RDF UNIT TRAINED IN KANOMBE BARRACKS TO GO AND FIGHT FOR M23Rebuttal:
It is common (and verifiable) knowledge that Kanombe Barracks is a
garrison-type barracks that comprises living quarters; a referral
military hospital also open to civilian patients; a cemetery; and five
service support units’ headquarters and related facilities. This
Barracks therefore cannot host the training of recruits or any other
force preparation activity.Evidence: During their visit to Kigali, the
GoE toured Kanombe Barracks and were able to see that the allegation
is farfetched ______________________________

__________ALLEGATION 2.
RWANDA PROVIDED ARMS AND AMMUNITION TO M23Rebuttal: The GoE seriously
suggests that it was able to establish, in about a week’s time, that
Col. Makenga could not obtain 75mm canons and their ammunition from
FARDC and concludes that these were instead provided by RDF. As a
matter of fact, RDF does not hold 75mm canons in ordinance stores and
has never purchased such canons or their ammunition. Remnants of these
weapons and ammunition from the 1990 – 94 war of liberation were
disposed of in 2008, which is well documented by the RDF ordinance
regiment. The GoR has credible information that FARDC, unlike RDF,
maintains 75 mm canons and anti-tank rifle grenades on their
arms/ammunition inventory, through RDF participation in several
joint-operations with FARDC including the recent operations codenamed
AMANI-LEO and UMOJA-WETU.Evidence: Relevant documented evidence can be
availed for in-situ review.
________________________________________ALLEGATION 3. PROOF THAT KEY
FACILITATOR OF M23 WAS SEEN IN GISENYIRebuttal: Brig Gen. Ruvusha
denies all allegations and states that he was on leave and out of
Gisenyi from 3 – 14 May 12 and provides an incontrovertible evidence
of his whereabouts during the period.Evidence: A summarized statement
of Brig. Gen. Ruvusha denying allegations can be found on Annex B to
this submission. ________________________________________ALLEGATION 4.
M23 TROOPS CROSS BY BOAT WITH EQUIPMENTS FROM BUKAVU TO
GISENYIRebuttal: I. This is technically impossible because RDF use
motorised zodiac boats to carry 60 personnel and tones of equipment
back and forth at night without detection by FARDC border patrols.II.
It is impossible to drive RDF 15 tonner trucks along the route
reported by GoE because the alleged route is under major construction
and there is no way it could support night movement involving heavy
trucks. In addition, it is inconceivable how offloading of troops in
RDF uniforms on RDF trucks on the Rwandan side of the border with DRC
at a time of tension is out of order, extra-ordinary and linked to
Col. Makenga.Evidence: Detailed specifications and technical data
regarding all types of boats held by Rwanda Marines can be found on
Annex Con this submission.
________________________________________ALLEGATION 5. CONGOLESE
BUSINESSMEN VISITED RWANDA TO DISCUSS M23 FINANCINGRebuttal:
Investigation by the Rwanda migration department indicates that the
two businessmen mentioned in the addendum did not travel to Rwanda
during the period mentioned in the addendum. Only Mr.Dieudonne
Komayombi travelled through Rwanda to Nairobi between 24 and 28 of
June 2012.Evidence: Detailed accounts of the nature and purpose of
these calls and meetings are available on Annex D on this submission.
________________________________________ALLEGATION 6. GENERAL JACQUES
NZIZA, THE PERMANENT SECRETARY OF THE MINISTRY OF DEFENCE, IS ALLEGED
TO BE PROVIDING MILITARY, FINANCIAL AND LOGISTIC SUPPORT TO M23. IT IS
ALSO ARGUED THAT HE WAS RECENTLY DEPLOYED TO RUHENGERI AND GISENYI TO
COORDINATE ASSISTANCE AND RECRUITMENT.Rebuttal: Gen Nziza actively
dismisses these allegations, since as PS of Ministry of Defense he is
in charge of daily accounting at the Ministry and as such; deploying
him to support M23 would amount to grounding most of the core
activities of the Ministry. Additionally, Gen. Nziza provides solid
evidence that support the fact that he has not been in Gisenyi or
Ruhengeri of recent.Evidence: For copies of Gen. Nziza’s daily
meetings, including detailed logs 114 people he met at the Ministry
during that same period, see Annex F of this document.
________________________________________ALLEGATION 7. GENS. JAMES
KABAREBE AND CHARLES KAYONGA ALLEGED TO BE SUPPORTING M23 THROUGH
COORDINATING COL.MAKENGA’S OPERATIONS.Rebuttal: Gens. Kabarebe and
Kayonga have played an active role in promoting peace in the region,
and as such, the fact that they can be in contact with senior
officials of FARDC and/or M23 should not come as a surprise. The false
allegations made in paragraph 33 of the addendum as evidence of their
involvement in supervising Col.Makenga’s operations are
misleading.Evidence: For detailed accounts of Gens. Kabarebe and
Kayonga involvement in attempts to prevent the crisis are provided at
Annex D and E.  ________________________________________ALLEGATION 8.
LT COL JOMBA WAS RECENTLY DEPLOYED FROM GAKO MILITARY ACADEMY WHERE HE
HAS BEEN AN INSTRUCTOR, TO RUHENGERI SINCE THE CREATION OF M23. HE WAS
ALLEGEDLY PUT IN CHARGE OF COMMANDING LOCALLY MILITARY OPERATIONS IN
SUPPORT OF M23.Rebuttal: Lt Col Gakumba states that he was never
deployed to Ruhengeri and remains an instructor at Gako Military in
Bugesera. He provides incontrovertible evidence to support his
statement; these include daily and weekly training activities in which
Lt. Col. Gakumba was involved, as well as details of all visits by
foreign delegations handled by the officer while at Gako.Evidence:
Relevant statement and supporting documents are available at Annex H
on this submission.
________________________________________ALLEGATION 9. THE GOE REFERS
TO THE SIGNAL INTERCEPTION BY FARDC OF RADIO COMMUNICATIONS BETWEEN
RDF AND M23Rebuttal: The so-called signal interception a FARDC
indicated the reception of RDF troop reinforcements by M23, and
request for additional reinforcements. The evidence provided is one of
the most unsophisticated pieces of fabrication in the entire report..
On the basis of “image 10” on p.16 of the addendum (i) the mode of
communication indicated is a single frequency per channel also
referred to as a ‘direct mode operation’; (ii) encryption seems to be
based on a manual cipher system also known as SLIDEX; (iii) the
frequency is VHF (high) and the frequency range (159,500.00 KHz –
160,900.00 KHz – 161,000.00 KHz) indicates some eqipment of commercial
standard. Hence, it is technically incompatible with the RDF VHF
communication system which uses PRC family military standard with low
VHF rage operating from 30 – 80/108 MHz which means that a two-way
communication would be impossible; (iv) Furthermore, RDF uses digital
encryption imbedded in its communication assets which confirms that a
two way communication is not possible in this case.Evidence:
Additional details confirming that the intercepted radio communication
cannot refer to a communication between an RDF communicator and that
of M23 are available on Annex Ion this submission
________________________________________ALLEGATION 10. BOSCO
NTAGANDA-OWNS PROPERTY IN RWANDARebuttal: Investigations on the claim
of a house belonging to Ntaganda indicate that the house presented as
image 15 in the addendum is actually owned owned by Mr. Innocent
Ndagano alias “Cent Kilos”. Further allegations that Hotel Bushokoro
located at Kinigi is co-partially owned by Gen. BoscoNtaganda is
proved wrong because the property is actually owned at 50% each by Mr.
Enock Munyajabo and his wife Mrs. NyiramanaKesie. it is therefore
categorically false to claim that the properties belong to
BoscoNtaganda.Evidence: The certificate of registration of epithetic
lease title No. UPI 3/03/04/05/217 is available at Annex J to this
submission under the certificate of registration of epithetic lease
title No. UPI 4/03/07/03/329 is at Annex Kto this submission.Aimable Rwamucyo

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