MR DEHAL
Mr Chairperson, in so far as that paragraph itself is concerned, that is page 13, paragraph 3.2.2.5, indeed subparagraph (a) is correct.  Subparagraph (c) it would seem follows from subparagraph (a), but in truth is not an objection in principle raised by myself, relative to the applicants represented by Ms Kooverjee and I, but indeed by Mr Berger, relative to Mr Ismail when he then testified.  It is not really a point I am taking, I simply supported Mr Berger.  In so far as subparagraph (b) is concerned, the terminology is incorrect, the inference therefore is incorrect.  I do not nor do my clients decline to provide the victims' legal representative with anything in that regard, I do not have any copies.  In fact when you, Mr Chairperson, enquired from my appropriately what might the word application refer to if it does not refer to the evidence of Mr McBride in the 29 hearing, I endeavoured to suggest what it may possibly refer to.  I do not have those documents.  Mr Brian Currin represented Mr McBride, I telephoned Mr Currin, I sought to have his files sent to me, but he indicated after careful search that the files he did find, would be of no use to me.  I do not decline to provide any documents, I do not have them, and I think in this regard, when I am given the opportunity to respond, what I will do is refer to non-committal aspects of bundle C, particularly the first seven pages, which allude to what that document application may possibly be.  Thank you.