MR KNOETZE
Mr Chairman, may I at this stage intervene and indicate to you that in our view, it is not necessary for our client to specify each and every incident as my learned friend is now trying to indicate.
	The Act refers to acts, omissions and offences and Gen Van der Westhuizen's amnesty application clearly indicates that he seeks amnesty for everything in connection with Katzen, and everything that we have discussed, everything that we have placed before you.
	So that an enquiry such as this, firstly in my view, is unnecessary and secondly, would perhaps bind my client to those incidents that my learned friend is referring to, and we do not wish to be bound.
	It is possible if you take a Plan such as Katzen, that somebody thinking that he is exercising his official duties, and thinking that he has to act in terms of what was written there, does something of which my client is unaware.  
	It may come out later, and if we have then not mentioned such an incident and asked for amnesty for that, we can be held responsible for that, be charged subsequently.
	That is why, on purpose, we did not in this application specify offences, acts or omissions, we ask amnesty for everything, as a whole.  I may however, indicate Mr Chairman, that we have prepared a list of incidents which may either be delicts or offences and if you wish, we are prepared to hand that to you, but we would only do that on the basis that we make it very clear that we do not restrict our application to those incidents that we have identified.  	Somebody else may have another view, some Prosecutor, some Judge, some Magistrate and as I have already said, somebody may have done something that we do not know of and may then say but I did it in terms of Katzen and then by implication, the implication will be that we are also guilty of that.  We do not want to be in that position.