MR DU PLESSIS
Thank you Mr Chairman and Honourable Membersof the Committee.  Mr Chairman before we start with dealing withthe evidence pertaining to our applications and before we startwith the proceedings there is one aspect that we would like todeal with first of all and which we would like to raise with theCommittee and the Members of the Committee.  That aspect dealswith the situation the applicants find themselves in pertainingto certain witnesses and certain documents which they might beable to use in support of their applications.  Certain people,participants in some of the deeds who are named in the applications,have made arrangements with the Attorney General to become Statewitnesses in possible criminal proceedings against some of theapplicants, especially Brigadier Cronje and Captain Hechter.
1A We/...
14
 We have had discussions with the Attorney General on this issueabout the possibility of using the evidence of some of these Statewitnesses to support the applicant's applications.  Clearly theState witnesses, if they speak the truth about their happeningswill be able to support the applicants in their applications andwill be able to corroborate certain facts.  Some of the Statewitnesses might also be able to shed some light on certain happeningsand certain issues pertaining to these applications outside thenarrow sphere of the deeds and the acts themselves.  
 I have prepared heads of argument on this matter which I wouldlike to hand up to the Commission which deals with my argumentin respect of the request that the applicants would want to maketo the Commission to facilitate or order that these State witnessesbe subpoenaed to come and give evidence at these hearings firstly,and secondly pertaining to the availability of the dockets inpossession of the Attorney General pertaining to the possiblecriminal proceedings in certain instances and pending criminalproceedings in other instances of some of the other applicants. We say that those documents, as well as the evidence of the Statewitnesses might or will serve to support the applications of theapplicants.  
 I beg leave to hand up copies of the heads of argument that Iprepared to the Committee.