MR COETSER
Well the point is he has set out the factual situation in his statements and he has elaborated thereon, or indeed they have been gone through to see what he can remember and can't actually remember in relation to what he actually knows about the matter.  In so far as full disclosure is concerned, there are two issues to my mind.  Whether in relation to the information aspects that he's been questioned on, the Commission comes to the view that he has deliberately and intentionally hidden facts from this Commission on aspects that he has been questioned about and aspects which the Commission would like to know about.  That's the one.  The second aspect is whether or not the Commission was of the view that with regard to the information that he has conveyed to the Commission, he has deliberately lied.  If those two aspects are absent, well then in relation tot he information that he's disclosed and any further aspects the Commission wants to know about from him in the performance of the Commission's function, those two aspects are absent, then he has made full disclosure, from a practical point of view.  The only issues that remain are, are there indications that clearly show that in relation to the information he has provided, he has, in a material respect, lied to this Commission, or in relation to aspects of information incidents or whatever the Commission is interested in and want to know about, he has deliberately withheld information from the Commission.  Now I would, with respect, submit that in the analysis of his testimony, looking at it holistically, taking it as a whole, there is no proof that he has done either of those things.  What he has been exposed, is doing in one or two instances at worst is that he has indulged in reconstructive reasoning when providing the affidavits concerned, but in the controlled process of oral testimony and cross-examination, reconstructive reasoning on one or two aspects has been exposed, but I would, with respect, submit that in conveying what he knows about the situation to this Commission, these aspects are not particularly material.  Whether he was told for example by Pretorius, at the time when Pretorius spoke to him that there was going to be this raid on Botswana or whether he found out about it at Hammanskraal, is neither here nor there.  What difference does it make?  He found out about the raid.  It may be that he reconstructed in his mind that Pretorius told them this, whereas being tested in oral testimony on his memory, he realised, no, sorry, this came from Hammanskraal.
	Is that material?  I pose a rhetorical question.  I would submit not.  There are one or two other aspects that I would say that the same argument applies on those other two aspects.