MR MARTINI
Yes, Chairperson.  With respect, where that evidence to contradict all the evidence of the applicants - the General stated CCB was a unit of the Special Forces, forming part of the South African Defence Force, the budget came from the South African Defence Force, they were paid by the South African Defence Force.  Possibly one can say by the very nature that they were covert, they weren't uniform soldiers but they clearly fell within the ambit of the Security Forces.  How somebody could argue that they didn't after all the evidence, is beyond me.  They were controlled by a General, and according to the General, the footsoldiers so to speak, the applicant wouldn't know this, had to revert to higher authority, to the Minister of Defence, for certain instructions.  If Gen Webb's version is to be believed.  If someone had to be killed, I think his evidence was he had to revert to a higher authority which would be, I'm not sure if it was the General or the Minister of Defence or the Chief of Defence.  But quite clearly the Minute Mr Bizos handed in, L1(?) refers to the CCB, where the General signed it, where he tried to redefine murder.  That's raised in my Heads, Chairperson.  So with respect, I cannot see how any member of this Committee could ever find that the applicant was not either an employee of the State, or a member of the Security Forces.  Based on the evidence we've heard.