[1] Hategekimana Appeal Judgement, para. 166 (considering that “a soldier from the Ngoma Military Camp” provided a reasonable identification of the alleged subordinate); Ntabakuze Appeal Judgement, para. 127 (upholding a finding that there was sufficient notice for crimes allegedly committed by “members of the Para-Commando Battalion” at specific locations); Muvunyi I Appeal Judgement, para. 55 (finding sufficient notice that alleged superior responsibility extended to the criminal acts of “ESO Camp soldiers” at a specific location); Ntagerura et al. Appeal Judgement, paras. 140, 141, 153 (establishing that sufficient notice was provided when the alleged subordinates were identified as soldiers from the camp under the accused’s control). See also Simba Appeal Judgement, paras. 71, 72 (confirming the Trial Chamber’s statement, in relation to notice of members of an alleged joint criminal enterprise, that it was sufficient to identify the general perpetrators “by broad category, such as Interahamwe or gendarmes” along with other geographic and temporal details). Notably, in the Simba case on which the Prosecution relies, the Trial Chamber also stated that it was “not satisfied that the Prosecution could have provided more specific identification”. Simba Trial Judgement, para. 393, quoted in Simba Appeal Judgement, para. 71, cited by Prosecution Response Brief (Ngirumpatse), para. 351.

[2] Bagosora and Nsengiyumva Appeal Judgement, paras. 131, 132; Muvunyi I Appeal Judgement, para. 94; Muhimana Appeal Judgement, para. 197. See also Renzaho Appeal Judgement, para. 128.