As early as December 2006, WILLIAM SAMOEI RUTO (“RUTO”) and HENRY KIPRONO KOSGEY (“KOSGEY”), prominent leaders of the Orange Democratic Movement (“ODM”) political party, began preparing a criminal plan to attack those identified as supporters of the Party of National Unity (“PNU”). JOSHUA ARAP SANG (“SANG”), a prominent ODM supporter, was a crucial part of the plan, using his radio program to collect supporters and provide signals to members of the plan on when and where to attack. To reach their goal, RUTO, KOSGEY and SANG coordinated a series of actors and institutions to establish a network, using it to implement an organizational policy to commit crimes. Their two goals were: (1) to gain power in the Rift Valley Province, Kenya (“Rift Valley”), and ultimately in the Republic of Kenya, and (2) to punish and expel from the Rift Valley those perceived to support the PNU (collectively referred to as “PNU supporters”).
Note: Much of the application was heavily redacted
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