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| Post subject: Herman & Peterson: Erlinder Jailed by Major Genocidaire
|Peter Erlinder Jailed by One of the Major Genocidaires of Our Era—Update 
Edward S. Herman and David Peterson 
The May 28 arrest of U.S. attorney and Chicago native Peter Erlinder by the Paul Kagame dictatorship in Rwanda reveals much about this regime that is routinely sanitized in establishment U.S. and Western media coverage and intellectual life. But if we use Erlinder's arrest to call attention to some less-well-known facts, a much grimmer scenario about Kagame than one that portrays him as the "man of the hour in modern Africa," who "offers such encouraging hope for the continent's future" (Stephen Kinzer), comes to light.
For one thing, Kagame does not like free elections, and he has avoided or emasculated them assiduously. Erlinder arrived in the capital city of Kigali on May 23 to take up the legal representation of Victoire Ingabire, a Hutu expatriate who had spent the past 16 years in The Netherlands. Upon her return to Rwanda in January, Ingabire was regarded as the leading opposition figure, even though her United Democratic Forces has yet to be allowed to register as an official party. The Kagame regime arrested her on April 21, and charged her with "association with a terrorist group; propagating genocide ideology; negationism and ethnic divisionism." As 2010 is an election year in Rwanda (now scheduled for August 9), her arrest negates any meaningful challenge to Kagame's rule.
Rwanda's last election year was 2003. Opposition parties, candidates, and media wound-up harassed, shut-down, arrested, exiled—even disappeared. Kagame's main rivals at the time, the Hutu former President Pasteur Bizimungu (1994-2000) and the Hutu former Prime Minister Faustin Twagiramungu (1994-1995), were both branded "divisionists," a kind of Kagame-speak that means they provided an alternative to the one-party Kagame rule. Bizimungu was arrested and jailed and eliminated from the political process altogether; Twagiramungu's name remained on the ballot, but his party, the Democratic Republican Movement, was abolished, many of his aides were arrested, Rwanda's state-controlled media smeared him relentlessly, and he was virtually prevented from campaigning.
Kagame won the 2003 election with a laughable 95% of the vote. The country's National Electoral Commission declared the process "free and fair," and its Supreme Court ruled that only two ballots out of the entire total cast had been miscounted. A spokesperson for UN Secretary-General Kofi Annan praised the "high voter turnout," and added that he "considers this election an important step towards the establishment of a pluralistic multi-party democracy in Rwanda." The Bush White House congratulated "President Paul Kagame on his victory," and said that the "United States will work cooperatively with the government of Rwanda."
Yet, in a country whose population then, as now, was majority Hutu by roughly a 6-to-1 margin over the Tutsi, it was only Kagame's intimidation and repression of Rwanda's civil society, and his election-rigging, that could have produced a landslide like this. Thus when in late April, Erlinder called the arrest of Ingabire a "carbon-copy of Kagame's tactics in 2003, when all serious political challengers were jailed or driven from the country," and likened the charges against her (now extended to himself as well) to "trumped-up political thought-crimes…arising from the 'crime' of publicly objecting to the Kagame military dictatorship and Kagame's version of Rwandan civil war history," this was what he meant.
Erlinder is right.
The Arusha Accords of August 1993 had stipulated that national elections be held in Rwanda by no later than 1995, but this was precluded by the military takeover of Rwanda by Kagame and his Rwandan Patriotic Front (RPF) from April through July 1994, which allowed the minority Tutsi faction (less than 15 percent of the population) to seize power by force.
The accusation of "genocide denial" is a powerful weapon in the arsenal of the Kagame regime, with rival politicians or any other Kagame target who are so accused simply pushed out of the way. According to news accounts immediately following Erlinder's arrest, "A police spokesman, Eric Kayingare, said that Mr. Erlinder was accused of 'denying the genocide' and 'negationism' from statements he had made at the tribunal in Arusha, as well as 'in his books, in publications'." Martin Ngoga, the Prosecutor General of the Kagame regime, told Agence France Presse that Erlinder "denies the genocide in his writings and his speeches. Worse than that, he has become an organizer of genocide deniers. If negating [the Tutsi genocide] is not punished in [the United States,] it is punished in Rwanda. And when he came here he knew that."
On June 4, formal charges were filed against Erlinder under a number of Rwandan laws, including the Law Relating to the Punishment of the Crime of Genocide Ideology. The actual charges included "Denying and downplaying genocide through his publications and conferences," and "Spreading rumors that are capable of threatening the security of the Rwandan people."
Three days later, on June 7, Rwanda's High Court Judge Maurice Mbishibishi ruled that the prosecution's case against Erlinder was sufficiently serious to reject Erlinder's request for bail. The judge ordered Erlinder detained for another 30 days.
Rwanda's Genocide Law criminalizes what it calls "creating confusion aiming at negating the genocide which occurred…" (Article 3(2)). Indeed, Rwanda's 2003 Constitution even states that "Revisionism, negationism and trivialization of genocide are punishable by the law" (Article 13), and commits the Rwandan government to "fighting the ideology of genocide and all its manifestations" (Article 9).
Among the evidence cited against Erlinder in court by Prosecutor Richard Muhumuza is Erlinder's contention that the "crime that triggered" the massive killings in Rwanda in 1994 was the shooting-down of the Falcon-50 jet carrying then-Rwandan President Juvenal Habyarimana, then-Burundian President Cyprien Ntaryamira, and ten others on its approach to the Kanombe International Airport in Kigali on the evening of April 6 of that year—and that this crime was ordered by Paul Kagame. To this, the Prosecutor adds the fact that Erlinder cites the identical findings in 2006 of the French anti-terrorist Judge Jean-Louis Bruguière, and the findings of the Spanish Judge Merelles Abreu in 2008, both of whom requested that their government issue arrest warrants for the Rwandan Patriotic Front (RPF) members responsible for these events. (As a Head of State, Paul Kagame enjoys immunity from arrest and prosecution.)
In other words, the Kagame regime's case against Erlinder, at least as it was argued in court on June 4 and accepted by Judge Mbishibishi on June 7, amounts to the charge that Erlinder has defended his client, the Hutu former Rwandan Army Major Aloys Ntabakuze before the International Criminal Tribunal for Rwanda (ICTR) with a great deal of success, and that in so doing, Erlinder has helped to reveal the true face of the Kagame regime and the monumental violence that it brought not only to Rwanda, but to the whole of Central Africa over the past 20 years. As a May 31 statement by Victoire Ingabire described her own predicament as well as Erlinder's: "A fair trial is being violated because international lawyers would fear that their [defense] motions will lead to indictments being issued against them for ideology of genocide….[T]he defense or testimony to show the truth about the killings in Rwanda before, during and after the genocide would be taken as a proof of negation of the genocide. Then, the lawyers, experts' witnesses and factual witnesses would fear the intimidation and threats to be arrested because of their [efforts] to portray different views from Kagame's regime."
Of course, this is straight out of Kafka, as a compelling case can be made that Kagame and his RPF were the major genocidaires in Rwanda, and in alliance with Uganda’s Yoweri Museveni dictatorship, with both under U.S. and U.K. protection, have extended and enlarged their genocidal operations to the neighboring Democratic Republic of Congo. Peter Erlinder has never denied that mass-atrocities were committed in Rwanda in 1994, and that a large number of Tutsi were slaughtered. But in his seven years as a defense counsel before the ICTR, he has shown that a much larger number of Hutu were also slaughtered, and, more important, that it was the Tutsi Paul Kagame and his Tutsi insurgency, the RPF, that acted as both initiator and main perpetrator of the mass-bloodletting known as the "Rwandan genocide."
This, ultimately, is what the political crime of "denying the genocide" really means: That Erlinder has marshaled convincing evidence drawn from sources that include U.S. and UN documents to show that the official version of this mass-bloodletting, long-since institutionalized within establishment U.S.-, Western-, and Kagame-friendly circles, is a fabrication—one that serves their interests in the greater Central Africa region and beyond, but not the historical record.
One damning piece of evidence uncovered by Erlinder is an internal memorandum drafted in September 1994 for then-U.S. Secretary of State Warren Christopher (now archived at Erlinder's Rwanda Documents Project at the William Mitchell College of Law in Minnesota), in which Christopher was informed that a UN team on the ground in Rwanda "concluded that a pattern of killing had emerged" there, the "[RPF] and Tutsi civilian surrogates [killing] 10,000 or more Hutu civilians per month, with the [RPF] accounting for 95% of the killing."
The memorandum "speculated that the purpose of the killing was a campaign of ethnic cleansing intended to clear certain areas in the south of Rwanda for Tutsi habitation. The killings also served to reduce the population of Hutu males and discouraged refugees from returning to claim their lands." Despite this and similar evidence, not a single Tutsi member of Kagame's RPF responsible for these acts has ever been charged with a crime at the ICTR, while Kagame and his regime continue to bathe in Western adulation and support, and can arrest an American in Kagali who dared to expose Kagame's crimes on a charge of “genocide denial”!
We may recall that the reported (but contested) massacre of 8,000 military-aged men at Srebrenica in July 1995 led to genocide charges, imprisonment of many Serb officials and military personnel, and huge indignation in the West. Yet, here is an internal U.S. document alleging "10,000 or more Hutu civilians" butchered per month by Kagame’s forces to cleanse the ground for Tutsi resettlement, and not only is the leading butcher not imprisoned, but not a single Tutsi member of Kagame's RPF responsible for these acts has ever been charged with a crime at the ICTR. Meanwhile, Kagame and his regime continue to bathe in Western support and adulation, and even get away with charging the man who helped expose his regime's crimes with “genocide denial”!
Consider also the seven following material facts:
1. The “crime that triggered” the mass killings known as the "Rwandan genocide" was indeed the assassination of Hutu President Juvenal Habyarimana, when his Falcon-50 jet was shot down nearing Kigali on April 6, 1994. On April 30 of this year, the U.S. District Court for the Western District of Oklahoma issued a summons to Paul Kagame and nine other RPF members, notifying them that a "wrongful death and murder" lawsuit has been filed against them by the surviving widows of Habyarimana and Ntaryamira (then the President of Burundi). In the words of the lawsuit, "Gen. Kagame and the [RPF] resumed the war, without any provocation, with the assassinations of Presidents Habyarimana and Ntaryamira. From the standpoint of fixing central responsibility for the massacres that the assassinations… touched off, these acts were taken with full knowledge on the part of Gen. Kagame that resumption of the war would cause massive civilian casualties…." One of the three U.S. attorneys whose signature appears on the wrongful death and murder Complaint is Erlinder's. Four weeks-to-the-day later, the Kagame regime arrested Erlinder in Kigali.
2. It is now conclusively established that these political assassinations were carried out by Kagame’s forces. When International Criminal Tribunal for Rwanda investigator Michael Hourigan had assembled compelling evidence showing this, then-ICTR Chief Prosecutor Louise Arbour quashed his investigation on orders from U.S. officials. This official line of inquiry has been suppressed ever since, though it was amplified and confirmed by the French magistrate Jean-Louis Bruguière, whose own inquiry concluded in late 2006 that Kagame and the RPF, fully aware that they would lose the elections scheduled by the Arusha Accords due to the overwhelming majority enjoyed by the Hutu in the country, opted for the "physical elimination" of Habyarimana and reopening their assault on the Rwandan government to achieve their goal of an RPF-takeover of the country. Although three consecutive U.S. presidential administrations (Clinton's, Bush's, and Obama's) and the establishment U.S. media have been wonderfully cooperative in keeping crucial evidence such as this on the “genocide” out of public sight, the work of Peter Erlinder and his colleagues has been important in the struggle to bring it into the light of day and counter the Western party-line.
3. The important U.S. analysts Christian Davenport and Allan Stam also concluded that far more Hutu than Tutsi were killed during the period of the "Rwandan genocide" (April-July, 1994), and that killings on the ground in Rwanda actually “surged” in each area attacked by Kagame’s RPF.
4. Allan Stam, a former U.S. Special Forces soldier as well as an academician, has pointed out that the Kagame-RFP military offensive following the triggering event of the "Rwandan genocide" (i.e., the shootdown of the Falcon-50 jet) were closely modeled on the U.S. ground invasion of Iraq three years earlier during the 1991 Gulf War, and that Kagame's forces went into mass action within one hour of this event. Kagame actually studied at Fort Leavenworth, Kansas, some time prior to the RPF's final assault in April-July 1994, and has maintained very close ties to the U.S. military ever since. As Stam describes it: "Fort Leavenworth is the commander general staff college. This is where rising stars of the U.S. military and other places go to get training as they are on track to become generals. The training that they get there is on planning large scale operations. It's not planning small-scale logistic things. It's not tactics. It's about how do you plan an invasion. And apparently he did very well."
5. Both before and during the “Rwandan genocide,” the United States pressed for the reduction of UN troops in Rwanda. The Rwandan government went before the UN Security Council and urged more UN troops,  but the presence of a larger contingent of UN troops on the ground clearly would have interfered with Kagame’s well-planned and executed military operations. This points up the likelihood that any pre-planned, organized mass killings were dominated by Kagame’s RPF, and that the U.S. government supported them.
6. Kagame’s forces established control of Rwanda within one hundred days of the triggering event, the assassination of President Habyarimana. This is wholly inconsistent with the standard notion that the RPF's was an unplanned defensive reaction, and that his ethnic group, the minority Tutsi, was the main victim of the "Rwandan genocide."
7. Kagame has used the excuse of pursuing “genocidaires” to justify his regular invasions of the Congo. The casualties in these operations, coordinated with fellow dictator Yoweri Museveni, have run into the several-millions. We believe that Kagame has far outstripped Idi Amin as a mass killer (Amin’s killings are estimated at 100,000-300,000, whereas Kagame’s surely run well over a million civilians). But Kagame is servicing establishment U.S. and Western interests, and for the past 20 years, he has, therefore, received a free-pass to rob and kill.
"The prosecution of Peter Erlinder is not a political tactic, it is an act of justice," Rwanda's Foreign Minister Louise Mushikiwabo said after a Rwandan court denied Erlinder's request for bail on June 7. "[T]he fundamental issue at stake is whether Rwandans believe it is permissible for genocide defenders and deniers to threaten the hard-won stability and harmony they have built in the 16 years since the death of one million of their families, friends and neighbors….[T]his needs to be understood: flagrant and orchestrated breaches of our Genocide Ideology laws will be met with the full force of the law." Some days earlier, an editorial in Kigali's Sunday Times (a Kagame-regime mouthpiece) warned ominously: "His arrest in Kigali this week, on charges of Genocide denial, will go a long way to serve as a warning to all the revisionists and Genocide deniers out there, that there is no space for their trade on Rwandan territory."
These are the expressions of a minority dictatorship clinging to power through fear, intimidation, and deceit. Peter Robinson, a U.S. attorney serving as a defense counsel before the ICTR, notified the tribunal that the Kagame regime's prosecution of Erlinder had forced him to resign from his case. "I cannot defend my client under these conditions," Robinson told the New York Times. "As long as defense lawyers are subject to prosecution, we can't continue to participate in cases here."
A declaration issued by at least 40 lawyers who also defend clients before the ICTR denounced what it called the "criminalization…of the rights of the Defense whereby anyone who is involved in the defense of an accused person…runs the same risks and is exposed to the same threats of being criminally categorized as a 'negationist' as defined in Rwandan legislation." In what amounts to the proclamation of a strike by the combined defense counsel at the ICTR, these lawyers accused the Kagame regime of taking "hostage" both Erlinder and the "rights of the Defense," and "resolve[d] to postpone all activities, other than those which strictly conserve the interests of our mandates, until such time as the minimum conditions for the normal exercise of our missions have been restored by the removal of threats to them…."
Separately, Adama Dieng, the Registrar at the ICTR, was instructed to ask the ICTR's Office of Legal Affairs to determine whether any of the charges leveled against Erlinder by Rwanda "derives from the words [Erlinder] spoke and statements he made in his case before the ICTR." The Office of Legal Affairs responded in the affirmative, and "advised the [ICTR] to assert [Erlinder's] immunity without delay." In what might prove to be the most decisive action yet in securing Erlinder's freedom from one of Kagame's jails, this caused Dieng to send a Note Verbale on behalf of the ICTR to the relevant authorities in the Rwandan government that asserts unequivocally: "The ICTR hereby notifies the Rwandan authorities that Professor Erlinder enjoys immunity and requests therefore his immediate release."
As of Wednesday, June 16, this is where Peter Erlinder's case stands.
"Insecure governments are arresting Americans and accusing them of espionage, sowing dissent or treachery against the state," the editorial voice of the Chicago Tribune once said about a superficially similar case—the early 2009 arrest by the authorities in Iran of Northwestern University journalism school graduate Roxana Saberi. Her arrest "[fit] an increasingly familiar plot line," the Tribune noted, like that of its former correspondent Paul Salopek, arrested by Sudanese authorities in 2006, the journalist Parnaz Azima and the academic Haleh Esfandiari, arrested by Iranian authorities in 2007, and the journalists Laura Ling and Euna Lee, arrested by North Korean authorities in 2009, each of them charged in one form or another with crimes against the stability and security of the arresting states.
Each of these six individuals was eventually released, however. And in each case, the state that had arrested them—Iran, The Sudan, and North Korea—ranks at or near the top of the U.S. government's list of Official Enemies, making their arrests top-ranked concerns for the managers of U.S. foreign policy, and highly newsworthy events throughout the establishment media.
Not so Peter Erlinder in Rwanda. As Christopher Black, a Canadian attorney and signatory of the ICTR defense counsels' declaration, observes: "The lack of outrage by the Obama administration and at the United Nations is maddening. It does not matter whether one believes the RPF version of events or the evidence of the reality of the war as set out in the trials at the ICTR. Surely Barack Obama and the UN Secretary-General Ban Ki-moon believe in free speech? Surely they accept that history must be reexamined continuously in light of new facts? The stench of hypocrisy is nauseating. We all know what would happen if an American dissident lawyer was arrested by the Iranians for disputing their version of the killings in Tehran in the aftermath of last year's presidential elections—the Obama crowd would be demanding his immediate release and more sanctions. But Obama and the Pentagon want to keep their three big bases in Rwanda, so nothing happens but a pro forma 'tut-tut' and then on to other business."
It is long overdue that the people of the United States and the rest of the Western world learn the truth about who was killing "10,000 or more" civilians per month in Rwanda (and went on to kill many times that in the neighboring Democratic Republic of Congo), and challenge their governments to stop supporting Paul Kagame's dictatorial rule.
One good place to begin would be for the Obama administration to demand the immediate release of Peter Erlinder. During the week of June 7-11, Betty McCollum and Keith Ellison, two Democratic U.S. House members from Minnesota's 4th and 5th districts in the Minneapolis - St. Paul area, co-sponsored a draft resolution urging "President Paul Kagame to immediately release Professor Peter Erlinder from jail and allow him to return to the United States." But at the time of this writing, the resolution appears buried inside the House Committee on Foreign Affairs.
Regrettably, it is clear that, like its predecessors, the Obama administration values the U.S. military's "special relationship" with the Kagame dictatorship far more than it does the rights and welfare of an American lawyer unjustly imprisoned in Kigali. In keeping with its hypocrisy on human rights around the world—Obama's support for the 2009 Honduran coup and violent aftermath, for example, and for Israel's relentless grinding-down of the Gaza Palestinians, and recent attack on the Free Gaza Flotilla in international waters—the State Department's almost complete silence on the Erlinder case should surprise no one.
Even when Secretary of State Hillary Rodham Clinton was asked by a reporter with Africa Action to address Peter Erlinder's arrest, Clinton declined to state that Erlinder had been unjustly arrested, and declined to call for his release. Instead, almost the first words out of her mouth were: "We really don’t want to see Rwanda undermine its own remarkable progress by beginning to move away from a lot of the very positive actions that undergirded its development so effectively. We still are very, very supportive of Rwanda. The kind of development that has taken place in Rwanda is really a model in many respects for the rest of the continent."
Free Peter Erlinder.
[ Edward S. Herman is professor emeritus of finance at the Wharton School, University of Pennsylvania and has written extensively on economics, political economy, and the media. Among his books are Corporate Control, Corporate Power (Cambridge University Press, 1981), The Real Terror Network (South End Press, 1982), and, with Noam Chomsky, The Political Economy of Human Rights (South End Press, 1979), and Manufacturing Consent (Pantheon, 2002). David Peterson is an independent journalist and researcher based in Chicago. Together they are the co-authors of The Politics of Genocide, recently published by Monthly Review Press (http://monthlyreview.org/books/politicsofgenocide.php). ]
---- Endnotes ----
 This is an updated and expanded version of our earlier article for MRZine by the title: "Peter Erlinder Jailed by One of the Major Genocidaires of Our Era," May 29, 2010.
 For a much more comprehensive development of the themes discussed here, see Edward S. Herman and David Peterson, "Rwanda and the Democratic Republic of Congo in the Propaganda System," Monthly Review 62, May, 2010. Also see Herman and Peterson, The Politics of Genocide (New York: Monthly Review Press, 2010).
 Quoting Kinzer's hagiographic words in A Thousand Hills: Rwanda's Rebirth and the Man Who Dreamed It (Hoboken, NJ: John Wiley & Sons, 2008), 337.
 "Rwanda opposition chief held for 'genocide denial'," Agence France Presse, April 21, 2010.
 See, e.g., Declan Walsh, "Kagame is triumphant. But has the one-time visionary become Rwanda's latest autocrat?" The Independent, August 26, 2003; James Astill, "Rwanda's electoral charade," The Guardian, August 27, 2003 (as reprinted in the Sydney Morning Herald); "Rwanda donors uneasy after decisive victory," Washington Times, August 28, 2003; Grace Matsiko and Geoffrey Kamali, "A Look at Kagame's Landslide Victory," All Africa, September 3, 2003; and Kelly McPharland, "Rwandan leader inspires nervousness," National Post, September 13, 2003.
 Cathy Majtenyi, "Rwanda's Electoral Commission Rejects EU Findings," Voice of America Press Releases and Documents, August 29, 2003; "Rwanda's Supreme Court confirms Kagame's landslide victory," Agence France Presse, September 5, 2003; "UN chief welcomes smooth holding of Rwandan election," Xinhua News Agency, August 29, 2003; "U.S. congratulates Rwanda's Kagame on election victory," Agence France Presse, August 27, 2003.
 Peter Erlinder quoted in "U.S. Lawyer to Defend Victoire Ingabire: First Female Presidential Candidate in Rwanda—Jailed by President/Gen. Paul Kagame," News Advisory, International Humanitarian Law Institute, April 23, 2010 (as posted to the BayView website).
 See the Peace Agreement between the Government of the Republic of Rwanda and the Rwandese Patriotic Front, signed at Arusha on 4 August 1993 (A/48/824-S/26915), U.N. General Assembly, December 23, 1993. A total of seven documents were gathered together as the "Arusha Peace Accords," the earliest the N'Sele Cease-fire Agreement dating from 1991.
 Josh Kron and Jeffrey Gettleman, "American Lawyer for Opposition Figure Is Arrested in Rwanda," New York Times, May 29, 2010.
 "Rwanda arrests U.S. lawyer defending opposition figure," Agence France Presse, May 28, 2010.
 Law Relating to the Punishment of the Crime of Genocide Ideology (No. 18/2008),Codes and Laws of Rwanda, Ministry of Justice, Republic of Rwanda, July 23, 2008.
 Charges in the case of Carl Peter Erlinder (Court Decision No. RDP0312/10/TGJI/GSBO), para. 1-2, transcript of the proceedings before Judge Maurice Mbishibishi in the Superior Court of Gasabo, June 7, 2010 (as posted to the website of Robert Amsterdam). English translation provided by the defense attorneys Kennedy Ogeto et al., June 8, 2010.
 Ibid, para. 41.
 See Constitution of the Republic of Rwanda, June 4, 2003, and its Amendments, as posted to the website of the Rwandan Ministry of Defense. Here we note that the word 'genocide' appears no fewer than 14 different times in Rwanda's approx. 16,400-word-long Constitution.
 See Court Decision No. RDP0312/10/TGJI/GSBO, June 7, 2010, para. 6.
 Victoire Ingabire Umuhoza, "The Arrest and Arbitrary Detention of Professor Peter Erlinder Is a Shame," United Democratic Forces - Inkingi Chair, Press Release, Kigali, May 31, 2010 (as posted to the "Victoire Ingabire Umuhoza for President" Facebook page).
 George E. Moose, "Human Rights Abuses in Rwanda," Information Memorandum to The Secretary, U.S. Department of State, undated though clearly drafted between September 17 and 20, 1994. This document is archived at the Rwanda Documents Project at William Mitchell College of Law, St. Paul, Minnesota, ICTR Military-1 Exhibit, DNT 264.
 See Edward S. Herman and David Peterson, "The Dismantling of Yugoslavia," Monthly Review 59, October, 2007, esp. Sect. 5 and Sect. 6, 19-26.
 John P. Zelbst et al., Madame Habyarimana, Madame Ntaryamira, et al., v. Paul Kagame, et al. (Case No. CIV-10-437-W), United States District Court for the Western District of Oklahoma, April 30, 2010, para. 30.
 See Jean-Louis Bruguière, Request for the Issuance of International Arrest Warrants, Tribunal de Grande Instance, Paris, France, November 21, 2006, 15-16 (para. 100-103).
 See Christian Davenport and Allan Stam, Rwandan Political Violence in Space and Time, unpublished manuscript, 2004 (available at Christian Davenport's personal website > "Project Writings"); and Christian Davenport and Allan C. Stam, "What Really Happened in Rwanda?" Miller-McCune, October 6, 2009.
 See Allan C. Stam, "Coming to a New Understanding of the Rwanda Genocide," a lecture before the Gerald R. Ford School of Public Policy, University of Michigan, February 18, 2009. Beginning at approx. the 22:47 mark, Stam explains: "Now, moments later, the RPF -- literally moments, somewhere between 60 and 120 minutes after his plane is shot down, the RPF invades. Now, we could characterize this invasion as, 'Wow, a spontaneous reaction to go in and defend our allies'. The problem is, this invasion looks staggeringly like the United States' invasion of Iraq in 1991. It has exactly the same features. There is a central drive in this case due south towards Kigali, very much like the central drive towards Baghdad. There is the sweeping left-hook -- but in this case because the map is reversed there is the sweeping right-hook. This is a plan that was not worked out on the back of an envelope. Fifty-thousand soldiers move into action on two fronts, in a coordinated fashion, 'spontaneously'? Tsk."
 In the words of Rwandan UN Ambassador Jean-Damascène Bizimana: "[T]he international community does not seem to have acted in an appropriate manner to reply to the anguished appeal of the people of Rwanda. This question has often been examined from the point of view of the ways and means to withdraw [UNAMIR], without seeking to give the appropriate weight to the concern of those who have always believed, rightly, that, in view of the security situation now prevailing in Rwanda, UNAMIR's members should be increased to enable it to contribute to the re-establishment of the cease-fire and to assist in the establishment of security conditions that could bring an end to the violence….The option chosen by the Council, reducing the number of troops in UNAMIR…, is not a proper response to this crisis…." See "The situation concerning Rwanda," UN Security Council (S/PV.3368), April 21, 1994, 6.
 "Republic of Rwanda Statement on the Bail of C. Peter Erlinder," BusinessWire, June 7, 2010.
 "Genocide Deniers Have No Place in Rwanda," Editorial, Sunday Times, May 30, 2010.
 Josh Kron, "Bail for American Lawyer Is Refused Despite U.S. Pressure," New York Times, June 8, 2010.
 Statement and Appeal from Defence Lawyers Currently Practising at the ICTR, June 8, 2010 (as posted to the World News Journal website). Also see Josh Kron, "Lawyers Report Intimidation by Rwanda," New York Times, June 13, 2010.
 See Adama Dieng, Registrar, The Prosecutor v. Theoneste Bagosora et al. (ICTR-98-41-A), June 15, 2010, para. 5-6.
 Adama Dieng, Registrar, Note Verbale (ICTR/RO/06/10/175), June 15, 2010.
 "Free Roxana Saberi," Editorial, Chicago Tribune, April 30, 2009.
 Christopher Black, Personal Communication, June 7, 2010.
 U.S. Rep. Betty McCollum et al., House Resolution 1426 (H.RES.1426), 111th Congress, June 8, 2010. Also see "McCollum Introduces Legislation Urging Rwandan Government to Immediately Release Peter Erlinder," News Release, June 9, 2010.
 In the 17 days from the date of Peter Erlinder's arrest on May 28 through Sunday, June 13, we are able to document a total of five dates on which the U.S. Department of State's chief spokesperson, the Assistant Secretary Philip J. Crowley, mentioned the fact of Erlinder's arrest, or answered a question about it. These dates were May 28, June 2, June 3, June 4, and June 8. Typically, Crowley is perfunctory, his exchanges with the media limited to less than 200 words (usually much less), as when he stated on June 4 that "we continue to expect that the Rwandan authorities will accord him due process in a timely and transparent manner, and we look for a compassionate and expeditious resolution." Through June 13, no Obama administration official had stated publicly that Erlinder was unjustly arrested and detained, nor had any administration official insisted that the government of Rwanda release Erlinder immediately.
 Secretary of State Hillary Rodham Clinton, "Diplomacy Briefing Series Conference on Sub-Saharan Africa," U.S. Department of State, Washington, DC, June 14, 2010.