MR WAGNER
Thank you, Mr Chairman, I appear again on behalf of Brigadier Willem Schoon.  As indicated in a letter to you last Friday, I will make short submissions on his behalf.  I had the submissions typed in memo form.  I understand copies have been made;  it is before you as members.
	My client Brig Schoon received notice on the 15th January this year in terms of section 19(4) of Act 34 of 1995 informing him of these proceedings as a person implicated or having an interest herein.  I have requested Adv Mpshe to provide me with a copy of the applications, which was granted, and for which I thank him.  I was given the applications of Mr Coetzee and Mr Chikalanga, so we assume that my client is not implicated in the application of Mr Nofomela.  This enabled me to take instructions from client regarding all the allegations therein implicating him.
	I have had the opportunity of consulting with Brig Schoon and it is apparent that he is implicated by Mr Coetzee in his written application in no less than 10 separate incidents for which amnesty is now being sought.
	My instructions of Brig Schoon is that Mr Coetzee is once again proving himself to be an utterly unreliable 
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witness and that the majority of allegations against my client are disputed by him.
	However, for my client to prove this, Mr Coetzee will have to be cross-examined in detail on each and every incident and allegation and in view of the many occasions where Mr Coetzee has testified in the past and all the different versions given by him to date, proper cross-examination in this regard could last a couple of weeks in my estimate. 
	This, the Committee has indicated to me, is quite impossible inter alia in view of time constraints applicable to this forum.  So it was decided that a largely limited cross-examination of Mr Coetzee will serve no constructive purpose whatsoever and that I should merely put on record on behalf of my client the issues disputed by him.  So I will deal with them one by one. 
	The first incident where my client is implicated is the murder of Peter Dlamini and Selby Mavuso which you will find on page 7 of the papers.  In this regard Mr Coetzee alleges that Brig Schoon gave the order for the elimination of these two victims.  I wish to put on record this is denied by Brig Schoon as a blatant lie.  He has no knowledge of this;  it is simply denied.
	The next allegation is the incident on page 10 of your papers, the murder of Gonisiswe Kondile.  It is alleged by Mr Coetzee that Brig Schoon was involved in this matter and in the process gave him certain instructions.  This is also denied by my client.  My instructions are that he was not involved in this matter and that he never gave any instructions in this regard, as alleged or otherwise. 
	The next incident is the murder of Ace Moema which is
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on page 12 of the papers.  I have consulted with my client and my instructions at present are that he cannot remember this incident and due to a lack of time we were unable to investigate this matter fully and at present we are in no position to comment thereon.  If necessary, and if allowed, we can deal with this at a later stage.
	The next incident is the conspiracy to murder Mr Marius Schoon, that is on page 19 of the papers before you.  My instructions are that my client has knowledge of this incident.  But, as far as he can remember, this was an incident initiated by Mr Coetzee himself.  Therefore my client denies the particulars of this incident as set out by Mr Coetzee in his papers. 
	The next implication is found on page 21 of the papers, namely the attack on Joyce Depalis house in Gaberone.  Brig Schoon denies that he had any involvement in this matter whatsoever and specifically denies that he gave any orders to Mr Coetzee as alleged by him. 
	The next incident is the kidnapping of one Joe Pillay, the incident described on page 23 of the papers.  In this regard my instructions are clear.  Brig Schoon admits his involvement in this matter and I am allowed to tell you that he has already applied for amnesty in this regard.
	The next incident is the attempted kidnapping of an ANC member called General.  This is the incident on page 25 of the application papers.  It is alleged by Mr Coetzee that Brig Schoon gave the instructions to kidnap this person in Swaziland.  My client specifically denies this allegation and bears no knowledge regarding who gave such instructions, if any. 
	Then the incident on page 28 of the papers, the cover-
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up of the murder of a diamond dealer.  It is alleged by Mr Coetzee that this person was murdered and that my client was informed regarding the particulars thereof.  My instructions are that Brig Schoon has no knowledge of this incident and that the allegations of Mr Coetzee in this regard is denied by him. 
	Then we have the cover-up of a shooting incident at Lindley on page 31 of the papers.  Mr Coetzee alleges that my client was informed of this incident and that he was  part of the subsequent cover-up.  My instructions are that Brig Schoon was in fact informed of a shooting incident, but that it was dealt with by other officials.  He denies that he was part of any cover-up whatsoever, or that it was done with his approval.  
	The last incident where my client is implicated is the one on page 44 of the papers, the theft of a labour union vehicle.  My client remembers that he received money from Mr Coetzee to be handed over to Colonel Van Rensburg, but my instructions are that he was brought under the impression that this was a private transaction.  He therefore denies any knowledge of or involvement in the unlawful actions as alleged by Mr Coetzee.
	If I am allowed, Sir, I have two further points which I would like to put on record.  It is on page 4 of the document before you.  I would like to put on record that three further clients of mine are implicated in the application of Mr Coetzee, they are General J J Viktor, Colonel J C Coetzee and Colonel R Krause.  They have not properly been notified in terms of section 19(4) of your Act.  Although Mr Mpshe faxed copies of notices in this regard to my offices the day before yesterday, it is
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interesting to note that in this notices Mr Mpshe you identify my clients as potential victims.  I don't know whether that was seriously intended. 
	I have not been able to take instructions of these individuals in this regard, and therefore I have no option but to reserve all their rights.  However, it is noted that this Committee is apparently conducting its procedures without complying with the explicit provisions of the said section, which will most certainly raise a question mark regarding the regularity of these proceedings.  Thank you, Sir.