MR WILLS
Yes, exactly.  In fact, the evidence in mitigation that is transcribed, follows almost to the letter of the mitigation, or sorry of the evidence, that was led before this Commission, the viva voce evidence.  And it's my submission that this lends credence to Mr Mbambo when he indicated in answer to those questions, that he did indicate this in Court and that there was no mala fides or an attempt to not disclose the facts on his part.
	Regarding that murder, clearly, taking into account and on the basis that Mrs Umbuyazi was involved and had ordered the, or had sanctioned the attack, when basically the evidence is Wiseman Ngxongo came to Izingolweni, he found Mbambo, Mbambo together went with Ngxongo to Mrs Umbuyazi's house.  Mrs Umbuyazi then made a phone call to the IFP contact in Bushbuckridge or Mpumalanga, she spoke to, we think, the chairperson there, and then she came back off the phone and she said, you guys must go and, in a hurry, and perform this mission.  That is borne out in the transcript of the record in the criminal proceedings, and is reflected as I say at pages 58, 59 and 60 of the bundle that I mentioned earlier, that is amnesty, the Ngxongo matter 4034/96.
	I submit in those circumstances, again, the applicant has satisfied both the requirements of full disclosure and the fact that this act was an act committed, associated with a political objective.  Again, to emphasise this, the representative of Mr Tuledi's family, attorney Ntuli from Nelspruit, was present at the proceedings at Ermelo, and he made no suggestion that one, Tuledi was not an active member of the ANC, and secondly, that Tuledi was not involved in the smuggling of weapons for the IFP, for the ANC, as was alleged by initially Sipho Umviyani as being the reason why Tuledi had to die.  I submit that had that not been the case that, particularly in the light of the fact that that family was represented, would have brought to the attention of the Committee.  My submission obviously being that one must at the very least assume that Tuledi was an active ANC person and in that sense he was a legitimate target and an obstruction to the IFP operations in that region.
	Turning now to the Mandini matters.  On the completion of my Heads I realised that I should have actually placed these within the context of the Izingolweni matters because they occurred at the same time.  Again, these involve applicant seven, in the main, and to a lesser extent, applicant six.  The reason for this being that the prime mover of these operations, the evidence suggests, is the, is chief Mataba from the Inyoni district in northern Natal, which I think adjoins the Izingolweni town boundaries, it's in the Umtinzini district.  Now you will recall from the evidence and the statement of Mbambo, that chief Mataba was listed as one of the person who he regarded as being one of the hit squad commanders.  Basically what occurred was that chief Mataba, in the main, made certain requests of applicants six and seven, to perform certain deeds.  Should I rather be, sorry I withdraw that statement, he essentially ordered six and seven to take out certain people.  Amongst them a Cosatu bus driver, certain indunas who were allowing free political association areas, and a number of others.  
	Now not only did he enlist their assistance in these matters, he also provided most of the logistical requirements.  In fact in the, on the one occasion chief Mataba himself pointed out the house where the target lived, and on other instances he provided certain persons to do that for him.  But in all instances, his blue Toyota Cressida vehicle was used in the incidents.  I submit in that context these matters must be seen, the ones specifically ordered by Mataba, as being act with, associated with a political objective.
There are a number of other acts which are directed against what appear to be Cosatu individuals in the Sundumbili area.  These also relate back to chief Mataba's concerns.  And those that don't, I think there's two that don't, I cannot specifically ...(intervention)