ADV MEMANI
What I'm doing here, Mr Chairman, I'm referring you to the bundle, I'm saying look at both applications that are submitted by Mr Motsamai.  They contain facts on most of the applications that he's made and Mr Visser and Mr Wagner chose to raise a dispute about whether the rest of incidents formed part of his application.  Now that was a legal argument.
	My understanding is that a lawyer whose faced with such a situation prepares all the facts as well, Mr Motsamai was already making the allegations.  He did not make the allegations against - as far as Mr Venter only is concerned.  Throughout he spoke of the rest of the incidents which are contained again in the second, what we call the second application.
    Mr Visser cannot be heard to say that at that stage he didn't consult on the rest of the allegations because he wanted to raise, would I say a point in limine that they were not properly before this Court, before this forum.