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#Me Too, Race, Class and Due Process

Gearóid Ó Loingsigh

20 August 2019

I usually write about the Colombian conflict and development and conflict in the country.  I have never written anything on the issue of sexual violence and less still on #Me Too, although I have dealt with specific cases in the framework of paramilitary and state violence.  However, the issue of sexual violence and #Me Too has risen its head in the local elections in Colombia this year.  I should clarify that although I have the right to vote in local elections in Colombia, I have not registered to do so, nor do I intend to.  I have, of course, no reasons to vote for the right wing candidate Claudia López in her new embodiment as a progressive and there are not sufficient reasons to vote for the candidate Hollman Morris whose candidacy, like the rest of those who self proclaim themselves to be on the left is steeped in all the vices of Colombian electoral politics.

However, in the midst of the battle between lefties who want to take control of the booty that is the Mayorship of Bogotá, allegations have been made of sexual violence against Morris and leaders such as Ángela María Robledo have made statements regarding his candidacy and that he should withdraw due to the allegations.  They aim to copy the #Me Too movement and its methods without analysing the reality of that movement and its real impact and its abandonment, if not its disdain for poor female victims of sexual violence.  The movement has been criticised not just by the right and sexists but also by lawyers and even feminist icons such as the author of the Handmaids' Tale, Margaret Atwood who not only criticised the movement but also publicly defended an academic accused in a secret process, which he cannot comment on as he was forced to sign a non disclosure agreement, the same type that many powerful men and companies have force many women to sign.(1)

So, I write this article as a contribution, not to the electoral debate about which I care little but rather to the issue of sexual violence and how we respond to it.

In October 2017, there arose what the media termed, the #Me Too movement in response to allegations of sexual violence and aggression by powerful Hollywood men against actresses.

There are no exact figures on sexual violence in the USA nor in other parts of the world.  However, the organisation RAINN (Rape, Abuse and Incest National Network) tries to compile, using various sources, figures that may indicate the scale of the problem, their main source being the very US Department of Justice and its National Crime Victimization Survey.(2)  Some of their stats are old, which is indicative of the problem we face regarding sexual violence, that not even compiling statistics on it is a priority.

The scale of the problem is huge, each year on average, 321,500 people over the age of twelve are victims of rape or sexual assault in the USA, those under the age of 30 being the main victims; 15% between the ages of 12 and 17 years, and 54% between the age of 18 and 34.  According to RAINN 14.8% of women in the USA will be victims of a rape another 2,8% of an attempted rape and also 3% of men have also been victims i.e. 1 out of every 10 rapes or attempted rapes are made against men.  The indigenous population of the US experiences a rate of sexual violence greater than the white population and other minorities, although the total figures are less due to its low participation in the overall demography of the country.  Also 41% of the cases of sexual violence committed against the indigenous population are at the hands of strangers, when in the rest of the population the figure is 19.5%.  Also in prisons we find an inmate population that is very vulnerable and it is calculated that about 80,600 prisoners, both male and female, suffer sexual violence in prison and 60% of that sexual violence is committed by functionaries and not by other prisoners, despite the myths surrounding sexual violence in prison.

However, the group that most experiences sexual violence in terms of absolute numbers are white women (about 200,000 per year) and 57% of 57% of the victimisers are also white.(3)  There can be no doubt about the scale of the problem.  Victimisers rarely see the inside of a prison cell, for every 1000 sexual crimes, barely 4.6 people end up in prison compared to 20 thieves, although the rate of reporting of every thousand thefts is three times that of rapes which indicates there is an underlying problem with the judicial system and the willingness of the victims of sexual violence to report their abusers.

Once in court, the victim faces other problems.  The police that take their reports, do not believe them, nor do prosecutors show much interest, the judge (who is normally a man) and the Jury have reactionary misogynistic attitudes regarding women, sex and sexuality, so factors that have nothing to do with the crime are taken into account, such as how many sexual partners the woman has, her clothes and whether she had consumed alcohol or not etc.,   Due process does not exist for the woman who reports a crime.  The demands of feminists have frequently revolved around that question, due process for the woman and of course, due process for the victim of any crime, is not counter posed to due process for the accused, regardless of whether it is a robbery, murder or rape.  Due process means a process with clear rules, with rights and duties and guarantees for all at every stage.  Here enters the #Me Too movement.  First of all, it should be pointed out that it is not really a movement in the organisational sense of the word, as it has no real structure with real affiliates, internal control organs, a board with a public responsibility nor even a political programme of demands to protect the rights of women and less still the rights of women who file criminal charges for sexual crimes.

What is the real role of #Me Too and its relationship with the question of race, class and due process?

#Me Too was born in the heart of the US Hollywood and TV entertainment industry.  No one doubts that sexual violence exists in Hollywood, its films promote it all the time and there exists the phrase Casting Couch, where the actresses submitted to the pressures of the men in order to obtain a role in a film.  What was innovative about #Me Too was that various actresses denounced this and other things, but not as part of a general struggle of women sexual violence.

#Me Too encouraged Hollywood women and by extension, without ever proposing it, all women to report their aggressor, something which is very positive.  But that is as far as the positive aspects of #Me Too go.  It is a bourgeois movement, a movement which brings together politicians like Hillary Clinton and tries to resolve the problems of discrimination and harassment in that industry.  It does not aim to mobilise women in a struggle for their rights.  It only aims to solver their problems and they have a right to demand an end to discrimination and harassment in their industry, but their methodology only works within that industry and even then only partially with clear consequences for the concept of due process.  No woman in a factory, or domestic worker can do the same.

Aware of their elitism some spokespersons (in as much as it has official spokespersons) tried, in their public statements to extend their demands to poor women, in word but not in deed.  The billionaire Oprah Winfrey gave a speech at the 2018 Golden Globe Awards which caused more than one liberal to think that she should put her self forward as a presidential candidate.  In her speech she vindicated #Me Too  and stated:

So I want tonight to express gratitude to all the women who have endured years of abuse and assault because they, like my mother, had children to feed and bills to pay and dreams to pursue. They're the women whose names we'll never know. They are domestic workers and farm workers. They are working in factories and they work in restaurants and they're in academia, engineering, medicine, and science. They're part of the world of tech and politics and business. They're our athletes in the Olympics and they're our soldiers in the military.(4)
But nothing of what she said was sincere.  She spoke of domestic workers, a sector of women that are particularly vulnerable.  They are abused in the workplace by everyone, both men and women in Hollywood and how many of them have been sexually abused in Hollywood?  Nobody knows and no one cares.  #Me Too has little or nothing to say about the issue.  Oprah also referred to the case of Recy Taylor, a black women whose gang rape at the hands of an armed gang of white men was an emblematic case in the struggle of black women.  But Oprah cares not for the struggle of black women.

The black women of the poor neighbourhoods of Baltimore had reported that employees and sub contractors charged with repairs and maintenance of social housing (The Projects) demanded sex in exchange for carrying out their work and had left women with out electricity etc., for weeks if they did not agrees to their demands for sex.  Fifty six women filed civil charges against the city, which they won, but they did not win the criminal cases.(5)  Where was Oprah and #Me Too?  Sipping champagne in some Hollywood elite event, perhaps, but what is is certain is they were not in Baltimore.  A case where poor black women, those who were in Oprah's mind in her speech, demanded justice and #Me Too had nothing to say. She could have referred to the case, but that would have put in her conflict with the Democratic Party that controlled the city and would have forced her to deal with the difficulties in filing and winning a criminal case.  Oprah wanted nothing to do with, it was better to talk in abstract, it was better not to talk of the existing relationships of power nor of the question of due process for women and less still to attack the Democratic Party as at the end of the day the #Me Too is just one of the celebrity wings of that reactionary party.

Who are the Me?

One thing that is clear is that in the #Me Too campaign not every woman is Me Too.  Not only are the poor women of the USA excluded, women from other parts of the world are too.  So, whilst the Nobel prize winner Malala Yousafzai is accepted as a victim of the sexist violence of the Taliban, the rapes of Iraqi women and girls at the hands of US soldiers is a taboo subject as is the violence that the Palestinian women are subjected to everyday by the Zionist state i.e. #Me Too, But Not You.  The Palestinians and Iraqis are neither rich, nor TV stars, their pain and the sexual and physical violence they suffer is not an issue for #Me Too as this is uncomfortable for Oprah and Hillary Clinton, amongst others as they are the highest expression of that violence and they justify it. Oprah after making a documentary that questioned the war ended up supporting the propaganda for the war and as regards Hillary, there is no need explain her criminal record in the area.  Raping a woman in Hollywood and Iraq is not the same for these supposed champions of the rights of women.  It is worth pointing out that in Iraq, rape is not an aberrant act by some soldiers but a weapon of war over which Oprah is silent and Hillary put the money up for.

Race and Innocence

It is well known that when a black person is accused in the USA the chances that they are convicted are higher, even when they are innocent, than a white person.  White people make up 64% of the population, close to the figure of 57% for sexual delinquents.  However, they only make up 30% of the prison population, so it is obvious that in sexual crimes there are racial differences.  This does not mean that the black men sentenced are innocent, it may be that it is simply more difficult to convict a white man than a black man in these cases or that a white man receives a lower sentence or probation.  However, the possibility that innocent black men are in prison for sexual crimes cannot be discounted.

There are two historically emblematic cases and one of more recent origin that demonstrate the point.  The historic cases are well known to the elites of Hollywood, they made films about them.  One is the Scottsboro case and the other is the Joseph Spell case where Thurgood Marshall, the first black man to occupy a seat as a judge in the US Supreme Court, defended him.

In the Scottsboro case, nine black men were accused of the gang rape of two white women and then sentenced to death.  After the third trial against them, four were freed.  The other five were either paroled or escaped prison.  The NAACP (National Association for the Advancement of Colored People), did not defend them as it feared doing so due to the nature of the supposed crime and that task fell to the Communist Party which recognised the inherent racism of the US legal system and particularly that of the specific case of Scottsboro.(6)

The other case is that of Joseph Spell, where a rich white woman accused her chauffeur of having repeatedly raped her.  After his arrest, according to the Prosecutor's Office, he confessed as he believe that he would sentenced in any case, but according to Spell, all he did was acknowledge that he had had consensual sex with his boss.  Spell was found not guilty by the jury thanks to the work of the then NAACP lawyer Thurgood Marshall.  In this case an accusation was not enough.

The Central Park Five

One of the most infamous cases of recent times is that of the Central Park Five.  In 1989, five young men, black and hispanics were arrested for the rape and assault of a woman, Trisha Meili, who was jogging in the park.  They confessed under duress, the victim had no memory of the events due to the beating she received.  However, years later DNA evidence proved that the rapist was one Matías Reyes, the five were exonerated and received 40 million dollars in compensation having spent six to seven years in jail.(7)  They were no saints, they were in the park, they confessed and yet they were innocent.  The case underlines the importance of due process.

The cinema director Ava Duvernay made a TV series that explored the case.  She turned up on many television shows where she was congratulated by the presenters.  The same presenters who had echoed #Me Too with the slogan that an accusation was enough in order take measures against the person.  None of them wanted to point out the reality of the Central Park Five case and implications of the #Me Too methodology.  According to the #Me Too logic they are guilty.  They were black or hispanic, poor, not saints and they were at scene of the events.  In other times not even Thurgood Marshall would have saved them from the electric chair and in the #Me Too times, the DNA would not have saved them either as the accusation is enough.

Due Process

Due process protects both the victim and the accused, not just in sexual violence cases but in all types of cases, or at least it is supposed to.  However, in the USA the reality is otherwise.  The US has the same problems to be found all over the world in relation to sexual crimes, domestic violence and abuse of minors.  But the country has a special feature known as Plea Bargaining, an agreement as to guilt.  Although it shares some features with Colombia's Advance Sentencing, it is not the same.

Basically, prosecutors have the power to negotiate not just to negotiate a statement of guilt but also the crime to which the prisoner will declare their guilt.  In theory, the prisoner will only acknowledge their guilt in relation to a crime they have actually committed but in practice it is not like that.  The prosecutors threaten to file charges for more serious crimes that carry a heavier sentence and then offer the possibility of pleading guilty to a lesser offence and they never go to trial.  It is a legal tool whose use is widespread in the legal system, so much so that the overwhelming majority of people in prison never had a trial, where their guilt or innocence is argued, but rather they declare themselves guilty of lesser crimes fearing the prosecutor will accuse them of something that will carry a long sentence of 20 or 30 years or even life.  The deal is that the detainee accepts five years, for example, or run the risk of 30 years or more and in many cases they haven't even been formally charged with a crime when they reach their agreement with the prosecutors.

Viano in his study of the system argues that it is a perversion of the idea of justice.(8)  Using official statistics he points out that 96.8% of all criminal cases are dealt with in this fashion.  In murder cases, 68.2% of them are plea bargained and in sexual abuse cases 87.5% of them are resolved through a plea agreement.  This happens both at federal and state level.  The system imposes an additional burden on poor people who cannot afford a lawyer and in practice citizens who exercise their right to trial by jury can receive longer sentences than those who plea bargain, i.e. they are punished for exercising their constitutional rights.  On the issue of innocent people declaring their guilt for fear of being given long sentences for more serious crimes, Viano quotes Albert W. Alschuler who states that "A procedure that is designed to determine who is guilty and who is innocent seems almost certain to accomplish this task more effectively than a procedure that is deliberately designed to evade the issue."(9) #Me Too also proposes evading the issue.  There is no doubt that innocent people make guilty declarations and the Police and Prosecutors' Office extract confessions from innocent people through threats or taking advantage of their state of mind etc.,

#Me Too proposes something worse than that system, as it proposes the abolition of the presumption of innocence, something which is, in practice, already the case for black men and poor whites in the US regarding almost any crime.  It also proposes the abolition of the right to a defence and due process even where the accused affirms their innocence.  In various cases they have already taken measures against the accused, but far from the glare of the Hollywood lights there are cases that should concern us all.  In the case against Harvey Weinstein criminal charges have been filed and sooner or later we will be able to evaluate the proof.  In the case of Kevin Spacey, accused of the sexual assault of two men, in one of the cases the family withdrew the civil lawsuit some weeks before prosecutor withdrew the criminal charges.  In less high profile cases, however, we don't have nor will we have the opportunity to evaluate the evidence as the accused haven't had that opportunity either.  There are various cases where people have been sacked from companies, universities and other bodies following allegations against them.  Which allegations?  We don't know, the accused not only had no right to defend themselves, they don't even know who has accused them or of what, only that it is what is termed improper sexual conduct.  In other cases the accused have been able to prove their innocence having lost their jobs, their friends and reputations.

The Presumption of Innocence in Colombia

Colombia is not a country where the accused have, in practice, the right to the presumption of innocence.  Social leaders are frequently accused of many crimes by the press and rarely are they forced to withdraw their statements.  The Police usually present the accused before the cameras declaring them guilty.  Some Colonel, who has no judicial authority, comes out and states they are guilty and goes over the supposed evidence against them, which in many cases does not exist.  It is a violation of due process and the presumption of innocence, but the state and its agents are not the only ones who do this.  The so called left do so also.

In 2015, a lawyer, defender of women's rights, some students and three subcontractors with the Mayor's Office were arrested accused of carrying out attacks in Bogotá.  The then Government Secretary of the Mayor Gloria Flórez Schneider, an important person in the Colombia Humana party came out to the media declaring their guilt and lamenting that armed groups had infiltrated the Mayor's Office and telling the El Espectador newspaper that it was not the first time criminal elements had infiltrated the Mayor's Office and  furthermore in her haste to condemn them she wanted it to be known that she was the person responsible for their capture.

After the events of last week we immediately held a Security Council meeting and the following day a National Security Council meeting where we agreed to strengthen our intelligence activities and evaluate the most likely hypothesis that the events were connected to the National Liberation Army [ELN] and exact instructions were given the immediate carrying out of operations by the Metropolitan Police and the Chief National Prosecutors' Office, which today have resulted in these detentions...
This should be seen by the citizens as an opportune and immediate response from State bodies, that we are working together in a coordinated joint effort for the security of the citizens.  These 14 arrests that were made in various boroughs of the city where people linked to the National University, the Pedagogical University and three people connected to the Mayor's Office.(10)

Hollman Morris was little softer on this but not much either as he also spoke of the three subcontractors as infiltrators.  So they were declared guilty from the word go.  Something similar would happen two years later with the attack on the Centro Andino shopping centre.  The Left did not come out to defend the right to due process or the presumption of innocence.

The Electoral Campaign in Bogotá

In January, the ex-wife of Hollman Morris and two other women denounced Morris for ill treatment, including physical violence and sexual harassment.(11)  Morris responded with his own criminal charges for libel [which is a criminal offence in Colombia].(12)  Sooner or later this will be sorted out by the courts, but there are aspects of it which are easy to sort out.  Whether Morris's bodyguards followed his ex-wife or not, can be resolved by examining the GPS that all the bodyguards' cars have.  Whether he paid maintenance money to her and his children or not can be also be sorted out easily.  Other aspects are more complicated and will have to be dealt with by the courts.  There are those who say there is no need to wait for that as the Colombian justice system is slow and inefficient.  It is true that of the 123,639 prisoners in the country, 39,698 are remand prisoners and amongst them there are people in for a variety of sexual crimes as shown in the table below.  It should be pointed out that the Prison Service (INPEC) counts people in prison but when it counts crimes a person sentenced for two crimes appears twice in the statistics so the number of crimes is always higher than the number of prisoners.  However, they serve as an indicator of the scale of the problem.
Men sentenced 
Women sent. 
 Total sent. 
Men remanded
Women remanded. 
Total remands.
Total in prison
Sex acts with minors under 14.
Abusive carnal access of a minor under 14 
Violent carnal access 
Domestic violence

Source: INPEC

As can be seen, sexual crimes together with domestic violence account for 11% of the crimes for which people are sentenced or on remand for.  As a percentage there are more people on remand for unresolved murders than for other crimes, 21,792 sentenced prisoners and 6,693 remands, which together make up 14.6% of the prisoner population.  Are we going to suspend the processes against them and sentence them at once?  The justice system limps along in these cases too.

Ángela María Robledo and others wrote an open letter demanding that Gustavo Petro, the boss of bosses in Colombia withdraw his support for Hollman Morris "given the various cases of violence against a number of women and the charges filed against Hollman Morris with the relevant authorities."(13)

However, she was not sincere in her letter.  I would like to know when did she discover that allegations of this nature mean a person cannot be a candidate.  She was the vice-presidential formula for Gustavo Petro's presidential campaign in 2018.  Recently the writer Héctor Abad alluded in a tweet to a Wikileaks document that talks of an alleged restraining order that Petro's ex-wife had taken out against him and Abad asked why she did this stating that they are not given for good behaviour.(14)  Mary Luz Herrán, Petro's ex-wife, in a communiqué, denied that there ever had been a restraining order against him.  However, some of us have long and good memories.

In 2007, she was being followed by intelligence agencies and it was reported publicly.  El Tiempo newspaper asked about her links to Venezuela and on this issue Petro made a statement and El Tiempo reported the following:

He [Petro] also stated that for the last seven years he has been unable to approach his wife due to a court order.  So, he has no knowledge of whether she has any links to Venezuela although he admitted that when they were married, she accompanied him on various occasions to the neighbouring country.(15)
Back then, nobody, not Petro, nor his ex-wife questioned the veracity of what was said about a restraining order.  I haven't a clue as to why they deny it now and ignored it in 2007.  But when Ángela María Robledo was presented as the vice-presidential candidate, this matter was of no import to her.  Hollman Morris might be guilty, I wouldn't stick my neck out for him, nor for Petro or Ángela María Robledo.  But this issue and Robledo's petition is not about the rights of women but an electoral dispute, otherwise she would never had accepted being Petro's vice-presidential candidate with such a doubt hanging in the air.

Neither is it the case that the political programme of Colombia Humana defends women.  The question of violence against women does not appear in it until page 24 of a 30 page document and what is stated in it is banal and is no different from the current legislation of the country.

Zero tolerance for violence against women: Colombia Humana will not tolerate any form of violence against women for which it will make prevention and humane care and effective sanctions against victimisers a central task of the government.(16)
That is it, nothing specific.  Nothing regarding the possibility of filing criminal charges against men, no legal support i.e. nothing.  I just don't believe Robledo.  Morris made sexist statements, but on the basis of those I cannot convict him of very specific crimes.  He has the right to due process, the same process that he and the then Bogotá Humana violated in the case of those detained in 2015.

Recently  Rafael Uribe Noguera's siblings were found not guilty of the crimes of covering up the crime of the rape and murder of Yuliana Samboní, an indigenous girl, raped and murdered by Rafael Uribe Noguera, a rich architect from the north of Bogotá,  and altering a crime scene.  There was much public evidence against them.  There were no protests, Robledo did not organise a letter asking for the judge's resignation, which she should.  I looked on her website, facebook page and twitter and couldn't find anything.  She is so worried about the question of sexual violence that she has nothing to say about the recent judgement.  The zero tolerance she preaches is not as close to zero as would seem.  Hers is but a political manoeuvre, regardless of whether Morris is guilty or not.

No matter how uncomfortable it is for us, even in cases of sexual violence we must defend due process.  Colombia has already experienced the regional justice system with its faceless judges, prosecutors and even witnesses.(17)  How many innocent leaders went to jail thanks to that system?  There always exists the right to know what you are accused of, who accuses you and what evidence there is against you.  When we don't like the person, when the crime is repugnant is when we should be more cautious and champion due process.  When we are sure about a case, when we see it as obvious is when we should defend due process, otherwise we don't guarantee justice for the women and we prepare the ground for condemning innocent people.  If Morris did what they say he did, then the case will soon be resolved and he will be barred from holding public office and we can evaluate the evidence against him.

Neither should we fetishise the bourgeois legal system, but neither #Me Too, nor Robledo proposes a thorough reform of the system and less still its overthrow, as they are in agreement with it.  Of course, sometimes we go outside the system like when we denounce the military and Uribe Vélez, but we do so on the basis of evidence and it is precisely due to a lack of due process that we have to.  Margaret Atwood asked that “If the legal system is bypassed because it is seen as ineffectual, what will take its place? Who will be the new power brokers?”(18)  It is a question to which neither #Me Too nor Ángela María Robledo have an answer other than them.  When it became public that the actress Asia Argento had not only been accused of pressurising a minor de have sex with her but also made an economic settlement, paying him $380,000 to keep him silent, #Me Too, with the exception of Rose McGown kept quiet and McGowan only spoke out because she mistakenly believed that the minor was 12 and not 17.  Argento went on with her life, she was not erased from films she had made as had happened to Spacey her career was not harmed.  Who took that decision?

Robledo is a Colombian politician whose greatest desire is to recover her seat in Congress, who trusts Colombian politicians?  If we don't trust them running the country, how are we going to trust them with a judicial system without clear rules where she and her political cronies are who will decide the criminal responsibility of people?  What she decides today Uribe or Duque can decide tomorrow.  The Right is more than capable of setting up the left.

All infringements of due process and other judicial guarantees through a popular outcry end up being used, sooner or later, against unions, peasant organisations, human rights defenders, the poor the excluded and even feminist organisations.  This has been the long and sad history of the USA, the birthplace of #Me Too that some want to emulate in Colombia.  They do so at our peril.


(1) The Guardian (15/01/2018) Margaret Atwood faces feminist backlash on social media over #Me Too

(2) See

(3) All figures are from the RAINN site statistics on perpetrators are from

(4) Oprah Winfrey's Golden Globes Speech

(5) NBC News (08/01/2016) Baltimore Sex-For-Repairs Victims Win $8 Million Settlement

(6) For further information on the case see The Trials of "The Scottsboro Boys": An Account

(7) NYT (19/06/2014) 5 Exonerated in Central Park Jogger Case Agree to Settle Suit for $40 million

(8) Viano, E. C. (2012) Plea Bargaining in the United States: A Perversion of Justice in  Revue Internationale de Droit Pénal 2012/1 (Vol. 83) pp 109-145

(9) Alschuler, A.W. cited in Viano, E. C Op. Cit. paragraph 31

(10) El Espectador (08/07/2015) No es la primera vez que personas ilegales se infiltran: Distrito

(11) RCN Radio (22/01/2019) Hollman Morris es acusado de violencia intrafamiliar por su esposa

(12) El Tiempo (04/02/2019) Hollman Morris denunció por injuria y calumnia a mujeres que lo acusan

(13) Las2orillas (26/07/2019) Ángela María Robledo y 60 mujeres se le atravesaron a Hollman Morris

(14) Colombia Indignado (17/04/2019) Héctor Abad hace delicada afirmación sobre exesposa de Petro y ello lo desmiente de frente

(15) El Tiempo (09/05/2007) Espiaban a ex esposa de Petro

(16) Government Programme of Gustavo Petro 2018-2022.

(17) For many years Colombia operated a faceless justice system where the identities of judges, prosecutors and witnesses was hidden even from the defence and they were usually not able to see the witnesses when cross examining them.

(18 )The Guardian (15/01/2018) Op. Cit.

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