MS GABRIEL
The first is that the problem in this case as we suggested was with full disclosure.  Full disclosure is not necessarily limited to just a portrayal of the relevant facts, but as was apparent from my cross-examination, full disclosure in this case must mean something more than selective disclosure.
	Let me start with the application of the 4th applicant.  At this point the family wishes to state quite clearly that they have no opposition to the amnesty application of the 4th respondent, 4th applicant, pardon me.  They are satisfied that he has made a full disclosure and that his objectives at the time were proportionally related to the instructions that he had received.  His versions of events have been consistent and they were made at the earliest possible opportunity.  As against that we have two versions set apart by some two and a half years submitted by the second applicant and the third applicant.  
	What's interesting in these applications is that they seek to distinguish their earlier versions about not recalling detail and suddenly in the second application recall a massive amount of detail when confronted with evidence by the family, seem to recall it and then when confronted by questioning recall even more details including what we were thinking at the time.
	So apart from distinguishing the fact that they could not remember earlier, they also seek to distinguish Taylor's version.  They point out that Taylor gave them the order.  They point out that Taylor was mistaken in believing that, and I quote: 
"Myself, du Preez and Laurrie Wasserman realised on questioning him that there was no evidence which we could take to court, although he himself admitted that his mission was the placing of bombs."
The question is why?  Why seek to distinguish these other aspects of Taylor's evidence?  On Taylor's version we see that the objective was to eliminate, not because of a lack of evidence, not merely because of a lack of evidence, but not because this man was suspected to be of serious and imminent danger, suspected to be a terrorist, but that is Taylor's version and he is dead and we will never know.  By seeking to distinguish this, what the applicants have done is to extract themselves out of all complicity in the planning and in the execution of Ninela's death.  
	What they have done is to confine themselves very clearly to the limited ambit of taking instructions and the minute they do that they are exonerated from having to explain the basis of their actions.  They are exonerated from having to explain whether the manner in which they reacted at that point, was justifiable and proportional in the circumstances.  So that, on my submission, is really the basis on which they seek to distinguish Taylor's  evidence.
	Now the explanation we are given, one of the explanations we are given is that Taylor had a bad memory.  If that is so, it is highly unlikely that he would remember detail.  It is highly unlikely that he would remember that the applicants were in fact with him.  It is more probable that a man suffering from lack of memory or bad memory would in fact remember very little.