MR SAMUEL
Now I turn to page 6 paragraph 30.  Before I put my client's version to you, I just want to ask you a question regarding your earlier evidence, or your answer to a question raised by the learned Chairman.  The Chairman had asked you if Mr Mbane did not want to cooperate with you and if she had not suffered the heart attack, what would have been the position.  Your response was that you all would have denied that she was assaulted by your Special Forces as such.  Am I correct in saying that?  That was your response.