MR BERGER
Chairperson, before my learned starts, might I hand in to you three bundles.  They are the documents which were filled out and submitted to the Reparations Committee.  They have been divided into
- Deceased persons;
- Injured persons and;
- Damage to property.  
I'm not handing it in as an exhibit, but I'm handing it in for your assistance.  That should have the relevant details for each of the victims.  
	Chairperson, the other point that I just wished to raise before my learned friend continues with his cross-examination, relates to what was put yesterday by my learned friend, Mr Lowies, in relation to the criminal trial and the calling in of certain witnesses, including Miriam Molete and Florence Molete and in relation to their apparent refusal to speak to Mr Strydom and the other counsel, on instructions from the ANC.
	I've read the relevant section of the record and in particular it's pages 3208 through to 3215, 3-2-1-5.  And with respect to my learned friend, I don't believe that he put the position fairly to the witness.  At page 3210, Mr Botha is asked, Adv Botha is asked by the court whether he spoke with all the people concerned and he's asked; is it - I'm translating from the Afrikaans: 
"Is it everyone's attitude that they have instructions from the ANC, not to speak to anyone besides the ANC?"
And Adv Botha says: 
"M'Lord, I was not able to speak to any of the witnesses other than two, Abudnega Mabusa and Simon Moloi, who informed me that they were conveying the attitude of the other persons."
There's then a debate and the judge says:
"Tell them that I am busy with a trial arising from the attack on Boipatong on the 17th of June.  I've been informed by one of the advocates who acts for the accused, that they have summoned you here to give possible evidence after they've consulted with you.  And I've been further informed that you tell the advocates that you are not prepared to consult with them because you've been instructed by representatives of the ANC, that you should not speak to anyone about the case other than the ANC, is that so?"
And then there's - no-one speaks, the record simply reflects:
"All the witness indicate that it is so."
... but no-one speaks.  Then the judge says:
"All of them are satisfied, is that so?"
And then again no-one speaks and it's:
"All the witnesses answer in the affirmative."
And immediately after that the judge says:
"As a result of the "mededeling" (as a result of this intimation) I've been informed that they say that they are now afraid to speak to the advocates because they have been told to do so, or prohibited to do so by the ANC, is that so?"
And then the interpreter says:
"No, M'Lord"
And then the court says:
"Why will you not speak with the advocates?"
And the interpreter says:
"They are not our advocates, M'Lord.  Mr Abudnega Mabusa wants to speak, M'Lord."
And then the court says:
"Yes"
And then Mr Mabusa says:
"We don't know these advocates.  This is the first time that we come into contact with them.  It would have been better if the previous advocates, if it was the previous advocates who had called us.  At this stage it is not a question of fear, we don't have trust."
And then the court says:
"Who is the advocate that you consulted with previously?"
Mr Mabusa says:
"There they sit."
And the interpreter says:
"He is pointing to the State advocates."
Then the court says:
"Who at the ANC offices said that, or said to them that they should not speak to anyone about the case other than the ANC."
And then Mr Mabusa says:
"Concerning the ANC, they are not at issue here, we are talking about the advocates currently before the court."
I'm not going to go through everything in detail, but then two described as "women witness", "vroue getuie" not identified, are asked:
"Is this the position, that you have been instructed by the ANC not to talk to anyone?"
And they say:
"No, it is not so, M'Lord."
Both of them say.  And then the second one says:
"We are amazed that we have been called by strange people, not those who usually call us."
And then ultimately the court asks, this is at 3213 in the middle:
"Are there any of them who say that they were told by the ANC not to speak to anyone other than the ANC?"
And the interpreter says:
"Skud die kop ontkennend" (They shake their heads in the negative, M'Lord)
The whole debate is from the witnesses saying; we trust the State advocates, we don't know who these people are and we don't want to speak to them for that reason.