UNKNOWN
Crimes planned or executed by the CCB outside the borders of the RSA in the period 98 or 99 and crimes planned or executed by the CCB within the Borders of the RSA in the same period.  The applicants have, with their own evidence, made it abundantly clear that the Committee has not been placed in a position to have regard to the full conspectus of facts relevant to the assessment of the factors listed in 20(3) Mr Chairman.  We have noted context is one, as we have noted, context is one of the considerations referred to in the Act.  Context surely concerns the overall activities of the CCB.  These activities were the context in which the offences for which amnesties are sought, were planned and executed.  The applicants have acknowledged this in a way in which the applications have been drafted.  All that - they have decided only to disclose those facts pertaining to context which happened to suite their version.  The context that suites their version, Mr Chairman to give us the mechanics of how things were done, and that sort of thing.  The Act also refers to proportionality.  Proportionality involves comparison, as far as for example the applications of Verster and Webb are concerned, it will certainly impact on the Committee's assessment of the proportionality of their conduct, were the Committee to know that for example, there was undisclosed evidence which showed the following, that apart from a few minor incidents, these applicants disclose they were in addition and at the same time responsible for the death of ten or twenty or fifty or a hundred other people and which explained why those other victims were targeted, which explained whether the victims were targeted as military targets or civilian targets, were they UDF or ANC or ECC or NUSAS, or AZAPO, so that we can see what the parameters of this conspiracy were.  It is submitted that it cannot be seriously suggested that the fact that Webb and Verster authorised the poisoning of water holes at refugee camps, is irrelevant to an assessment of their entitlement to amnesty.
	The relevance and importance of evidence concerned in the full extent of the conspiracy, is emphasised by the Applicant's own testimony.  Verster's evidence was that the CCB activities were mainly outside the RSA.  He also said that Region 6's activities were only a drop on the CCB's activities.  We know that there were ten regions, the CCB 89 budget was approximately R30 000 000, that the CCB had between 170 and 200 projects of which half were offensive in nature.  It is also no argument to say that only South African operations were relevant to these proceedings, because Region 6 only operated in the Republic.  The evidence is that Region 6 was also being used externally and Basson's evidence is quoted.  In fact Maree has almost exclusively been working outside the Republic and Basson, the Region 6 Co-ordinator, was involved in various operations in South Africa, Maree's quote.  
"Basson also testified that the Region 6 had other members who weren't applying for amnesty because they worked externally."