ADV MEMANI
I started with Queenie's clinic, with Mzuzwana and then Queenie's clinic, Winnie's house, Situ Mzuzwana's parental home, Bobby Sebotsa's brother's house, Janie Mohape's car, Tawhata's car, Bolasha's house, Kuzi's house, Sekgopi Malebo, the mission house in Botshabelo.
	Mr Chairman, my attorney indicates that these are matters 6.3, 6.4 and 6.6 to 6.14.
	In all these incidents again Mr Motsamai had no political ..rather no personal conflict at all with the victims. All these people were political activists, and Mr Motsamai has been described as a good policeman by his colleagues. There has been no suggestion that he was motivated by misconduct in attacking these people. If he was a good policeman he would have been a policeman who carried out his instructions, and he carried out the instructions.
	Mr Chairman, the Police have no version about these incidents. They have denied knowing about the incidents and we had the somewhat surprising position taken by Bester, for instance, when he dealt with Winnie Mandela's bombing that he regarded it as an unrest thing, that he would leave it there.
He says the thought had not occurred to him that he might - that the Security Branch or certain members of the Security Branch might have been behind the bombing. Mr Chairman, that simply cannot be true. He did not follow it up because he knew he was responsible for it and it was himself - the incident that he did not direct his attention towards the Security Branch.
	Mr Chairman, the only reasonable explanation for the denials is that these policemen were responsible, and to admit that they were responsible would lead to their prosecution probably. They have also not applied for amnesty for these incidents.	
	On occasions these policemen attempted to discredit Mr Motsamai. They attempted to discredit him by saying, suggesting things like Nicosi's house was bombed as a result of a ritual murder. These things were just not followed up. No evidence was led, no-one claimed that he ever gave those instructions, and my submission is that an adverse inference
should be drawn against them for having made these suggestions and no evidence having been led about them.
	Mr Chairman, in conclusion I humbly submit that Mr Motsamai is entitled to be granted amnesty in respect of all the offences for which he has applied for amnesty.