CHAIRPERSON
Yes, please.
MR BIZOS
"No, we won't do that, but Themba listen here, the thing is ne, people are coming to work, now they're throwing stones at them.  Now, to block the people they're going to keep them in there but they don't want to do that, they want the people to come into town.  There is no problem with that as long as we can just - we don't know who to liaise with on the ground man, that's our main problem now."
		"Even in Alexandra?"
		"Yes."
		"They can speak to Xhoso, Elias Xhoso.  I'm not sure if that is right, or Philip Langamandla, okay.  Philip Langamandla or Elias Konko or David Khumalo."
		"Tell me Themba are you also coming here to town?"
		"Yes."
		"Tell, me, to address the people here at the library?"
		"Yes."
		"And tell me, another thing that I want to ask you Themba, are the people going to Pretoria as well?"
		"I think so."
		"To the IEC?"
		"Yes, but we are still going to negotiate with them not to do so."
So, we submit this too proves that he was a person to - there should be no difficulty there.
"Did the ...(inaudible) speak to you last night?"
		"No, he didn't speak to me last night."
		"We quickly need some sniffer dogs yes, because we have information that the podium there will be, the ANC will do something and the National Party Government Police or agents"
I draw attention to the fact that there was obvious, that it may be inferred that there was consultation between Mr Ndlovu and Mr Themba Nkosa because you will recall that Mr Nkosa ...[indistinct]  
	Now, the rest, Mr Chairman, we put the document in, but we don't have to read it in, Mr Chairman. 	That the IFP made no attempt to co-ordinate the activities with the relevant peace structures and the SAP.  That again should have been an easy matter for an admission, but it was not made. 
"5.  That the IFP foresaw that there would be wide public violence committed by many of those attending the gathering or participating in associated marches"
Well, they were not prepared to make any admission in relation to that.  
"That groups of marches attending the gathering attacked and killed pedestrians and motorists on their way to the gathering".
They deny those allegations.  The one denies and the other one says, no knowledge, does not have any instructions in relation to it.  
	In view of the evidence that was available, we will submit that it's quite easy to make - they should consider, possibly, before these proceedings get out of hand, that they make a formal admission.
"That a number of groups of marches passed Shell House earlier on the 28th of March 1994, during which they behaved provocatively and launched mock attacks on ANC security guards, but there were not shot at by the said security guards."
Again there are videos, there are - well, let me put it this way, although there may not be videos of these particular marches, there is video material and there is sufficient evidence from persons other than the security guards from whom we appear, for them to be able to ascertain and whether they should make an admission in relation to that remark.  Then paragraph 8,
"That the organisers of the gathering and the marchers were at all material times aware that the Shell House was the national headquarters of the ANC and that Lancet Hall was the regional headquarters of the ANC."
There is a denial of that by Dr van Wyk and Mosselson says that they can't admit or deny. 
"That the said organisers were at all material times aware that there was an extensive history of conflict
frequently violent between members of the IFP and members of the ANC and that in view of the imminence of the first democratic election, political feelings were running very high as at 28th March 1994."
Again we have in 1.4 page 96, there is an admission of they were aware of the history of conflict, Mr Chairman, but that is Dr van Wyk but Mosselson says that they can't admit or deny it.  So we are in this position Mr Chairman, that if one of the parties only admits, we have to prove it.  
Then, in relation to paragraph 12
"That from Park Station the marchers did not move in the direction of Library Gardens"
11, I beg you pardon, I'm reading paragraph 11, 
"That from Park Station the marchers did not move in the direction of Library Gardens but split into groups, some moving east along Loot Street and then south down King George Street, and others moving south down Wanderer Street then east along De Villiers Street."
I'm sorry, I omitted paragraph 10,
"That the marchers involved in the shooting incident at Shell House were from the Mansfield Hostel and had travelled from there by train to Park Station."
Now, 10, 11 and 12 are admitted, which I must read,
"That the marches moving into these groups then advanced at the intersection of King George, converged I beg your pardon, and De Villiers Streets being at the north-west corner of Shell House."
Those three paragraphs are admitted by Dr van Wyk in paragraph 1.5 on page 96.  Mosselson say that they can't admit or deny it.  Again, we would submit that having regard to the evidence that was given and the information that would be easily ascertainable in relation to 11 and 12, Mosselson say that they had not instructions in 11 to 12.  May I indicate that this document was served on the 16th of April and no instructions have yet been obtained.  
	Paragraph 13 on page 9,
"That the portion of King George Street between De Villiers Street and Plein Street, adjacent to Shell House on its western side, had a number of substantial concrete barricades spread across the road both at its northern and its southern points, which barricades rendered the passage by large number of people patently it difficult and unsuitable."
This is partly admitted and partly denied on page 96, paragraph 1.6, they say that,
"The objectors admit that there were some concrete barriers spread across the road in King George Street, at the corner of King George Street and De Villiers Street and at the corner of King George Street and Plein Street but would not admit that these barricades rendered the passage by a large number of people patently difficult and unsuitable."
May I indicate, Mr Chairman, that there is a plan of the area which is being referred to.  Copies are available and we will make them available to the Committee.  Perhaps I should hand them in at this stage so that - it was one that was handed in at the inquest.  My learned friends are familiar with it but we will have them copied.