MR VISSER
Mr Chairman, you are, of course, quite correct, but you will remember that there was cross-examination by myself.  At that stage the Chairman pointed out to me that I cannot restrict it only to Fountain street, but I also had to include the possibility that reference could be made to Botshebelo which we accepted at the time.  It then later appeared, Mr Chairman, that when Mr Motsamai gave his evidence, and I can give you the references on the record, stated specifically that he did not apply for amnesty in regard to Botshebelo which brought us back to point one, square one, which was assaults on this group of 19 people at Fountain Street.
	I immediately concede that on the application on Annexure A it is not that specific.  What we are submitting to you, Mr Chairman, is it was always in the spirit of understanding that we are talking about incidents.  The one incident is the one that Mr Ngo refers to as the Botshebelo incident and the other as the Fountain Street, the Bloemfontein incident.  It certainly never encompassed any other assaults although they may have taken place, Mr Chairman, in the Fountain Street Building, but unrelated to this incident, because, as you have pointed out yourself, there is no general amnesty and the references on the record that Mr Stander refers you to is of no assistance to you at all, because all that was put is that Mr Molefe will say that he was assaulted on numerous occasions.  Well, fine, no problem with that, he can go and tell the Humans Rights Commission about that if he feels, as Mr, Judge Ngoepe has pointed, Justice Ngeope has pointed out to him, is his right.  
	We persist in the objection, Mr Chairman, we cannot 
just go on and have people implicated in, with, in regard to matters which are not before you.  What are before you?  Before you, for Mr Motsamai, are 14 groups or individual incidents and we submit, Mr Chairman, that the implicated persons have a right to see the Chairman say, Mr Stander, you are restricted to bring your application or your evidence within the confines of one of them.  If he chooses 13, that is fine, Mr Chairman, but then we will deal with that, because we have been prepared on that, we have been given notice about that and we will deal with that, but we cannot deal with incidents in 1993 or any other incident which does not fall within the purview of that incident.  That is my submission, with respect.