MR RHEEDE
Mr Chairperson, for the convenience of my client I'm just going to continue in Afrikaans.  My client has a reasonably serious problem, I must state from the very beginning that he is willing to testify here but he has been approached to make an affidavit in order to facilitate the procedure, but there were two reasons why he will not be making an affidavit.  Firstly, he has reading and writing problems and I would not want him to make an affidavit which he will have to read back in the future.
	Secondly, it is clear from the evidence that there are certain serious incriminating answers which will be requested.  He has not applied for amnesty and he has a certain reputation in the Western Cape, which could have serious problems for his rights and it is my instruction to request, in the light of the fact that the Commission has subpoenaed him in terms of Section 29, that a Section 31 Appeal be made for consultation with the Attorney-General within this jurisdiction or the Chief Attorney-General or the Director of Public Prosecutions, before he could actually be requested to answer these questions. 
	The second point that I would like to offer is that we would like direction regarding who exactly has subpoenaed him as a witness.  It would not appear to be the applicants because it appears as if their cases have been dealt with.  Would it be persons on behalf of the victims or is it the Committee?  This is my respectful submission that this indication will also influence who has the right to cross-examine him, upon which occasions he may be cross-examined.  If it is the Committee that has called him, then he should testify in the final instance, as it would be in a courtroom situation.  If it is on behalf of those persons who were involved in the Athlone Early Learning Centre, then it would be them who have subpoenaed him and they may cross-examine him and then be satisfied with the answers that he will provide.
	Similarly, this applies to the Committee who should be satisfied with the answers that he can provide.  It has emerged previously with this sort of application and I think specifically of Pik Botha's evidence that he gave, and this is an aspect to be clarified.