MR LOWIES
Chair, with all due respect, I am not challenging the TRC Report.  It is there, it's a given - and with respect I have not had the chance to read the second paragraph at page 6 which answers your question and that is, the information is needed and now I quote
"Further, to consider whether to apply for the recusal of the Committee or any other member thereof"
In other words, with respect Chair, we are not asking you to judge the correctness of the TRC Report, you are the forum, with respect, where we apply for information.  Firstly, you are the forum, with respect, where we apply for a recusal if needs be.  You have to hear that and nobody else.  We say the application that we are bringing is the following, there is a prima facie report wherein damning findings were already made against my clients.  You are an extension of that body, brings in my argument of the reasonable suspicion of bias.  Now, in order to make a value decision on this, based on all the facts, we say on behalf of the applicants, please supply us with information whereafter we can make a value decision whether or not to ask for your recusal.  An important aspect would be the - the most important aspect - if yourself or any Member of the Committee formed part of those deliberations, with respect, it means that you were privy to a finding already on record, detrimental and prejudicial to my client's application and one of two things should then happen and I'm not asking you to rule on that yet because we're not there but the argument will go the relevance hereof is the following.  If this Committee or a Member thereof had prima facie prejudged a lay person in the position of my clients, the applicants, will form the opinion that the matter has been prejudged and I say this with the greatest of respect, to proceed would be a farce but it is not the allegations yet.