In The Matter Of:Claudia Balcero Giraldo, et al. vs.
Drummond Company, Inc., et al.
Letters Rogatory Video Hearing
Vol. 1
March 12, 2012
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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
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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.
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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.)
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
17 BY MR. COLLINGSWORTH:
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
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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.
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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.
15 BY MR. COLLINGSWORTH:
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
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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.
18 BY MR. COLLINGSWORTH:
19 Q Is that your signature at the bottom of the
20 Spanish page which is marked 084 in our document
21 numbering system?
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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
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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.
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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
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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
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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.
7 MR. COLLINGSWORTH: Thank you, Your Honor.
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
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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.
12 BY MR. COLLINGSWORTH:
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?
18 A Yes, of course.
19 Q Thank you.
20 Mr. Mattos, we'll put the document aside
21 for now. I want to ask you some other questions.
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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?
13 A Yes, of course.
14 THE INTERPRETER: And for the Court
15 Reporter Blanco, B-L-A-N-C-O, Maya, M-A-Y-A.
16 BY MR. COLLINGSWORTH:
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.
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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.
8 BY MR. COLLINGSWORTH:
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.
18 BY MR. COLLINGSWORTH:
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?
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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.
21 BY MR. COLLINGSWORTH:
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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.
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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.
15 BY MR. COLLINGSWORTH:
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
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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?
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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.
8 BY MR. COLLINGSWORTH:
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?
13 A Yes, of course.
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
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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?
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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
13 purposes of identification.)
14 BY MR. COLLINGSWORTH:
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?
18 A (Witness reviewing document.)
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?
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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.
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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?
10 A Yes, of course.
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
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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.
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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.
18 BY MR. COLLINGSWORTH:
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
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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
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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
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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
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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?
10 A Yes, of course.
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
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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
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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.
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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
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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
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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.
14 BY MR. COLLINGSWORTH:
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
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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.
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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.
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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?
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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.
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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.
15 MR. COLLINGSWORTH: Thank you, Your Honor.
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.
21 MR. COLLINGSWORTH: Thank you, Your Honor.
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1 BY MR. COLLINGSWORTH:
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?
18 A Yes, of course.
19 Q Who was -- who was present when that
20 statement occurred?
21 A Let's say that, you know, practically half
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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
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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
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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.
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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
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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?
17 A Yes, of course.
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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1 he did. False positive.
2 BY MR. COLLINGSWORTH:
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
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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
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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
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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.
11 BY MR. COLLINGSWORTH:
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.
16 BY MR. COLLINGSWORTH:
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?
21 A Yes, of course.
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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.
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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
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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.
18 BY MR. COLLINGSWORTH:
19 Q After that meeting did you ever again see
20 Alfredo Araujo?
21 A No, I didn't see him again.
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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.
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1 THE COURT: Yes, of course, with pleasure.
2 MR. COLLINGSWORTH: Thank you, Your Honor.
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
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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.
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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,
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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?
10 A Yes, of course.
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.
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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.
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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?
17 MR. COLLINGSWORTH: Objection, no
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.
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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?
13 A Yes, of course.
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
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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
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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
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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?
12 A Yes, of course.
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?
19 A Yes, of course.
20 Q And do you remember now that those
21 questions did involve the murder of the union leaders?
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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
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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:
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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?
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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.
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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.
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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
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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?
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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
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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.
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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
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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?
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1 THE INTERPRETER: Could Counsel repeat that
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?
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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?
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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?
14 A Yes, of course.
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
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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
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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
9 purposes of identification.)
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.
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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?
10 A (Witness reviewing document.)
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
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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.
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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.
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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.
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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
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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.
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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?
17 A Yes, of course.
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?
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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
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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.
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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?
11 A Yes, of course.
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
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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?
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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
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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.
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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.
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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,
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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
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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.
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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
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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.
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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
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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
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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.
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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?
6 MR. COLLINGSWORTH: Objection as to form,
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?
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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
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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?
18 A Yes, of course.
19 Q And how do you know that monies supplied to
20 the Juan Andrés Álvarez Front did not come from
21 narcotics trafficking?
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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.
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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.
17 A (Witness reviewing document.)
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
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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?
14 THE INTERPRETER: Could Counsel repeat that
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.
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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.
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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
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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:
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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?
17 MR. COLLINGSWORTH: Objection as to form,
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
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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
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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.
14 (Defendants' Exhibit 3 was marked for
15 purposes of identification.)
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
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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?
18 A Yes, of course.
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
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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?
12 MR. COLLINGSWORTH: Objection, no
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.
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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?
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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.
10 A (Witness reviewing document.)
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?
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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?
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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?
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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?
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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.
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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.
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1 Q Where do the multinationals do business in
2 the Department of Cesar?
3 MR. COLLINGSWORTH: Objection, no
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?
21 A Yes, of course.
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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
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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?
10 A Yes, of course.
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.
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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?
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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
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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.
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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
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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
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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
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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.
5 THE WITNESS: Yes, of course.
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?
10 A Yes, of course.
11 Q And that was exactly two weeks before you
12 signed a clarification that Mr. Collingsworth presented
13 to you, correct?
14 MR. COLLINGSWORTH: Objection, no
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.
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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.
15 (Defendants' Exhibit 4 was marked for
16 purposes of identification.)
17 THE COURT: Which disk? I believe it's
18 this one.
19 MR. JEFFRESS: It's right here.
20 MR. COLLINGSWORTH: Thank you, Your Honor.
21 I will now have a few questions to follow up on some
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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?
10 A Yes, of course.
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?
20 A Yes, of course.
21 Q What happened to him after that operation
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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
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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
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1 the prosecutor at the justice and peace process.
2 BY MR. COLLINGSWORTH:
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.
6 BY MR. COLLINGSWORTH:
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
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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
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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
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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
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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
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1 that?
2 MR. JEFFRESS: Objection, leading, no
3 foundation.
4 THE WITNESS: I didn't understand the
5 question.
6 BY MR. COLLINGSWORTH:
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.
16 THE WITNESS: Yes, of course.
17 BY MR. COLLINGSWORTH:
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?
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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.
Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
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.
17 MR. COLLINGSWORTH: 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
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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
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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
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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
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Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(169) $1.5 - against
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
96:11;100:6;104:12,13; 106:17;108:15,16; 110:18;114:11;133:17; 137:21;148:15age (1) 51:9agency (4) 64:4;67:9;127:7; 151:13ago (4) 19:6;84:1;117:11; 167:1agree (2) 25:11;136:18agreed (3) 6:12;7:17;25:7agreement (12) 30:8,11;31:4,9;32:12; 37:17;60:3;61:5;143:10, 14,15,17agreements (1) 32:17ahead (1) 91:11al (2) 9:13,14Alabama (4) 9:15;77:16;115:10,11Albarracin (1) 127:15Alcides (7) 5:5,8,9;8:2;9:19; 52:19;77:12Alfredo (27) 34:6,19,20;35:3;36:5, 7,16,20,21;37:15,17,21; 38:4,9;50:12;54:3; 55:14;75:12,14,20;91:4; 106:9;107:4;152:15; 154:21;164:13,18alias (24) 5:9;8:2;11:2;30:14; 31:15;34:5;46:13;47:6, 6;48:13;50:10,18;52:8; 53:8;57:17;71:10,10,11, 12,12;77:12;126:2; 140:14;145:4all-out (2) 15:7;63:6allow (2) 23:2;78:3allowed (1) 86:3allowing (1) 148:8almost (7) 21:18,18,20;33:5; 80:12;124:4;138:5alone (1) 54:12along (3) 60:15;62:1;75:13although (1)
24:11Alvarez (7) 12:19;13:6,17;21:21; 26:10;31:20;32:5
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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
B
back (16) 12:9;15:21;38:19;
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(170) age - back
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(171) background - Charrez
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(172) C-H-A-R-R-E-Z - coordinating
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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;
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(173) coordination - done
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(174) door - fights
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(175) figures - hear
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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;
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(176) heard - Jesus
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(177) J-E-S-U-S - longer
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(178) look - Mountains
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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;
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(179) move - operation
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(180) operations - political
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
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R
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Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(181) politics - referring
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
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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
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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)
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(182) reflect - shown
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
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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
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Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
(183) side - thought
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
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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
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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;
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(184) thread - version
Claudia Balcero Giraldo, et al. vs. Drummond Company, Inc., et al.
Letters Rogatory Video Hearing - Vol. 1March 12, 2012
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
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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
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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
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Zinc (5) 45:13,17;130:3,9,10zone (2) 59:4;123:18zones (1) 19:2
Min-U-Script® Gore Brothers Reporting & Videoconferencing410 837 3027 - Nationwide - www.gorebrothers.com
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