MR BERGER
I base it on the evidence that I've presented to you.  I base it on the lack of evidence on the side of the applicants to actually identify any, come forward with any concrete evidence to show that any of the deceased were involved militarily and the fact that the people who were supposed to have been being observed at page 65 of bundle 1, none of them were killed.  Why is it that we have the deceased - not one of the deceased is on that list at page 65 and then of course the whole question of what they knew about what Vic McPherson, what they knew about Kabwe, that whole argument that I've already presented about the escalation of the concept and the time, the time in which we lived, 1985, the middle of 1985.  I ask the Committee to think back to what was happening at that time and how things were rapidly spiralling out of control.
	And then finally there were just two applicants, you will recall, there were two applicants, I forget their names now, whose evidence was that they were asked to gather certain information and they had no idea what that information was going to be used for.  Well they can't possibly have the requisite mens rea for any effects.