_______________________________________________________________ | | http://legal.lege.net/military_necessity/ | | 2003 Iraq War; "Military Necessity or War Crimes?" at | #1: http://truthout.org/docs_03/071403D.shtml , | #2: http://truthout.org/docs_03/072503D.shtml , | #3: http://truthout.org/docs_03/072603D.shtml -- | This series clearly show both that the 2003 Iraq war is and | was illegal in all respects and also that it was not | justifiable by any "Military Necessity" either. In short, | it is and was a War Crime. | | Local transcript: | | | Van Bergen & Gittings | Military Necessity or War Crimes? | http://truthout.org/docs_03/071403D.shtml | http://truthout.org/docs_03/printer_071403D.shtml | | | Bush War: Military Necessity or War Crimes? | By Jennifer Van Bergen & Charles B. Gittings [1] | t r u t h o u t | Monday, 14 July 2003 | | [Editor's Note] This is Part One of a three-part series | that raises the question whether the ``Bush War'' - namely, | the domestic agenda in the so-called ``war on terrorism,'' | the Military Tribunal Order of November 13, 2001, the | illegitimate detention of suspects at Guantanamo Bay and | elsewhere without due process -- are justified, as the Bush | Administration claims, by the doctrine of ``military | necessity,'' or whether they, in fact, constitute violations | of the Geneva Conventions, which would thus be ``war | crimes'' under United States law, subject to capital | punishment. Part One introduces the question. Part Two | discusses the Geneva and Hague Conventions, which the | authors claim Bush is violating. Part Three discusses the | doctrine of military necessity and concludes military | necessity does not justify the Bush War. | | A reporter visits Guantanamo Bay and asks a guard about | the sign at the front gate of the prison camp. The sign | says: "Honor bound -- to defend freedom." | | The reporter asks "Isn't that a little strange, a | slogan about freedom on the gate of a prison camp?" | | The guard replies "Doesn't seem strange to me-- does it | seem strange to you?" [2] | | This exchange appeared in a New York Times Magazine | story. One can't help but wonder if either of these persons | are aware that over the front gate at the Auschwitz | concentration camp the Nazis had a sign that said "Work | makes one free." | | An Air Force Colonel who has been given the job of | chief defense counsel for military commissions at Guantanamo | talks to Reuters and says that some of the rules formulated | for the these commissions would be different if he was | making the rules. As reported by Reuters: | | ``If I were the person who had designed this system, I would | have designed it differently," [USAF Col. Will] Gunn said. | | Gunn singled out language permitting the Defense Department | to monitor any conversations or communications between | defense lawyers and defendants, which some critics have | called a breach of customary attorney-client privilege. | | "For instance, I would make it clear that no conversation | between the defense counsel and a client can be monitored | unless the government had a particularized reason for doing | so ... a reason that can be clearly articulated," Gunn said. | | Gunn said the appeals process would be different if he had | designed it. The rules do not allow for an independent | judicial review of convictions or sentences. Appeals go to a | military panel appointed by the Pentagon, and final review | of convictions or sentences is made by Bush himself. | | Gunn said the traditional U.S. military justice system | allows for some appeals to be heard by a civilian court. | | "The most serious cases with the most severe sanctions can | be reviewed by civilians," Gunn said. [3] | | As it stands, the President has claimed the authority | to invade any country he pleases, determine who is an enemy | combatant, whether or not they can be detained indefinitely, | whether they are to be tried before a commission (or not at | all), what the rules for such commissions should be, and | whether or not the results of such a trial are fair and just | -- solely at his own discretion. | | One wonders if any of these people have ever read the | Federalist, where Madison says: | | ``The accumulation of all powers, legislative, executive, | and judiciary, in the same hands, whether of one, a few, or | many, and whether hereditary, self-appointed, or elective, | may justly be pronounced the very definition of tyranny.'' | [4] | | And whenever anyone dares to question the Bush | Administration's actions -- many of which these authors | believe are violations of the Geneva Conventions and other | treaties, and some of which are war crimes subject to | capital punishment under U.S. law -- the Administration | always insists that it is following Geneva . . . except to | the extent that "military necessity" requires otherwise. | | The President has claimed that the invasion of Iraq was | a military necessity and we now know it was founded on | forged documents. [5] The President has claimed that the | detention of persons at Guantanamo is ``appropriate and | consistent with military necessity, in a manner consistent | with the principles of the Third Geneva Convention of | 1949.'' He has declared that the establishment of Military | Tribunals in this country, even while the civil courts are | open and fully functioning, is ``necessary to meet the | emergency.'' [6] | | The authors thus ask the question: is Bush complying | with international law, and specifically with the Geneva | Conventions? Or is he violating them? If government | officials, including Bush and Rumsfeld, are violating | Geneva, are they thereby committing war crimes? Or does | military necessity dictate -- and justify -- their course? | What do the Geneva Conventions require of the | Administration? What is military necessary and what | determines it? | | Tomorrow the authors will discuss the Geneva and Hague | Conventions which set forth the parameters within which any | ``High Contracting Party'' (which includes the United | States) is obligated to operate. | | ___ | | NOTES: | | 1 Jennifer Van Bergen [ jvb@truthout.org ] is a frequent | contributor to Truthout. She holds a J.D. from Cardozo | School of Law and will be teaching a course on ``The | Anti-Terrorism Laws, the Constitution and Civil Rights'' at | the New School Online University, NY, this Fall. | Charles B. Gittings [ cbgittings@pacbell.net ] is a computer | programmer and the founder of the Project to Enforce the | Geneva Conventions (PEGC) [ | http://63.206.217.42/geneva_project/ ] | | 2 Ted Conover, ``In the Land of Guantanamo [ | http://www.nytimes.com/2003/06/29/magazine/29GUANTANAMO.html | ],'' New York Times, 6/29/03 | | 3 Will Dunham, ``Key Lawyer Differs on U.S. Terrorism Trial | Rules [ | http://www.reuters.com/newsArticle.jhtml?type=topNews&storyID=3006466 | ],'' Reuters, 6/28/03 | | 4 James Madison, The Federalist Papers, #47 [ | http://memory.loc.gov/const/fed/fed_47.html ] | | 5 See | http://www.statesman.com/news/content/coxnet/iraq/ap_story.html/Intl/AP.V42 | | 6 See the Military Tribunal Order [ | http://www.whitehouse.gov/news/releases/2001/11/20011113-27.html | ], and the White House Fact Sheet on the Status of Detainees | at Guantanamo [ | http://www.whitehouse.gov/news/releases/2002/02/20020207-13.html | ]. | | | © Copyright 2003 by TruthOut.org | | (In accordance with Title 17 U.S.C. Section 107, this | material is distributed without profit to those who have | expressed a prior interest in receiving the included | information for research and educational purposes.) | | ____________________________________________________________ | | | Van Bergen & Gittings | Military Necessity or War Crimes? | Part II | http://truthout.org/docs_03/072503D.shtml | http://truthout.org/docs_03/printer_072503D.shtml | | | Bush War: Military Necessity or War Crimes? | By Jennifer Van Bergen & Charles B. Gittings [1] | | t r u t h o u t | Tuesday, 15 July 2003 | | [Editor's Note] This is Part Two of a three-part series | that raises the question whether the ``Bush War'' - namely, | the domestic agenda in the so-called ``war on terrorism,'' | the Military Tribunal Order of November 13, 2001, the | illegitimate detention of suspects at Guantanamo Bay and | elsewhere without due process -- are justified, as the Bush | Administration claims, by the doctrine of ``military | necessity,'' or whether they, in fact, constitute violations | of the Geneva Conventions, which would thus be ``war | crimes'' under United States law, subject to capital | punishment. Part One introduced the question [ | http://truthout.org/docs_03/071403D.shtml ]. Part Two | discusses the Geneva and Hague Conventions, which the | authors claim Bush is violating. Part Three discusses the | doctrine of military necessity and concludes military | necessity does not justify the Bush War. The Bush | Administration is violating the Geneva and Hague | Conventions, the U.S. Constitution, and federal criminal | law. | | Conventions, the U.S. Constitution, and federal criminal | law. | | Part 1 [ http://truthout.org/docs_03/071403D.shtml ]; | Part 2 [ http://truthout.org/docs_03/072503D.shtml ]; Part 3 | | The United States Constitution expressly incorporates | international treaties as ``the supreme law of the land.'' | Article 6 of the United States Constitution states: The | Constitution, and the Laws of the United States which shall | be made in Pursuance thereof; and all Treaties made, or | which shall be made, under the Authority of the United | States, shall be the supreme Law of the Land; and the Judges | in every State shall be bound thereby, any Thing in the | Constitution or Laws of any State to the Contrary | notwithstanding. | | All executive and judicial officers and members of | Congress are bound by oath to support the Constitution, | including Article 6. The term ``treaties'' includes those | signed by the President and ratified by the Senate, as well | as those not ratified or simply part of ``customary | international law'' -- meaning those principles which are | recognized by most nations. [2] The Geneva and Hague | Conventions were signed and ratified by the United States in | 1956. They have a long history. They were developed through | many wars, starting in 1864. Their present versions arose | out of the depredations of World War II. As the Geneva | Convention requires, the United States codified their | enforcement in the U.S. Code. [3]. | | Geneva forbids ``the passing of sentences and the | carrying out of executions without previous judgment | pronounced by a regularly constituted court, affording all | the judicial guarantees which are recognized as | indispensable by civilized peoples.'' It is forbidden under | the Hague Convention ``to declare abolished, suspended, or | inadmissible in a court of law the rights and actions of the | nationals of the hostile party.'' [4] Think about what Bush | has done by detaining combatants at Guantanamo for over a | year without trial . . . or by taking persons out of civil | courts and throwing them in military brigs for eventual | trial before military tribunals . . . tribunals that do | not have judicial guarantees that meet basic Constitutional | or international human rights standards. Think about the | lack of judicial guarantees, the lack of access to a jury of | peers, of basic rules of evidence (that disallow hearsay, | for example), the right to confidential communications with | and zealous representation by an attorney, and the right to | appeal to an independent judicial body. The Bush Military | Tribunals fail to guarantee any of these protections. | | In fact, the Geneva Convention not only requires due | process by regularly constituted courts, but requires that | every captured person ``whose status is in doubt'' have his | status determined by a competent tribunal. The official | Geneva Commentary states that ``[t]his amendment was based | on the view that decisions which might have the gravest | consequences should not be left to a single person . . . | The matter should be taken to court.'' Because combatants | might be subject to capital punishment, a further amendment | was made, ``stipulating that a decision regarding persons | whose status was in doubt would be taken by a `competent | tribunal,' and not a specifically a military tribunal.'' [5] | A unilateral determination by the President that captives | are ``unlawful enemy combatants'' does NOT meet the | requirements of the Geneva Convention. It is rumored that | some detainees have already been deported to other | countries. (Some rumors have it that these persons were | deported to countries that use harsher interrogation methods | than we do.) The 1945 Charter of the International Military | Tribunal forbids the deportation (not to mention the | ill-treatment or murder) of ``civilian population of or in | occupied territory'' for ``any . . . purpose.'' [6] Geneva | forbids the ``unlawful deportation or transfer or unlawful | confinement of a protected person . . . or willfully | depriving a protected person of the rights of fair and | regular trial.'' [7] Geneva defines protected persons as | those ``who, at a given moment and in any manner whatsoever, | find themselves, in case of a conflict or occupation, in the | hands of a Party to the conflict or Occupying Power of which | they are not nationals.'' [8] While Geneva makes rules for | how combatants and civilians are to be treated, it also | makes rules that apply to the nation who captures them - and | to those that violate the treaty. The Geneva Conventions | ``were the first treaties to require States to prosecute | violators, regardless of their nationality or the place | where the offence is committed.'' Furthermore, under Geneva, | ``States must not only respect but `ensure respect' for | [international humanitarian] law.'' [9] The 1929 Geneva | Convention abolished the provision that the Convention is | binding only if all the belligerents are bound by it. In | other words, Geneva is binding on all. | | Finally, Geneva is applicable in all circumstances. | This means that ``no Power bound by the Convention can offer | any valid pretext, legal or other, for not respecting the | Convention in all its parts.'' Whether the war is just or | unjust, a war of aggression or of resistance to aggression, | all parties are bound, not merely to take the necessary | legislative action to prevent or repress violations, but to | search for, and prosecute, guilty parties. No signatory can | evade this responsibility. [10] The Bush Administration is | denying terrorist suspects hearings by a competent tribunal | on their status, and is disobeying the intent of the | conventions that combatants should be classified as POWs | until such a hearing finds otherwise. The legal processes | that will be used in the military tribunals violate both the | Conventions and any rational concept of justice; they | presume guilt, lack independent counsel, and lack appeal to | independent competent authority. These are all deeply | troubling flaws that cannot be ignored. Any one of those | things by itself would be a war crime. Taken together, they | are an outrage against humanity. | | The United States enacted section 2441 of Title 18 of | the United States Code to enforce Geneva. Section 2441 | states that ``Whoever, whether inside or outside the United | States, commits a war crime . . . shall be fined under | this title or imprisoned for life or any term of years, or | both, and if death results to the victim, shall also be | subject to the penalty of death.'' [11] In its pertinent | part, subsection (c) defines a war crime as: | | (1) a grave breach in any of the international | conventions signed at Geneva 12 August 1949, or any protocol | to such convention to which the United States is a party; | | (2) prohibited by Article 23, 25, 27, or 28 of the | Annex to the Hague Convention IV, Respecting the Laws and | Customs of War on Land, signed 18 October 1907; | | (3) which constitutes a violation of common Article 3 | of the international conventions signed at Geneva, 12 August | 1949, or any protocol to such convention to which the United | States is a party . . . [12] Clearly, the Bush | Administration is flagrantly violating Geneva, and in doing | so, it is violating the United States Constitution, | international humanitarian law, and domestic federal law. | How can Bush get away with this? Military necessity. | | Next, in Part Three of the Bush War, the authors | discuss the doctrine of military necessity and conclude that | it does not justify Bush's actions. | | ___ | | NOTES: | | 1 Jennifer Van Bergen [ jvb@truthout.org ] is a frequent | contributor to Truthout. She holds a J.D. from Cardozo | School of Law and will be teaching a course on ``The | Anti-Terrorism Laws, the Constitution and Civil Rights'' at | the New School Online University, NY, this Fall. | | Charles B. Gittings [ cbgittings@pacbell.net ] is a computer | programmer and founder of the Project to Enforce the Geneva | Conventions (PEGC) [ http://63.206.217.42/geneva_project/ ] | | 2 See Paquete Habana, 175 U.S. 677 (1900) and U.S. v. | Belmont, 301 U.S. 324 (1934). | | 3 18 U.S. Code, section 2441. [ | http://www4.law.cornell.edu/uscode/18/2441.html ] | | 4 Geneva Common Article [ | http://www.yale.edu/lawweb/avalon/lawofwar/geneva03.htm#art3 | ] 3(1)(d); Hague IV Annex [ | http://www.yale.edu/lawweb/avalon/lawofwar/hague04.htm#art23 | ] (HR) Article 23. | | 5 International Committee of the Red Cross (ICRC) (Jean S. | Pictet, ed.), Commentary to the Protocol Additional to the | Geneva Conventions of 12 August 1949, and relating to the | Protection of Victims of International Armed Conflicts [ | http://www.yale.edu/lawweb/avalon/imt/proc/imtconst.htm#sec1 | ], 8 June 1977 (hereafter ``Geneva Commentary''), vol. 3, | pp. 75-76. | | 6 IMT Charter (London 1945). | | 7 Hague IV Annex [ | http://www.yale.edu/lawweb/avalon/lawofwar/hague04.htm#art23 | ] (HR) Art. 23-28. | | 8 Fourth Geneva Convention [ | http://www.icrc.org/ihl.nsf/c525816bde96b7fd41256739003e636a/78eb50ead6ee7aa1c12563cd0051b9d4?OpenDocument | ] (Civilians) Article 4. Other definitions specifically | include POW's. See Pietro Verri, Dictionary of the | International Law of Armed Conflict, (ICRC, 1992). | | 9 Both quotes from: ICRC, Punishing Violations of | International Humanitarian Law at the National Level: A | Guide for Common Law States (2001), pp. 9-10 (emphasis in | the original). | | 10 All information in this paragraph is from: ICRC, Geneva | Commentary, vol. 3, p. 27. | | 11 See footnote 12 for link. This statute applies only to | violations against U.S. citizens. See footnote 7 for the | link to the Hague Convention articles. | | 12 http://www4.law.cornell.edu/uscode/18/2441.html. The | clause ends with ``and which deals with non-international | armed conflict.'' Thus, clause (1) and (2) apply to | international conflicts, and clause (3) applies to | non-international ones. The meaning of this is that there is | no ``sovereign immunity'' for officials who commit war | crimes against domestic rebels, criminals, or untermenschen. | (Sub clause (4) relates to any person who willfully kills or | causes serious injury to civilians under the Protocol on | Prohibitions or Restrictions on the Use of Mines, | Booby-Traps and Other Devices.) | | | © Copyright 2003 by TruthOut.org | | (In accordance with Title 17 U.S.C. Section 107, this | material is distributed without profit to those who have | expressed a prior interest in receiving the included | information for research and educational purposes.) | | ____________________________________________________________ | | | Van Bergen and Gittings | Military Necessity or War Crimes? | Part III | http://truthout.org/docs_03/072603D.shtml | http://truthout.org/docs_03/printer_072603D.shtml | | | Bush War: Military Necessity or War Crimes? | By Jennifer Van Bergen & Charles B. Gittings [1] | t r u t h o u t | Tuesday, 15 July 2003 | | [Editor's Note] This is Part Three of a three-part | series that raises the question whether the ``Bush War'' - | namely, the domestic agenda in the so-called ``war on | terrorism,'' the Military Tribunal Order of November 13, | 2001, the illegitimate detention of suspects at Guantanamo | Bay and elsewhere without due process -- are justified, as | the Bush Administration claims, by the doctrine of | ``military necessity,'' or whether they, in fact, constitute | violations of the Geneva Conventions, which would thus be | ``war crimes'' under United States law, subject to capital | punishment. Part One introduces the question. Part Two | discusses the Geneva and Hague Conventions, which the | authors claim Bush is violating. Part Three discusses the | doctrine of military necessity and concludes military | necessity does not justify the Bush War. | | | Military Necessity | | As we wrote yesterday, the Bush Administration is | violating Geneva, and in doing so, it is violating the | United States Constitution, international law, and federal | domestic law. The President and his officials get away with | this by claiming "military necessity." The determination of | military necessity shifts the balance on most prohibitions. | The Third Geneva Convention forbids: | | Wilful killing, torture or inhuman treatment, including | biological experiments, wilfully causing great suffering or | serious injury to body or health, unlawful deportation or | transfer or unlawful confinement of a protected person, | compelling a protected person to serve in the forces of a | hostile Power, or wilfully depriving a protected person of | the rights of fair and regular trial prescribed in the | present Convention, taking of hostages and extensive | destruction and appropriation of property, not justified by | military necessity and carried out unlawfully and wantonly. | [2] | | The Hague Convention prohibits destruction or seizure | of "the enemy's property, unless such destruction or seizure | be imperatively demanded by the necessities of war." [3] | | "Military necessity" is a term that has been thrown | around quite a bit by this Administration. What is it? | According to one scholar: | | Military necessity was first stated as a legal principle in | General Orders No. 100, a codification of the law of war | drafted by Francis Lieber and issued by President Lincoln in | 1863. Controversial from the beginning, the principle was | nevertheless intended as a new restraint on military | discretion, as Lincoln's application of it during the Civil | War demonstrates. Military necessity remains an important | restraint on military operations in new situations for which | specific rules have yet to be established. [4] | | Lieber wrote that "Military necessity, as understood by | modern civilized nations, consists in the necessity of those | measures which are indispensable for securing the ends of | the war, and which are lawful according to the modern law | and usages of war." [5] | | Lieber's language is reflected in the Commentary to the | 1977 Protocol Additional to the Geneva Conventions, which | states that military necessity "means the necessity for | measures which are essential to attain the goals of war, and | which are lawful in accordance with the laws and customs of | war." [6] | | The concept of military necessity comes from the idea | of "just war," which is based on the idea of a human society | with norms and morals that transcend national boundaries and | apply to all humanity. According to the 16th century Dutch | jurist, Hugo Grotius, war is just if | | (1) the danger faced by the nation is immediate, | | (2) the force used is necessary to adequately defend the | nation's interests, and | | (3) the use of force is proportionate to the threatened | danger. [7] | | According to one commentator, there are three constraints on | the free exercise of military necessity: | | First, any attack must be intended and tend toward the | military defeat of the enemy; attacks not so intended cannot | be justified by military necessity because they would have | no military purpose. Second, even an attack aimed at the | military weakening of the enemy must not cause harm to | civilians or civilian objects that is excessive in relation | to the concrete and direct military advantage anticipated. | Third, military necessity cannot justify violation of the | other rules of IHL [International Humanitarian law]. [8] | | "[T]he principle of necessity specifies that a military | operation is forbidden if there is some alternative | operation that causes less destruction but has the same | probability of producing a successful military result." [9] | | The Truth About Bush's Wars | | The question must be asked, then: is the Bush | Administration following Geneva, except to the extent that | "military necessity" requires otherwise? | | Clearly not. Military necessity cannot justify | violation of rules of international humanitarian law, which | include those provisions in the Geneva and Hague Conventions | relating to status determination of captives, right to a | fair hearing, legal representation, and full due process. | Military necessity does not justify indefinite detention of | suspects without charge. It does not justify violation of | the United States Constitution. Nor can military necessity | sanction the violation of federal criminal law. | | And, where is the necessity in committing an act that | is explicitly prohibited by law? (Remember 18 U.S.C. 2441 | explicitly prohibits violation of Geneva and Hague and | requires the United States to prosecute violators. This | means that not only is every official who violates 2441 | guilty of a war crime, but every federal prosecutor in this | country who does not prosecute them is failing his or her | duty.) | | What about protecting our freedoms could possibly | justify preventing our laws from being enforced? And since | when does "necessity" entail doing anything that someone | happens to think is a good idea without the least regard for | any civilized standard of conduct? | | A real necessity is obvious. When we launched the D-Day | invasion we knew that there were French civilians living in | the beachhead area who would very likely be injured or | killed, but we also knew that warning them of the invasion | would seriously jeopardize the chance of it's success. That | is an example of a real military necessity: a specific | instance where the specific circumstances require a specific | method. | | It is not necessity to simply do whatever you think | might possibly give you some tactical advantage or leverage. | If we were to capture some of Osama Bin Laden's children, we | might be able to exert some pressure on him by roasting them | one by one over an open fire, but there wouldn't be anything | necessary about it -- it would simply be another atrocity | committed by an administration that has not the least | understanding of necessity because they are lost in | hysteria, greed, and the self-serving conviction of their | own infallibility. | | ___ | | NOTES: | | 1 Jennifer Van Bergen [ jvb@truthout.org ] is a frequent | contributor to Truthout. She holds a J.D. from Cardozo | School of Law and will be teaching a course on "The | Anti-Terrorism Laws, the Constitution and Civil Rights" at | the New School Online University, NY, this Fall. | | Charles B. Gittings [ cbgittings@pacbell.net ] is a computer | programmer and founder of the Project to Enforce the Geneva | Conventions (PEGC) [ http://63.206.217.42/geneva_project/ ], | | 2 Third Geneva Convention Article 130. The spelling is so in | the original. [ | http://www.yale.edu/lawweb/avalon/lawofwar/geneva03.htm#art130 | ] | | 3 Hague IV Annex (HR) Article 23. [ | http://www.yale.edu/lawweb/avalon/lawofwar/hague04.htm#art23 | ] | | 4 Burrus M. Carnahan, "Lincoln, Lieber and the Laws of War: | The Origins and Limits of the Principle of Military | Necessity," 92 American Journal of Int'l Law [ | http://www.asil.org/ajil/ajil982.htm ], Vol. 92 (No. 2), p. | 213 (April 1998). | | 5 www.commonlaw.com/Lieber.html. [ | http://www.commonlaw.com/Lieber.html ] | | 6 ICRC, Geneva Commentary [ | http://www.icrc.org/ihl.nsf/b466ed681ddfcfd241256739003e6368/d80d14d84bf36b92c12563cd00434fbd | ], pp. 681-82. | | 7 See Rebecca Grant, "In Search of Lawful Targets," [ | http://www.afa.org/magazine/feb2003/02targets03.pdf ] Air | Force Magazine (February 2003). | | 8 Francoise Hampson, "Military Necessity," [ | http://www.crimesofwar.org/thebook/military-necessity.html ] | (From Crimes of War Project - The Book). | | 9 Douglas P. Lackey, The Ethics of War and Peace [ | http://198.231.69.12/papers/amsc1/012.html#n10 ] (1989) p. | 59, quoted in, Colonel J.G. Fleury, "Jus In Bello and | Military Necessity," Department of National Defence | (Canada), Advanced Military Studies Course ("This paper was | written by a student attending the Canadian Forces College | in fulfillment of one of the communication skills | requirements of the Course of Studies. The paper is a | scholastic document, and thus contains facts and opinions | which the author alone considered appropriate and correct | for the subject. It does not necessarily reflect the policy | or the opinion of any agency, including the Government of | Canada and the Canadian Department of National Defence."). | | © Copyright 2003 by TruthOut.org | | | (In accordance with Title 17 U.S.C. Section 107, this | material is distributed without profit to those who have | expressed a prior interest in receiving the included | information for research and educational purposes.) |______________________________________________________________