Your excellencies, and may it please the court, My name is Bon Harold Dumas

together with my co-counsel ms. Airrah G. Daguimol representing the office of the
prosecution. I will be addressing the 1st issue regarding the destruction of the
Baobab Tree Sanctuary. and Ms. Airrah will be addressing the 2 nd issue regarding
the killing of 5 UN personnel.

The Office of the Prosecution present this first charge with respect to the
destruction of the Baobab Tree Sanctuary in Momaayo that defendant is guilty of
violating Article 25 of the Rome Statute on the basis of individual criminal
responsibility, for ordering, soliciting or inducing the commission of such a crime
which in fact occurs or is attempted, the war crime of intentionally launching an
attack in the knowledge that such attack will cause incidental loss of life or injury
to civilians or to civilian objects or widespread, long-term and severe damage to
the natural environment which would be clearly excessive in relation to the
concrete and direct overall military advantage anticipated in Article 8(2)(b)(iv) of
the Rome Statute.

This claims can be proven by the fact that President Garba directly ordered Lt. Col.
Diallo together with the troops of the 1st Commando Battalion to cross the border
by stealth through the Momaayo National Park and infiltrate the quiet village of
Dunanti without considering King Abdu’s formal declaration of his non-
continuance of the oil extraction operation through a front-page article in The
Pictopian Times. As a result to this order, there was substantial damage to the
Baobab Tree Sanctuary caused by the three Kissakan tanks that were rolled slowly
through the Momaayo National Park to create a direct path to the oil access point
resulting in the flattening and destruction of 25,000 baobab tree saplings. This
destruction would also affect the balance of rare species of animals, including
3,890 rare species of insects which depend on the baobab tree and are found only
in Momaayo. The damage of the destruction although mentioned was still for
investigation, it is evident enough that the 25,000 Baobab Tree is material and
should be acceptable for evidentiary purposes.