:12,21;94:1; 95:3;96:9;97:5;99:19; 100:4;107:18;115:9; 119:19,20,21;120:6; 121:18,18;122:1,3; 123:14;134:7;141:10, 12;160:1;161:11,17; 167:1processes (1) 80:15produced (1) 70:14profession (1) 6:9proffered (1) 133:17program (1) 132:15Progreso (3) 73:12;150:4,13P-R-O-G-R-E-S-O (1) 73:13promises (2) 94:3,18pronounced (1) 51:21proposed (1) 162:16prosecuted (1) 80:17prosecutor (25) 85:15;87:7,13;88:1; 89:2;91:3,12;93:8,14; 95:2,18;97:18;98:4,13, 16;99:2,14;101:19; 159:14;160:1,9,13,15; 164:21;165:7prosecutor's (3) 90:17;95:7;120:5protected (1) 91:10protection (7) 92:7;94:7;100:21; 108:15;112:8,9;159:16protocol (1) 152:10protocols (1) 151:14provide (18) 8:9;62:15;64:21; 67:14;108:5;111:4; 113:18;115:18;116:7; 117:13;127:4;128:11,

15;142:15;147:8; 151:13;161:10,16provided (6) 20:21;119:21;120:11, 11;138:10;150:9providing (2) 100:18;101:18public (5) 17:10;65:13;66:2; 67:12;83:19pull (1) 43:18pulled (1) 43:5purpose (1) 140:16purposes (5) 22:5;34:13;102:9; 136:15;156:16pursue (1) 69:13put (10) 15:3;18:8;25:20; 42:19;120:17;121:6; 132:16;134:12;143:4; 148:2putting (1) 20:7

Q

qualified (1) 14:4quality (1) 30:5quarter (2) 151:16,20questioner (1) 136:19

R

rail (2) 62:1;65:4railroad (7) 53:14;60:1,11;61:11; 63:15;64:21;150:19Ramirez (2) 7:1;117:3random (1) 147:4rate (1) 85:17rather (2) 54:12;104:19reached (1) 141:16react (1) 161:5read (8) 9:7;20:2;129:13,15, 16,18;140:8,11reading (1)

135:17realization (1) 108:2really (5) 39:21;51:9;130:6; 139:1;149:6rear (1) 45:21reason (2) 91:7;126:2reasons (2) 98:12;163:11rebuttal (1) 76:20recall (4) 26:1;44:5;64:14; 165:20receive (14) 28:17;56:14,18;64:16; 70:16;82:3;83:6;94:4, 18;112:17,21;113:5,6; 149:19received (17) 40:14;41:4;56:8,13; 59:21;70:13;97:4; 111:14;130:1,8;159:11; 161:6;162:18,19;166:6, 21;167:2receives (1) 113:2receiving (8) 56:12;84:4;91:8; 112:8,8,13;144:20;145:1recessed (3) 52:16;77:5;124:18recognize (3) 21:8;86:10;132:21recognizing (2) 20:9;46:5recollection (2) 54:6;72:12Reconvened (1) 77:6record (16) 7:4;9:12;24:8;25:1; 30:19;77:4;90:1,2; 102:2,3;124:16;131:13, 18;132:16;155:4,15recorded (3) 81:13;89:18;95:15Recording (1) 10:1redirect (1) 157:3reduce (1) 83:14referenced (1) 22:12referred (1) 77:20referring (7) 29:6,13;30:17;32:15; 52:6;63:21;160:18


(181) politics - referring



reflect (1) 90:2refuse (1) 149:4regarding (6) 57:6;94:5;104:20; 114:8;134:2;151:14regards (2) 70:10;92:15registered (1) 131:4regular (2) 17:20;95:5regulations (1) 18:4related (2) 8:15;120:5relation (1) 42:6relations (1) 153:1relationship (10) 37:14,21;68:10;81:19; 115:15;139:19;149:8; 153:14;161:19;162:3relegated (1) 166:7relevant (1) 148:18remain (1) 6:10remained (1) 105:21remember (130) 12:21;16:21;19:5; 20:6,8;26:4;28:1,11,16, 19;35:4,11,13;37:4; 38:17;41:5,20;44:7,10; 45:15;46:11,20;47:2,5,7, 9,18,21;49:5,8,10;50:7, 13;51:5,6,20;52:3;53:6, 11;54:5,7,9,11,15,17,19; 55:7,15;56:7,14;58:3,13; 60:1;62:5,21;64:17,18; 65:14;72:8,15;73:7,13; 74:13,16,17,21;82:12; 85:9;86:20;87:16,21; 88:5,5,7,14,15;91:12; 93:21;95:1,17,20,21; 97:6,21;99:8;101:21; 105:3,20;106:13;107:3; 110:8;111:1;113:16; 115:17;116:12,14,17; 117:4;121:17,17,20; 122:14;125:12,13;129:5, 7,8;131:5,6,7;132:9,13, 13;133:4;136:20;138:1; 139:8,11,16;146:14,20; 150:5;152:17,18;153:2; 156:8;157:16;161:4; 163:10;164:7remind (1) 35:17

repeat (16) 16:14;32:1;75:15; 78:14;87:18;95:13;96:6; 98:1,20;114:21;117:17; 118:4;128:1,10;130:14; 133:8repeated (1) 21:7repetition (1) 30:10replaced (1) 56:9report (3) 39:11;63:18;64:6reporter (4) 10:2;26:15;51:4;90:12represent (2) 23:17;78:11representing (1) 84:3request (1) 108:14requesting (1) 128:10require (1) 10:15required (3) 95:3,6;167:11requirements (4) 17:16;77:14;78:1; 167:10reserve (2) 25:8;113:9reservist (1) 17:17residence (1) 5:6Resistencia (3) 48:12,13;158:11R-E-S-I-S-T-E-N-C-I-A (1) 48:14resolve (2) 24:16,20resolved (1) 25:2resources (2) 15:11,15respect (3) 24:14;68:3;133:17respond (5) 64:8;105:13;121:8; 160:13;167:7responsibilities (4) 12:11;14:17;15:1,4responsibility (1) 80:8responsible (1) 120:2rest (1) 151:18Restrepo (2) 112:19,21result (1)

41:13results (1) 33:4resumed (2) 52:17;124:19retract (1) 162:16return (1) 167:12review (2) 20:13,18reviewed (2) 25:14,15reviewing (6) 20:17;21:6;34:18; 103:10;129:17;140:10rifles (3) 73:10,19;150:4right (33) 32:12,18;34:3;36:12; 37:4;41:5;45:2;46:10; 52:2;55:17;56:15;62:6; 64:17,18;68:20;73:8; 85:18;101:21;103:3; 104:4;112:14;129:7,8, 13;131:18;134:4; 135:19;143:3;147:3,13; 150:10;156:19;158:15rights (4) 18:4;65:16;95:7; 160:16Rima (1) 28:15R-I-M-A (1) 28:15Rio (1) 5:10Rivera (1) 133:14road (1) 35:6Rodrigo (1) 88:16Rogatories (1) 77:14Rogatory (9) 22:12,14,18;23:4,8; 24:19;78:3;167:10,12role (4) 43:7;44:3;50:2;155:8room (1) 27:6Rosedo (1) 5:17roughly (4) 47:21;53:3;61:20; 75:11RPT (1) 5:18rule (1) 47:19ruling (1) 24:11

rumored (1) 88:8rural (7) 12:14;13:8;15:5; 70:19,19;128:20;130:10

S

safe (1) 61:12safety (8) 67:14;69:13;71:3; 92:6,11;95:6;107:11; 160:11salary (1) 127:7Salvatore (2) 37:11;127:15Samario (4) 5:9;8:2;54:16;77:12same (30) 16:10;17:8,9,18; 18:11;21:7;33:19;34:20; 40:12;49:5;51:2;65:17; 79:9;82:19;93:13;95:15; 96:7;99:6;100:1,2,19; 101:1;105:2;109:9,11; 110:17,20;118:8; 141:14;162:7San (1) 132:6saw (10) 16:11;18:13;53:7; 105:13;142:14,20;143:1, 6,8;157:7saying (7) 54:7,12;88:7;94:7; 95:20;97:3;131:7scared (1) 114:10scope (1) 23:15screening (1) 23:3second (5) 12:20;13:1;52:11; 63:1;79:18secret (2) 15:9;18:18sector (2) 69:19;80:1security (47) 12:3,5;20:5;26:9; 29:19;40:13;43:9,16; 50:3,9,11;51:19;53:14; 54:1;55:19;57:7;60:1; 63:16;64:3,4,16,21; 67:13,16;68:4,10,15,18; 69:10,15;70:9;73:20; 91:20;92:6,11;94:14,14, 18;95:6;100:18;101:18; 104:21;112:2;147:16; 149:15;151:13,15

seemed (1) 49:12Seemingly (1) 81:17seems (1) 5:13seize (1) 70:4select (1) 147:6self-defense (2) 81:8,18self-evident (1) 33:5self-staining (1) 128:2self-sustaining (1) 127:3semester (1) 13:1send (3) 54:17;128:2,7sent (1) 45:20sentence (4) 80:12;82:3;83:6,14sentences (1) 82:8separated (4) 100:16,17;101:16,17September (2) 13:2;132:10sergeant (1) 73:8series (2) 10:6;35:9serve (1) 80:5service (2) 138:10,20services (1) 33:12set (3) 24:4,19;92:17several (6) 18:21;38:8;97:20; 131:10;139:3;159:19shall (1) 78:3share (1) 166:18SHERMAN (2) 3:16;9:21short (4) 45:21;52:13;124:13; 151:9shotgun (2) 73:9;150:3show (8) 19:9;34:10;90:3; 102:2;135:1,4;153:21; 154:1shown (1)


(182) reflect - shown



163:18side (2) 18:11;35:6sign (2) 156:4,7signature (3) 19:19;20:1,3signed (10) 19:6;20:15;21:1; 93:19;107:3;125:15; 152:21;155:12,19; 156:10signing (2) 20:6;94:10simple (1) 133:21simply (3) 93:6;107:6,16situation (4) 73:1;147:17;160:17, 18skirmish (1) 163:12slow (1) 20:11slowly (1) 108:2small (8) 28:13;58:5;61:14; 63:2;64:11;127:3; 130:10;163:12society (1) 161:20soldier (2) 16:6;18:19Soler (1) 48:16somebody (4) 50:19;64:15;143:9; 149:21someone (11) 18:6;29:16;50:18; 57:4;86:14;121:3; 142:14,15;143:6;156:3; 157:8sometime (2) 84:1;167:1sometimes (6) 103:17;105:13;111:1; 147:9,9;153:6somewhere (1) 124:11sorry (20) 15:5;49:18;50:17; 68:21;75:16;76:2;91:11; 102:17,20,20;117:16; 120:20;130:15;132:7; 137:11;142:19;144:11; 145:18;154:2;156:12sort (2) 60:2;122:3sought (2) 15:17;33:12

source (2) 57:15;112:13sources (1) 127:9Southern (3) 9:15;77:16;79:19space (3) 9:3;28:11;68:11Spanish (10) 19:17,20;20:10,11; 33:20;102:4;125:11,21; 140:4;162:9speak (12) 18:19;20:10,10;31:6; 62:5;87:9;91:17;100:20; 114:4;115:8;125:10,21Speaking (5) 33:20;35:7;86:2; 146:11;162:9specific (5) 32:16;43:14;57:13,14; 64:1specifically (9) 63:11;64:4;87:14; 88:1;91:5;105:20;135:8; 154:11;159:13specify (2) 35:19;142:12spell (1) 39:14spine (1) 17:7spite (1) 163:2spoke (5) 46:14;84:15;110:9; 115:19,21spoken (8) 84:6;110:4,11,13,15; 123:2,6;144:14spouse (1) 8:15staff (3) 36:15,18;65:21stain (1) 127:13stand (2) 5:7;56:18start (3) 12:19;53:15;154:9started (6) 5:3;44:16;90:11;97:2; 143:17,20starting (3) 59:12;129:13,14state (21) 7:3;33:11;67:11,12, 13,15;68:3,10,15,18; 69:9,9,15;70:9;91:10; 108:6;112:9,10;115:10; 147:16;148:1statement (11) 19:6,9;20:7,14,21;

25:17;53:20;95:2; 155:18,19,20statements (3) 85:12;88:14;162:17States (8) 9:14;24:5,13;25:3; 77:15;88:16;115:9; 127:16station (3) 28:14;73:17,21stations (1) 68:1statistics (1) 62:4stem (1) 17:8stems (1) 68:9Steve (1) 10:2still (7) 78:5;79:14;80:14; 92:10,10;97:10;117:12stop (2) 42:20;90:2strange (4) 63:19,19;64:6,7strike (14) 16:19;30:4;42:17,19, 20;88:19;93:2;97:13; 100:11;114:18;133:18; 134:13;137:21;167:4strongest (1) 75:7structure (1) 79:15struggling (1) 16:7subcontractor (1) 39:20subdivision (7) 13:15,15;28:6;45:8; 46:12;49:6;74:18subject (3) 94:11;126:8;137:19submitted (3) 120:5;138:16;139:2subordinate (1) 79:19subversive (7) 33:7;67:21;68:2,7; 147:12;148:6,7subversives (16) 15:2,6;16:7,9;17:3,4, 20,21;39:12;60:8,18; 61:14;62:14;111:5; 147:14;148:9sudden (1) 107:15suggesting (1) 149:20superficial (1) 87:2

superfluous (1) 23:19supplied (3) 29:4;121:9;127:19supplies (1) 121:10support (4) 62:15;112:12;113:8; 128:6supported (2) 17:11;112:16supporter (1) 75:5supporting (1) 113:3supposed (1) 62:13supposedly (3) 68:7;123:15,16sure (4) 5:14;89:11;124:2,9surface (1) 107:19suspected (1) 39:11swear (3) 7:21;8:21;23:5swearing (1) 8:6sworn (6) 8:3,12,17;78:5,6; 93:19system (11) 19:21;20:12;91:9; 92:18;95:1,5;108:5; 110:3;148:16,21;149:10

T

Tabares (4) 5:9;8:2;9:19;77:12talk (6) 50:5;96:7;114:15; 141:20;144:2;159:15talked (7) 100:17;101:17;103:8; 104:8;144:7;146:19; 156:4talking (2) 62:3;149:15tall (3) 51:2,2,7tape (3) 90:18;135:5,6targeted (1) 42:21task (1) 146:16tasks (1) 79:15Telephone (3) 3:11;110:11;123:3telling (2)

70:7;95:17tells (1) 121:14temporary (1) 85:14ten (1) 80:12territory (1) 69:6Terry (4) 6:16;118:12;119:21; 156:9testified (13) 8:5;85:6;100:10,12; 111:3;123:20;124:5; 125:2;126:8;130:1; 132:11;139:3;157:6testify (22) 8:14;88:17;89:8; 91:18;92:9,12,21;93:15; 97:8;99:18;100:5,20; 107:20;108:3,20; 115:16;123:11;133:1; 139:14;161:15;165:12; 166:9testifying (6) 8:12;85:10;91:2; 135:20;139:8,11testimony (67) 8:9;85:21;87:14; 88:12;89:16;92:2;94:5; 95:8,12;96:3,15,17,21; 97:3,17;98:14;99:12,16; 101:4;102:3,18;103:4; 106:7;108:5;109:2; 113:15,18;114:6,8,19; 115:17;116:7;117:13; 129:4,10,13,15;131:13, 18;132:14;133:7;134:1, 3;135:5,5;136:17; 137:19;140:5,12;141:7, 21;154:7;159:1,2,13; 160:9,10;161:9,9,16,18; 163:7;164:10,11;165:8, 21;166:3thereabout (2) 28:13,14thereby (1) 126:6therefore (6) 23:9,13;24:3,20; 32:18;87:6therein (1) 24:21thinking (1) 96:21Third (5) 9:20;57:3;59:8;77:9; 79:19though (5) 24:18;50:5;90:14; 92:17;151:10thought (6)


(183) side - thought



76:3;111:13;112:2,3; 113:18;147:14thread (1) 148:6threat (1) 161:8threaten (2) 161:3;163:6threatened (4) 123:11;160:12;164:1; 166:3threatening (1) 137:21threats (13) 91:8,17;95:9;96:11; 97:3;99:17;133:6; 159:11;160:19;161:6; 164:19;166:7,21three (11) 17:1;42:7;73:9,10; 117:8;121:19;123:3; 133:18,19;150:4;163:20thrive (1) 56:20thumb (1) 20:7Tigre (18) 30:14;31:4,7,11,15,19; 32:4,6;116:2,3,9,15; 143:10,18,20;144:6,13, 14timely (2) 56:6;167:13times (6) 85:6;117:1,8;133:19; 139:3;147:15tinted (1) 46:3Tocuy (2) 74:11,15today (8) 93:20;112:13;139:3; 145:5,17,20;148:14; 149:11Today's (1) 9:16together (5) 18:21;40:4;73:6; 80:15;144:7told (60) 29:16;32:20;36:3,13, 14;41:9,20;51:19,20; 52:2;54:21;55:18;57:17, 18;89:2;96:11,20;97:14, 18;98:4,9;99:9,11,14; 100:19;101:1;104:2,3,6; 106:1;114:13;115:1,8, 11,19;117:13;123:12,13, 15;130:11,17;136:2; 138:3,7;139:4,5;141:6; 144:17;153:4;159:13; 161:13;162:6,18; 163:14;164:21;165:10,

18,18;166:17;167:5T-O-L-E-I-M-A-I-D-A (1) 12:1Tolemaida (78) 12:1;13:17;26:10; 27:20;29:20;31:12,20; 32:5,10;34:4,5;36:3,13; 38:5;40:13,14,16;41:11, 12;46:13;50:11,19;52:8; 53:9,17;54:8,21;55:18, 21;57:7,17;71:11;97:19; 98:6;99:3;100:16;101:3, 16;103:5,20;104:2,7; 105:5;106:4,8;108:8; 123:6,9;133:4;134:10; 136:21;137:8,10,13; 138:6,7;139:4,9,14,17; 140:15,16,18;141:15; 144:18;149:16;153:19; 158:5;161:2,7,12;162:8, 13;163:6,21;164:12; 166:17;167:5TONY (2) 3:6;7:9took (11) 10:13;12:9;13:5,7; 27:5;31:21;32:6;40:13; 46:6;94:8;150:4top (3) 35:14;102:17;103:3topic (1) 33:19total (1) 83:15totality (1) 146:6Totally (2) 113:5;142:3Tovar (1) 88:16towards (3) 46:2;68:4;134:8towns (1) 60:14trade (1) 159:8trafficking (6) 62:18;126:10,13,17; 127:17,21training (1) 66:20transcript (5) 134:5;135:4,17;140:4; 164:12transcription (4) 105:19;136:8,9;154:3transferred (1) 116:18transitional (4) 92:12;119:20;122:1; 167:1translate (1) 126:3

translation (2) 11:12;19:16translator (2) 19:15;68:19transport (2) 55:5;58:4transported (1) 45:18transporting (1) 151:13treaties (1) 65:16trees (1) 28:12trial (27) 23:8;88:15;100:6,13; 101:20,21;103:4; 104:12;106:2,7,17,17, 20;107:7;110:9,12,14; 123:20;124:6;129:10; 130:1,12;131:2,14; 139:9;140:5,12tribunals (1) 160:3tried (3) 90:3;95:5;154:1trigger (2) 43:6,18trouble (1) 89:10truck (1) 46:2trucks (1) 44:9true (22) 25:17;88:11,11;89:3, 3,6;91:2;96:1,3;103:12; 106:6;123:17;129:21; 132:2,4;136:1;140:12; 141:2,8,21;142:2,4trust (3) 41:18;56:5;57:8truth (18) 8:4,4,5,13,17;9:1,1; 10:15;84:16;87:7;93:4, 7;108:19,20;134:19; 137:3;142:9;159:8try (2) 72:1;149:10trying (2) 42:17;121:2Tuesday (1) 129:7Turn (2) 102:16;140:7TV (1) 5:18twice (2) 79:12;163:19two (26) 42:7,12;43:21;44:9, 17;47:13;48:1;49:2; 53:10;66:12;80:8;87:15;

88:2;93:18;95:20;117:8, 10;121:19;135:9; 140:15;146:11;154:12; 155:9,11;163:20;166:5type (9) 23:10,14,21;24:4; 65:17;67:17;68:5; 146:15;166:6typed (1) 155:17types (3) 23:20;53:13;112:21

U

unclear (1) 17:19under (18) 10:21;11:7;28:10; 54:13;59:5;78:5,5; 83:12;84:5;100:12,15; 101:15;108:6;112:15; 126:15;128:21;140:12, 21undergo (1) 24:1undergoing (2) 115:9;123:1underlings (1) 56:3underscore (1) 104:18understood (4) 52:2;59:18;94:16; 101:10undertaken (1) 43:20undertaking (1) 6:8undertook (1) 66:9unequal (1) 15:10Unfortunately (2) 15:18,18union (55) 29:10,15;30:3;33:1,6, 9,13;35:9,16,18;38:16; 41:8;42:5,8,15;43:2,19, 21;44:17,20;45:3,5,18; 46:5,21;48:1,5,7,9; 53:10;54:11;80:9,20; 82:7;85:11,13;86:21; 89:4,7;97:20;98:6; 123:9,21;130:12,18; 132:3;137:20;138:15; 146:11;155:9;157:19; 158:1,7,9;162:2unionists (2) 49:2;95:20union's (1) 138:9unit (5)

64:15;72:19;74:1; 86:15;95:8United (8) 9:14;24:5,13;25:3; 77:15;88:16;115:9; 127:16Unless (2) 23:18;159:15unresponsive (1) 114:19up (13) 5:7;12:9;13:7;49:16; 56:21;61:11;65:4;73:11; 106:19;113:9,12; 150:15;156:21upkeep (1) 63:13upwards (1) 73:11urban (3) 14:6;15:5;67:2U-R-B-A-N-O (1) 12:14Urbanos (21) 12:13;13:8;14:3,5,11, 13,15,18;43:10,11,13; 59:11,15;61:19,21; 72:18;74:2,7;75:5; 128:19,20U-R-B-A-N-O-S (1) 43:11Urbans (1) 57:21use (3) 8:10;52:20;66:1used (10) 30:16;54:8;57:7;58:6; 60:13;61:15;65:12; 67:15,20;83:21

V

Vaca (2) 161:3,13Vagas (1) 161:13valid (2) 133:9;134:3validity (2) 133:2,3Valle (3) 38:11,21;39:2V-A-L-L-E (1) 38:14Valledupar (14) 5:11,18;9:20;20:5; 36:17;38:11;40:19;58:6; 77:10;86:16;91:15; 116:19;145:7;153:15verge (1) 30:3version (9) 20:11;85:10;89:9;


(184) thread - version



95:14;97:11;133:2,13; 163:11,17versions (3) 87:9;159:7;160:21versus (2) 9:13;17:3via (1) 45:11vice (2) 42:14;44:20victims (3) 120:20;122:2;133:16video (16) 85:19,20;86:5,8,11; 91:16;132:19;136:1,5, 13;153:21;154:6,15; 156:13,13;163:18Videoconferencing (1) 10:1Videographer (6) 3:16;9:7,11;11:16; 124:16;167:18video-recorded (2) 9:18;167:19videotape (2) 99:12,15Vientos (2) 45:9,9V-I-E-N-T-O-S (1) 45:9view (2) 18:10;98:7village (2) 45:14;58:5visit (1) 167:2voice (1) 90:4Vosconia (1) 55:9V-O-S-C-O-N-I-A (1) 55:10

W

waited (1) 45:10waiting (4) 28:20;35:14;55:3,4war (6) 15:7;16:4;57:20;63:6; 70:5;159:6warned (1) 96:14warnings (1) 8:9Washington (1) 3:10watch (2) 134:4;135:11way (16) 15:3;16:10,18;17:2,3, 9;43:3;61:2;84:13;

113:7;130:7;132:5; 138:18;152:2;160:20; 161:11weapons (3) 66:1;70:1;150:9wear (1) 11:17Wednesday (1) 129:8week (1) 117:11weeks (4) 93:18;117:10;155:11; 163:18well-acquainted (1) 153:10well-known (3) 91:9;153:13,18weren't (3) 40:19;49:14;165:10what's (3) 22:7;29:21;136:8whatsoever (2) 122:7;146:15Whereupon (1) 8:1wherever (1) 70:19whichever (1) 151:12white (1) 28:16whole (2) 8:4;93:7whose (3) 30:14;66:15;82:10wife (1) 112:17WILLIAM (3) 3:4;7:7;78:10williamjeffress@bakerbottscom (1)

3:13willing (3) 84:16;115:16;117:12windows (2) 46:3,3wine (1) 44:10wisely (1) 97:7wish (1) 156:12withdraw (1) 135:16within (23) 23:15;24:4,18;28:5; 39:9,12,17;40:2;42:17; 43:1,14,17;57:5;66:20; 72:12;79:15;88:8;96:9; 106:19;108:15;123:3; 149:18;151:1without (2) 25:9;152:1

witness (64) 5:4,8;7:19,21;8:3,7; 9:2,5;16:14;18:13;19:9; 20:17;21:6;22:12;23:5, 15;24:1,5;27:4;28:10; 30:11;32:7;34:10,18; 38:15;44:15;71:8;72:8, 15;78:4,7;82:19;92:4; 93:12;96:19;97:4;98:20; 99:8;101:7;102:5; 103:10;104:11;114:21; 118:10;119:2;125:8; 127:2;128:10,11; 129:17;131:1;134:19; 138:14;140:10;143:16; 146:5;151:3,4,14;155:5; 159:18;165:4,16;167:6witnesses (2) 118:16;123:13Witness's (1) 71:7woman (2) 104:20;161:21word (13) 13:11,11,12;26:6; 27:13;30:16;35:8,14; 38:12,13,13;78:6;140:8words (2) 47:13;151:16work (9) 21:13;39:10;40:1; 109:8,9;111:18,21; 113:11;148:12worked (17) 18:21;37:1,2;70:14; 73:6;109:5;111:15; 112:2,4,4;119:20;143:4, 5,6;149:2;150:2,12worker (1) 105:15workers (2) 43:1;45:18working (7) 12:18,19;61:8;63:14, 16;90:21;113:14works (1) 30:4worse (1) 17:7written (1) 124:11wrong (2) 111:10;135:17wrongly (1) 51:21

Y

year (23) 12:3,8,21;13:1,2;26:5; 33:17;49:5;53:11;74:21; 75:1;79:2,13;82:1;83:4; 116:11,13;132:10;145:6,

21;166:2,2,6years (12) 8:19;17:1,6;30:7; 80:12,14;82:5,6,7;83:8, 15;123:3Yeraska (1) 74:19young (3) 15:12,12;105:15younger (1) 51:8Yuca (3) 47:6,6,7

Z

Zinc (5) 45:13,17;130:3,9,10zone (2) 59:4;123:18zones (1) 19:2


(185) versions - zones

May Firstiradvocates.mayfirst.org/sites/default/files/03.12.12 Samario Transcript & Exhs.pdfGore...

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Transcript of May Firstiradvocates.mayfirst.org/sites/default/files/03.12.12 Samario Transcript & Exhs.pdfGore...