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Nicholls, Cambanis & Associates Attorneys At Law TRC AMNESTY COMMITTEE Suite 3919, 39th Floor Carlton Centre Johannesburg 2001 Telephone 331-6919 331-6910 PER FAX: (021) 24-5225 331-6920 / 7 / 8 / 9 ATTENTION: P.O.Box 8694 Johannesburg 2000 Fax: (011) 331-8691 Docex No. 631 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR Your Ref: Our Ref: Date: CRYSTAL CAMBANIS/hm 12 January 1999 Dear Sir, RE: BOIPATONG AMNESTY APPLICATIONS For your information we are furnishing you with the names of the victims represented by Advocate Danny Berger, Advocate P.G. Malindi and Ms C.H. Cambanis respectively. ADVOCATE D.l. BERGER 1. Sanah Motloung 2. Paul Makhetha Sebolai 3. Zachia Fuku Ramakarane 4. Isaac Phungula 5. Mary Dlamini 6. Joseph Mphumela 7. Margaret Moepa 8. Lydia Ntsala 9. Rebecca Motaung 10. Emily Mashinini 11. Diamond Zarr.ile Lata Caroline Heaton-Nicholls (BA. LLB.) Crystal Hariklia Cambanis (BA. LLB.)
46

2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Jul 22, 2020

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Page 1: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331 -692 0 7 8 9

ATTENTION POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631ADV PADDY PRIOR AND CHIEF LEGAL ADVISORYour Ref Our Ref Date

CRYSTAL CAMBANIShm 12 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

For your information we are furnishing you with the names of the victims represented by Advocate Danny Berger Advocate PG Malindi and Ms CH Cambanis respectively

ADVOCATE Dl BERGER

1 Sanah Motloung

2 Paul Makhetha Sebolai

3 Zachia Fuku Ramakarane

4 Isaac Phungula

5 Mary Dlamini

6 Joseph Mphumela

7 Margaret Moepa

8 Lydia Ntsala

9 Rebecca Motaung

10 Emily Mashinini

11 Diamond Zarrile Lata

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

12 Mirriam Monokwane

13 Maria Letsoko

14 Maria Dibakiso Hlubi

15 Albert Sibisi

16 Maria Mosoetsa

17 Mirriam Mosoetsa

18 Paulina Mlangeni

19 Maria Mokhotsoa

20 Matseleng Mirriam Molete

21 Elizabeth Malindi

22 Solomon Malindi

23 Franscinah Malindi

24 Elizabeth Hlubi

25 Saul Ngakane

26 Annah B Magadi

27 Annah Motsiri

28 Abraham Moiloe

29 Joseph Molotse

30 David Kubu

31 Rebecca Sefatsa

32 David Mokoena

33 Joana Mafrika

34 Puleng Motaung

35 M Mokoseng

36 S Cibinani

37 A Molefi

38 L Seroe

39 MP Mboyani

40 TC Nnete

41 Victor Ncwana

42 Dorothy Kobo

43 Nondsi Buwa

44 Family of Dinah Moeti

45 J Mathi

46 Elda Madayi

47 Lydia Manaki Malindi

ADVOCATE PG M ALIN PI

1 John Buwa

2 Alinah Mbatha

3 Meshack Hlubi

4 Elsie Buwa

5 Phillip Msibi

6 Johannes Hlubi

bull -

_4_

7 Ernest Sotsu

8 Lydia Genu

9 Selina Sefumo

10 Leah Motsoaledi

11 Linda Phungula

12 Lusanda Phungula

13 Wilson Keke

14 Samuel Latha

15 Evelyn Ramoeletsi

16 Abel Siyane

17 Elizabeth Ndaba

18 Agrineth Sibisi

19 Themba Benjamin Msibi

20 Dorcas Masha

21 Selinah Motsitsi

22 Ratetle Raketse

23 Martha Monaheng

24 Lydia Masediti

25 J Mohapi

26 S Mokoena

27 M Mamatela

28 R Britz

29 A Maleko

30 N Nyokong

31 M Motaung

32 K Newenya

33 Alinah Ntombazana Mthimkulu

34 Alfred Msibi

35 David Mbhele

36 Salaminah Moroe

37 Richard Jabulane Msibi

38 Mita Molete

39 Family of Richard Jim Nzimeni

40 Family of Modiehi Elizabeth Moloi

41 Family of Toli Samuel Ncokoto

42 Family of Madidjane Koza

43 Family of DA Sebolai

CH CAMBANIS

1 Betty Lerobane

2 Anna Mbatha

3 Koos Mokoena

4 Tina Nyane

5 J Pheku

6 Emma Bohloko

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

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S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 2: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

- 2 -

12 Mirriam Monokwane

13 Maria Letsoko

14 Maria Dibakiso Hlubi

15 Albert Sibisi

16 Maria Mosoetsa

17 Mirriam Mosoetsa

18 Paulina Mlangeni

19 Maria Mokhotsoa

20 Matseleng Mirriam Molete

21 Elizabeth Malindi

22 Solomon Malindi

23 Franscinah Malindi

24 Elizabeth Hlubi

25 Saul Ngakane

26 Annah B Magadi

27 Annah Motsiri

28 Abraham Moiloe

29 Joseph Molotse

30 David Kubu

31 Rebecca Sefatsa

32 David Mokoena

33 Joana Mafrika

34 Puleng Motaung

35 M Mokoseng

36 S Cibinani

37 A Molefi

38 L Seroe

39 MP Mboyani

40 TC Nnete

41 Victor Ncwana

42 Dorothy Kobo

43 Nondsi Buwa

44 Family of Dinah Moeti

45 J Mathi

46 Elda Madayi

47 Lydia Manaki Malindi

ADVOCATE PG M ALIN PI

1 John Buwa

2 Alinah Mbatha

3 Meshack Hlubi

4 Elsie Buwa

5 Phillip Msibi

6 Johannes Hlubi

bull -

_4_

7 Ernest Sotsu

8 Lydia Genu

9 Selina Sefumo

10 Leah Motsoaledi

11 Linda Phungula

12 Lusanda Phungula

13 Wilson Keke

14 Samuel Latha

15 Evelyn Ramoeletsi

16 Abel Siyane

17 Elizabeth Ndaba

18 Agrineth Sibisi

19 Themba Benjamin Msibi

20 Dorcas Masha

21 Selinah Motsitsi

22 Ratetle Raketse

23 Martha Monaheng

24 Lydia Masediti

25 J Mohapi

26 S Mokoena

27 M Mamatela

28 R Britz

29 A Maleko

30 N Nyokong

31 M Motaung

32 K Newenya

33 Alinah Ntombazana Mthimkulu

34 Alfred Msibi

35 David Mbhele

36 Salaminah Moroe

37 Richard Jabulane Msibi

38 Mita Molete

39 Family of Richard Jim Nzimeni

40 Family of Modiehi Elizabeth Moloi

41 Family of Toli Samuel Ncokoto

42 Family of Madidjane Koza

43 Family of DA Sebolai

CH CAMBANIS

1 Betty Lerobane

2 Anna Mbatha

3 Koos Mokoena

4 Tina Nyane

5 J Pheku

6 Emma Bohloko

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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BOIFATONC AMNESTY API [CATIONS

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bull Administration of the IFPB p f Per fax (031) 307 4964

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

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Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

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degor may still have rageiding the m S a r 9 regnttd to ar) Information that

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SOUTH AFRICAN POLICE SERVICE

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QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

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C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 3: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

34 Puleng Motaung

35 M Mokoseng

36 S Cibinani

37 A Molefi

38 L Seroe

39 MP Mboyani

40 TC Nnete

41 Victor Ncwana

42 Dorothy Kobo

43 Nondsi Buwa

44 Family of Dinah Moeti

45 J Mathi

46 Elda Madayi

47 Lydia Manaki Malindi

ADVOCATE PG M ALIN PI

1 John Buwa

2 Alinah Mbatha

3 Meshack Hlubi

4 Elsie Buwa

5 Phillip Msibi

6 Johannes Hlubi

bull -

_4_

7 Ernest Sotsu

8 Lydia Genu

9 Selina Sefumo

10 Leah Motsoaledi

11 Linda Phungula

12 Lusanda Phungula

13 Wilson Keke

14 Samuel Latha

15 Evelyn Ramoeletsi

16 Abel Siyane

17 Elizabeth Ndaba

18 Agrineth Sibisi

19 Themba Benjamin Msibi

20 Dorcas Masha

21 Selinah Motsitsi

22 Ratetle Raketse

23 Martha Monaheng

24 Lydia Masediti

25 J Mohapi

26 S Mokoena

27 M Mamatela

28 R Britz

29 A Maleko

30 N Nyokong

31 M Motaung

32 K Newenya

33 Alinah Ntombazana Mthimkulu

34 Alfred Msibi

35 David Mbhele

36 Salaminah Moroe

37 Richard Jabulane Msibi

38 Mita Molete

39 Family of Richard Jim Nzimeni

40 Family of Modiehi Elizabeth Moloi

41 Family of Toli Samuel Ncokoto

42 Family of Madidjane Koza

43 Family of DA Sebolai

CH CAMBANIS

1 Betty Lerobane

2 Anna Mbatha

3 Koos Mokoena

4 Tina Nyane

5 J Pheku

6 Emma Bohloko

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

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Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

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AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

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C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 4: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

bull -

_4_

7 Ernest Sotsu

8 Lydia Genu

9 Selina Sefumo

10 Leah Motsoaledi

11 Linda Phungula

12 Lusanda Phungula

13 Wilson Keke

14 Samuel Latha

15 Evelyn Ramoeletsi

16 Abel Siyane

17 Elizabeth Ndaba

18 Agrineth Sibisi

19 Themba Benjamin Msibi

20 Dorcas Masha

21 Selinah Motsitsi

22 Ratetle Raketse

23 Martha Monaheng

24 Lydia Masediti

25 J Mohapi

26 S Mokoena

27 M Mamatela

28 R Britz

29 A Maleko

30 N Nyokong

31 M Motaung

32 K Newenya

33 Alinah Ntombazana Mthimkulu

34 Alfred Msibi

35 David Mbhele

36 Salaminah Moroe

37 Richard Jabulane Msibi

38 Mita Molete

39 Family of Richard Jim Nzimeni

40 Family of Modiehi Elizabeth Moloi

41 Family of Toli Samuel Ncokoto

42 Family of Madidjane Koza

43 Family of DA Sebolai

CH CAMBANIS

1 Betty Lerobane

2 Anna Mbatha

3 Koos Mokoena

4 Tina Nyane

5 J Pheku

6 Emma Bohloko

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

gt06 Adderiay Struct C ilaquoTow r 6001 TV (02 I) 2 5 t i l Px(C2f) 233 2BC 2laquo5 225

SraquorVlaquoni c n trraquo iCth Rr CnrVbil W lt l l |h A Jeppraquo S tr Johannesburg 2 0 0 f TV (0 i I ) 333 6 320 Pa(0 I ) 133 0 8 3 2 6 3 I

M ftli ftuilelirti 9 iflth F le o i 31 Smith D u rb an 4 6 0 0 TliltOJ igt 307 laquo 7 7 f k lt53 ) 307 $74 2 9

N2S Building Stfi Haen ISTarmnui Strut Per Lon^sn 5iOQTi(0-t-31) 43 2ampS5 FiX(04 jigt j

S-rraI mjoyireggolgtacotraquo internet TCtpsZwvvwcrutnorgi

2J QPPOM 57CtT T22 CM) IClQT fcpound6IklHrgtT

Z d Wd frZ80 ST N laquo f lsquo 666T I 6 98 11pound ON XBd sstj a ua o h o i n u o s j

Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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BOIFATONC AMNESTY API [CATIONS

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 5: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30 N Nyokong

31 M Motaung

32 K Newenya

33 Alinah Ntombazana Mthimkulu

34 Alfred Msibi

35 David Mbhele

36 Salaminah Moroe

37 Richard Jabulane Msibi

38 Mita Molete

39 Family of Richard Jim Nzimeni

40 Family of Modiehi Elizabeth Moloi

41 Family of Toli Samuel Ncokoto

42 Family of Madidjane Koza

43 Family of DA Sebolai

CH CAMBANIS

1 Betty Lerobane

2 Anna Mbatha

3 Koos Mokoena

4 Tina Nyane

5 J Pheku

6 Emma Bohloko

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

gt06 Adderiay Struct C ilaquoTow r 6001 TV (02 I) 2 5 t i l Px(C2f) 233 2BC 2laquo5 225

SraquorVlaquoni c n trraquo iCth Rr CnrVbil W lt l l |h A Jeppraquo S tr Johannesburg 2 0 0 f TV (0 i I ) 333 6 320 Pa(0 I ) 133 0 8 3 2 6 3 I

M ftli ftuilelirti 9 iflth F le o i 31 Smith D u rb an 4 6 0 0 TliltOJ igt 307 laquo 7 7 f k lt53 ) 307 $74 2 9

N2S Building Stfi Haen ISTarmnui Strut Per Lon^sn 5iOQTi(0-t-31) 43 2ampS5 FiX(04 jigt j

S-rraI mjoyireggolgtacotraquo internet TCtpsZwvvwcrutnorgi

2J QPPOM 57CtT T22 CM) IClQT fcpound6IklHrgtT

Z d Wd frZ80 ST N laquo f lsquo 666T I 6 98 11pound ON XBd sstj a ua o h o i n u o s j

Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Wd 6 1 s Z I ST M b f lsquo66 6 1 I 69 8 1poundpound CH X b d SSb 9 U b D H 3 I H woa a

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

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AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

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GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

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degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

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Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

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Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

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1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 6: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

V- 6 -

7 Princess Pumla Marangxa

8 Florence Molete

9 Dinah Manyika

10 Patrick S Nonjoli

11 Jeremiah Mokoena

12 Samuel Mashope

13 Jane Biliso Charlie

14 Paulinah Mbatha

15 Wilson Mashigile Baloyi

16 Klaas Mathope

17 Victoria Mbongo

18 Edwin M Mokhotsoa

19 Esther Malindi

20 Jane Mbongo

21 Albert Nonyana

22 Matlhodi Moremi

23 Mirriam Magau

24 Evelyn Khunou

25 Meshack Jabulani Ramokonopi

26 Elizabeth Nosenga

27 Alicia Monokoane

28 George Manokoane

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Wd 6 1 s Z I ST M b f lsquo66 6 1 I 69 8 1poundpound CH X b d SSb 9 U b D H 3 I H woa a

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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Fax ( 0 3 l ) 3 0 7 m 4 c-m ail ifpiafoiaiifp orcza

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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AB0044Cryitfcl Cambau

AKev

a ASSOCIATES10LLS CAMbANI (ttyi at Law I |j (OU) 331-8691 INNESBURG

BOIFATONC AMNESTY API [CATIONS

Few Pad 7551iithfullyKLUTH

From C-Ctxigt

Co N Hs-j

Phono no -g i lt5 1 ^ Fax No -laquo- I S ^ l

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amptv

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| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

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Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

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L E G A L A I D B O A R D

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

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Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 7: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

29 Priscilla Ranyuza

30 Radebe Leeuw

31 Sana Xaba

32 Joseph Mgqina

33 S Lata

34 E Motaung

35 DE Daba

36 CD Nelubeni

37 J Bhikitsha

38 M Mokoena

39 B Zulu

40 B Keke

41 Family of Nomvula Jemina Lata

43 Family of Francinah Ndimande

44 Family of Matsheliso Flora Msomi

45 Family of Mantsali Paulina Dhlamini

46 Family of Memi Martha Nonjoli

We trust that you find the above in order

Yours faithfully

pf

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

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S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

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Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

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AMNESTY COMMITTEE

Ca TownMOO

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

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GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

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Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

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3421 (457) Supt (F) Ahrens

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Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 8: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

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Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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BOIFATONC AMNESTY API [CATIONS

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

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degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

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3421 (457) Supt (F) Ahrens

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Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 9: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

TRCAMNESTY COMMITTEE Suite 3919 39th Floor

Carlton Centre Johannesburg 2001

Telephone331-6919331-6910

PER FAX (021) 24-5225 331-6920 7 8 9

ATTENTIONADV PADDY PRIOR AND CHIEF LEGAL ADVISOR

JohannesburgPOBox 8694

2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIShm 13 January 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 18 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

As a result of the responses by the Applicants and the South African National Defence Force to the memorandum submitted on behalf of the victims it has become necessary to call the persons listed hereunder to give evidence on behalf of the victims

1 Joseph Mphomelo

2 Esther Malindi

3 Diamond Lata

4 Meshack Jabulani Ramokonopi

5 John Buwa

6 Johannes Rahantlhane

7 Meshack Thoane

8 Fiorina Dlamini

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

gt06 Adderiay Struct C ilaquoTow r 6001 TV (02 I) 2 5 t i l Px(C2f) 233 2BC 2laquo5 225

SraquorVlaquoni c n trraquo iCth Rr CnrVbil W lt l l |h A Jeppraquo S tr Johannesburg 2 0 0 f TV (0 i I ) 333 6 320 Pa(0 I ) 133 0 8 3 2 6 3 I

M ftli ftuilelirti 9 iflth F le o i 31 Smith D u rb an 4 6 0 0 TliltOJ igt 307 laquo 7 7 f k lt53 ) 307 $74 2 9

N2S Building Stfi Haen ISTarmnui Strut Per Lon^sn 5iOQTi(0-t-31) 43 2ampS5 FiX(04 jigt j

S-rraI mjoyireggolgtacotraquo internet TCtpsZwvvwcrutnorgi

2J QPPOM 57CtT T22 CM) IClQT fcpound6IklHrgtT

Z d Wd frZ80 ST N laquo f lsquo 666T I 6 98 11pound ON XBd sstj a ua o h o i n u o s j

Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Wd 6 1 s Z I ST M b f lsquo66 6 1 I 69 8 1poundpound CH X b d SSb 9 U b D H 3 I H woa a

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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Dept Phone No6 ^

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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I Co C o r ^ ic C o ^ ^

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- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 10: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

diams

9 Mrs Mokoena (Jeremias Mother)

10 Eliza Mosoetsa

11 Paul Sebolai

12 Emily Mashinini

13 Johannes Mbatha

14 Mr Wilson Baloyi

15 Mr Klaas Mathope

16 Mr Simon Moloi

17 Rebecca Motaung

18 Mirriam Molete

copy gt Florence Molete | tv lt - to id

20 Anna Mbatha

21 Hilda Monokoane

22 Diana Manyika

23 Maria Mashope

24 Jemima Mazibuko

tOvj_

Yours faithfully

CRYSTALMCAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

cc3

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Wd 6 1 s Z I ST M b f lsquo66 6 1 I 69 8 1poundpound CH X b d SSb 9 U b D H 3 I H woa a

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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T Q c m b u k N k a t h a Y c n k u lu lc k o

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Fax ( 0 3 l ) 3 0 7 m 4 c-m ail ifpiafoiaiifp orcza

Intvrael w v w ifp o rg

[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

Z d Wb 9 Z i 60 Z Z 9 3 d lsquo 6 S 6 I I 6 9 8 1 2 I ON Xbd SSb 9WbO H31N WOSd

CLUTH j S amp CONVEYANCERS j IRS amp TRANSPORTBESORGERS

I l IN A 88O 8IA S IB M E T

SOUTHERN HOUS1VGEBOU Gib P oor64e Vlow 2221 rraquotoriuraquo SlrSt222 Co lv IUnk LneUlaquon PRETORIA

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a ASSOCIATES10LLS CAMbANI (ttyi at Law I |j (OU) 331-8691 INNESBURG

BOIFATONC AMNESTY API [CATIONS

Few Pad 7551iithfullyKLUTH

From C-Ctxigt

Co N Hs-j

Phono no -g i lt5 1 ^ Fax No -laquo- I S ^ l

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| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

-6QZ rsquo99 1 42

Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

wm

Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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Page 11: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

JH van der Merwe Ref Mr H Friedrich Per Fax (011) 336-0116

Armin KluthRef Armin KluthPer Fax (012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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N2S Building Stfi Haen ISTarmnui Strut Per Lon^sn 5iOQTi(0-t-31) 43 2ampS5 FiX(04 jigt j

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

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Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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CLUTH j S amp CONVEYANCERS j IRS amp TRANSPORTBESORGERS

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bull Administration of the IFPB p f Per fax (031) 307 4964

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

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Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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J L S T IT L C ^ b M N E SA D

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Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

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A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 12: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson of the Amnesty Committee

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

Telephone331-6919331-6910TRC

331-6920 7 8 9

PER FAX (021) 24-5225POBox 8694 Johannesburg 2000

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref Date

1 3 January 1999CRYSTAL CAMBANIShm

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONSDATE OF HEARING 1 8 - 2 9 JANUARY 1999

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to the findings of the TRC in respect of the Boipatong Massacre TRC Report Volume 3 Chapter 6 page 689 - 690

In terms of Section 5(f) of the promotion of National Unity and Reconciliation Act 34 of 1 995 we call upon you to direct that the information upon which the said findings is based be made available to the Committee dealing w ith the Boipatong Amnesty Applications The Committee is chaired by Judge S Ngcobo

We would appreciate it if a copy of the said information could be made available to us as well

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

cc Judge NgcoboPer fax (021) 22-2221

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

gt06 Adderiay Struct C ilaquoTow r 6001 TV (02 I) 2 5 t i l Px(C2f) 233 2BC 2laquo5 225

SraquorVlaquoni c n trraquo iCth Rr CnrVbil W lt l l |h A Jeppraquo S tr Johannesburg 2 0 0 f TV (0 i I ) 333 6 320 Pa(0 I ) 133 0 8 3 2 6 3 I

M ftli ftuilelirti 9 iflth F le o i 31 Smith D u rb an 4 6 0 0 TliltOJ igt 307 laquo 7 7 f k lt53 ) 307 $74 2 9

N2S Building Stfi Haen ISTarmnui Strut Per Lon^sn 5iOQTi(0-t-31) 43 2ampS5 FiX(04 jigt j

S-rraI mjoyireggolgtacotraquo internet TCtpsZwvvwcrutnorgi

2J QPPOM 57CtT T22 CM) IClQT fcpound6IklHrgtT

Z d Wd frZ80 ST N laquo f lsquo 666T I 6 98 11pound ON XBd sstj a ua o h o i n u o s j

Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Wd 6 1 s Z I ST M b f lsquo66 6 1 I 69 8 1poundpound CH X b d SSb 9 U b D H 3 I H woa a

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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Dept Phone No6 ^

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

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GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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wafted costa incurred amp ^ maogementa to

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30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 13: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

recon c il ia tion0

1 o i m ioo raquoraquomifttls

Legal Department F O Box 3103

Cape Town 8000 Fax +27 21 34 8235 Ml 137 31 24 5307

V raquo W rat I CXYSTAL CAMBANU Vjn

14 Jan u ary 1999

Nicnolls Cajtibanis 8t Associatereg P 0 Bax 8694J o h a n n e s b u r g2000

Dear Ms Cambanis

M i B P tf ATCma AMNBaTV a p p l ic a t m k

Your letter dated 13 January 1999 refere The content are noted

I ldquo bdquo ^ 5 CdegUrSe ntitl d to lead ehows that thet e N n laquo m tcompHed with provisions of Section 20 ol the

S u l u e V a t ^ r trade rsquo 1 ^ adViM ^ t0 be deg f

S u n a w iU H ^ ^ w Ha7 t0j bC sati5ed thftt thc witnessea you intendftVld CC tod 10 end you bull j e s t e d to

PPy our copies Of the witness statementsldquo Cly mmane8 deg f 141(5 material aspects Of each witness

Theraquoe statements and summaries must also be supplied to the applicants attorneys as well as all other interested parties before Monday 18 January 1999

PADDY PRIOR NATIONAL LEGAL OFFICER

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Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

Z d Wb 9 Z i 60 Z Z 9 3 d lsquo 6 S 6 I I 6 9 8 1 2 I ON Xbd SSb 9WbO H31N WOSd

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I l IN A 88O 8IA S IB M E T

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BOIFATONC AMNESTY API [CATIONS

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bull Administration of the IFPB p f Per fax (031) 307 4964

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 14: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys A t Law

Truth and Reconciliation Commission suite 3 919 39th Floor ldquo Carlton CsnueCape Town Johannesburo

2001

Per Fax (021) 24 5225 POBox B 694 Johannaaburg2000

a t t e n t io n a d v o c a t e p a d d y PRIOR

Your Ref Our Ref

C RYSTAL CAMBANlStn

Telephone 3 3 1 -6 9 1 9 331 -6 9 1 0

3 3 1 -6 9 2 0 1 7 U 9

Fax (011 ) 3 3 1 -8 6 9 1

Does No 631

D a te

15 January 1999

Dear Paddy

RE R O IPA TO N G AMNESTY APPLICATIONS

Than you fcr your lette of 14 January 1999

W e are well aware of the specific issues at stake and have deiiberately seleded only those witnesses who are in a position to give evidence on those material aspects o victims memorandum which have been denied by the Applicants

Yours faithfully

^Lmdash r

CRYSTAL CAMBANISNICHO LLS CAMBAMS A N D ASSOCJATES

cc J H van der M rws Ref Mr H Friedrich Per Fax (011) 336 0116

cc Armin KluthRef Armin KlulhPer Fax (012) 323 5656

Carotins H u ton -N icho lls (BA LLB) Crystal Hariklia Cam ban is (B A K B

Wd 8pound Z 1 S t M B f lsquo 6 6 6 T 6 9 8 1 E 2 ON Xd d SSB 8Ut)3 N 3 I N WOHJ

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

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Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

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THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

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1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 15: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

The Chairperson Of the Suita 3 9 19 39th Floor TelephoneAmnesty Committee Carlton Cnntra 3 3 1 -6 9 1 9

Johannesburg 3 3 1 -6 9 1 02001 3 3 1 -6 9 2 0 7 8 9Per Tax (012) 24 5225POBox 8694 F a x (0 1 1 )3 3 1 -8 6 9 1Johannesburg2000 Dooex No 631

Your Rdf Our Ruf Oulu

CRYSTAL CAMBANlStn 15 January 1999

Dear SirMadam

RE BOIPATONG AMNESTY APPLICATIONS

Further to our letter dated 13 January 1998 we have reason to believe that Mr Gerhadus (Pedro) Peens and Mr Arthur John van der Gryp have given evidence in terms of Section 29 of the Act to the TRC

We have further reason to believe that certain aspects of their evidence are material In the Boipatong Amnesty Applications

In terms of Section 5(f) of the Act we call upon you to direct that the evidence referred to above be made available to Judge Ncobo and his committee

We wouid also appreciate it if a copy of the evidence could be made available to us

Yours faithfully

C ^ $ T A L CAM BANKS NICHOLLS CAM BAMS AND ASSOCIATES

ccPer Fax

Judge Ncobo (021 ) 22 2221

Carolina N ltaton-Nitshol(o (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

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P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

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February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

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Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

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For tnraquo attention of Pax No Tal No

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 16: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Armin KluthAttorneys amp Conveyancers

(012) 323-5658

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg 2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We refer to exhibits numbers L1 to L12 and to the version put by your counsel Advocate Da Silva

Please could you furnish us w ith the documentation containing the following information-

1 The registration number of the military vehicles involved

2 The times when they were deployed and the times when they were returned

3 The names of all military personnel who were in the military vehicles at the time

To this end we require sight of the appropriate vehicle(regisfrCtion number^ and if appropriate occurrence books arms and ammunition registers and any related documentation relevant to the nights of 1718 June 1992 We further request copies of such documentation and tender reasonable costs of photostating same

Please acknowledge receipt

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nichoils (BA LLB) Crystal Hariklia Cambanis (BA LLB)

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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I Co C o r ^ ic C o ^ ^

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- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

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FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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wafted costa incurred amp ^ maogementa to

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^ ^ eHoua - this to A Malindi

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 17: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

The Commissioner of Police Mr George Fivas

Per Fax (012) 339-1530

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

We have been informed that Sergeant Pedro Peens formally of Vanderbijlpark Murder and Robbery Unit has admitted to Mr Riaan Malan that he was present with other policemen in a police caspir in Boipatong during the night of 1718 June 1992

Please could you furnish us w ith the documentation containing the following information-

1 The registration of the caspir the time when it was booked out and the time when it was returned

2 The names of policemen who were together w ith Sergeant Peens in the caspir

3 The reasons for Sergeant Peens being in Boipatong

4 The nature of the work done by him and the other officers w ith him

To this end we require sight of the appropriate vehicle registers occurrence books arms and ammunition registers exhibits registers and pocket books relevant to the nights of 1718 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

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P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

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February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

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Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

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SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

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bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

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STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

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L E G A L A I D B O A R D

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

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1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 18: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

- 2 -

If you believe it is appropriate we are prepared to meet either w ith you or your delegate at any time and venue convenient to you

Please acknowledge receipt

Yours faithfully

NICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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BOIFATONC AMNESTY API [CATIONS

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Phono no -g i lt5 1 ^ Fax No -laquo- I S ^ l

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amptv

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| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

-6QZ rsquo99 1 42

Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

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HWti

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

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L E G A L A I D B O A R D

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

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2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 19: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

Chief Executive Officer Dr Martin Van Wijngaarden Iscor

Per fax (016) 440-3142

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg2000

Telephone 331-6919 331-6910

331-6920 7 8 9

Fax (011) 331-8691

Docex No 631

Your Ref Our Ref

CRYSTAL CAMBANIShm

Date

8 February 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

During the evidence at the hearing it has emerged that Kwa-Madala Hostel was sealed within hours of the attack on Boipatong Please could you confirm precisely when the hostel was sealed by whom it was sealed and why there was a delay in doing so

It has also emerged during the hearing that subsequent to the sealing off of the Hostel strict controls were put in place by Iscor to monitor those entering and leaving the hostel

According to Mr Moses Mthembu Iscor has records of those people who entered and left the hostel subsequent to it being sealed off

Please can we have copies of those records for the period 18 June 1992 to 31 October 1992

In respect of the period prior to the massacre Mr Moses Mthembu has stated that Iscor kept records of all hostel residents including those refugees who were not employed by Iscor Please could you let us have a copy of those records for the period 1 January 1992 to 18 June 1992

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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Dept Phone No6 ^

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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For tnraquo attention of Pax No Tal No

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DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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I Co C o r ^ ic C o ^ ^

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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hi (MJJUC [Mi) HI MM

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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wafted costa incurred amp ^ maogementa to

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 20: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

- 2 -

It is common cause that Prince Vanana Zulu was employed by Iscor as at 17 June 1992 It is also common cause that he was a resident at Kwa-Madala Hostel at the time Please would you let us have copies of all documents relating to the period during which Prince Zulu was on leave during 1992 Such documents should include applications for leave approval thereof and appropriate wage register documents

We tender the reasonable costs of photocopying copies of the abovementioned documentation

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

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Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

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SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

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L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

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Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

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bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 21: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttorneys At Law

Iscor Legal Services Suite 3919 39th Floor Carlton Centre Johannesburg

Telephone331-6919331-6910Per Fax (012) 307 4931

2001 331-6920 7 8 9

Attention Mr Francois StrydomPOBox 8694 Johannesburg

Fax (011) 331-8691

2000 Docex No 631

Your Ref Our Ref Date

CRYSTAL CAMBANIStn 26 April 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS

We refer to your fax dated 23 April 1999

We apologise for the incorrect date given in our letter on 22 April 1999 It was a draft letter and we did not change the date

Kindly let us have the requested information by Thursday 28th of April 1999 The requested information is obviously relevant to us as we act on behalf of the victims of the Boipatong massacre

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

Caroline Heaton-Nicholls (BA LLB) Crystal Hariklia Cambanis (BA LLB)

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

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[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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BOIFATONC AMNESTY API [CATIONS

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Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 22: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

17IW I999 0913 032 -3074QS4 INKATHA FREEDOMPARTV PAGE 01

4tfc Floor Albany How Narth Albany Grave DLHBAN 4001

P O Box 4432 Dorbaa 400 Ttl (031) 3074941 rlaquoK (031)3074K4

bull-mail lfptaflfportaIraquotrat wwwifjporg h

February 16 1999

Nicbolls Cambanis amp Awociatet P O Box 8694 JOHANNESBURG2000

^ Per Facsimile No 1011) 331 8691

Dear Sir

BOIP ATONG AMNESTY APPLICATION

Y our reference is C RYSTAL CAMBAKIShm

Further to my lettisr of 16 Flaquottotraquouy 1999 I regret to inform you that we cannot trace any record inddampt a llied by Mr Nosenga We have gone through all the a idio tape caamptettefi and minutes of the 1992 General Conference and co uld not find anything of Mr Nosenga

^ Thank you

Yours faithfully

M AtOL SECRETARY OF ADMINISTRATION

Present TN Hon Mne Morgowlhu S Sutholen Notorial Chairman fir 09 Nflutoon

r-r v fWH pound 6 0 21 9 3 d lsquo 6 66 T 1 6 9 8 1 E ON Xbd SSH 8Wlaquo0 H 3 I N UOMd

D e m o c r a c y m e a n s f r e e d o m to choose

INKATHAI n k a t h a J r r c c t io m Jrsquoj r t y

T Q c m b u k N k a t h a Y c n k u lu lc k o

4(b F loor A lbauy II an te N orth A lb an y C rave D IR R A N 4001

P O Bon 4432 D urban 4 M 0 Tt) (0J1) 307-1962

Fax ( 0 3 l ) 3 0 7 m 4 c-m ail ifpiafoiaiifp orcza

Intvrael w v w ifp o rg

[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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CLUTH j S amp CONVEYANCERS j IRS amp TRANSPORTBESORGERS

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BOIFATONC AMNESTY API [CATIONS

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From C-Ctxigt

Co N Hs-j

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| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

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Dept Phone No6 ^

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

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Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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From f g V r ^

I Co C o r ^ ic C o ^ ^

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- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

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Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

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1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

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laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

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wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

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30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 23: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

D e m o c r a c y m e a n s f r e e d o m to choose

INKATHAI n k a t h a J r r c c t io m Jrsquoj r t y

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P O Bon 4432 D urban 4 M 0 Tt) (0J1) 307-1962

Fax ( 0 3 l ) 3 0 7 m 4 c-m ail ifpiafoiaiifp orcza

Intvrael w v w ifp o rg

[ M m m E S F

m -02- 2 216 February 1999

Nicholls Cambaaii and Associates P O Box 8694 JOHANNESBURG2000

Per Facsimile No ( 0 1 1 ) 331 8601

Dear Sir

B O IP A T O N G A M N ESTY A P P L IC A T IO N

1 write to acknovledge receipt o f your letter Reference CRYS1AL C AMR ANT Shm ltiated 10 February 1999 regarding the above subject

I was personally present at the conference referred to in your letter and cannot recollect anything anywhere near what Mr Nosenga describes occuring there I am however trying to see if we have any record of this happening in oitr jecords although most of our records are disposed of after a period of five (5) years

Yours faithfully

KHUMALOGENERAL SECRETARY OF ADMINISTRATION

President T ie Hon Prince Mangosuthu G Buthelezi Nulionul ClKJiiiiKJH Oi QS NyubuiiH

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CLUTH j S amp CONVEYANCERS j IRS amp TRANSPORTBESORGERS

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BOIFATONC AMNESTY API [CATIONS

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From C-Ctxigt

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bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

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Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

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Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

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Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

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30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

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Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

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pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 24: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

CLUTH j S amp CONVEYANCERS j IRS amp TRANSPORTBESORGERS

I l IN A 88O 8IA S IB M E T

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BOIFATONC AMNESTY API [CATIONS

Few Pad 7551iithfullyKLUTH

From C-Ctxigt

Co N Hs-j

Phono no -g i lt5 1 ^ Fax No -laquo- I S ^ l

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amptv

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| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

-6QZ rsquo99 1 42

Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

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Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 25: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

amptv

t

| g NZ KhumaloSecretary for General

bull Administration of the IFPB p f Per fax (031) 307 4964

-

Your Ref

Nicholls Cambanis amp AssociatesAttorneys At Law

Suite 3919 39th Floor Carlton Centre Johannesburg2001

POBox 8694 Johannesburg 2000

Our Ref

CRYSTAL CAMBANIShm

Telephone 331-6919 331-6910

3 3 1 -6 9 2 0 7 8 9

Fax (011) 331-8691

Docex No 631

Date

10 February 1999

Dear Sirbull bull

RE BOIPATONG AMNESTY APPLICATIONS

I act on behalf of certain victims of the Boipatong Massacre Advocate Dl Berger and Advocate PG Malindi act for the remaining victims This letter is being sent to you on my own behalf and on behalf of Advocate Berger and Advocate Malindi

Certain of your members during their evidence in support of amnesty have stated that Mr Andries Matanzima Nosenga was taken from Kwa-Madala Hostel to Ulundi during July 1992 for the purposes of presenting him to the leadership of the IFP during the IFPrsquos national conference

v It has been further stated that Mr Nosenga was indeed paraded before the leadership of the IFP at the conference on the grounds that he had allegedly stated that he had been sent by the ANC to reconnoitre Kwa-Madala Hostel for the purpose of planting bombs at the Hostel

r bull -- - - cyWe are attempting to verify these allegations and would appreciate receiving any information you might have in this regard including minutes of the conference press releases video and audio recordings

I rgt -d bull lsquolt1rsquolt bull i-

We tender the reasonable costs of copying the abovementioned materialr------ mdash --------------- - __________ _

r - s V mm

Kindly acknowledge receipt of this letteri n w r r - lsquo

Yours faithfully

CRYSTAL CAMBANIS NICHOLLS CAMBANIS AND ASSOCIATES

Krsquo3

P o st^ it^ Fax Pad 7551 Page of

0 fc-^Ul-VYCllo From ^Co |oO

Dept Phone No6 ^

FaxNo C o 3 0 3 0 1 PaxNof o ( 0

-6QZ rsquo99 1 42

Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

wm

Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

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r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 26: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

-6QZ rsquo99 1 42

Your Rof 0 0 ^ 1 a T ~ i-AMBANlS hm

reg 26 February 19W

AMNESTY COMMITTEE

Ca TownMOO

TRC COPE TUWN

Our Ref 1 VlAPOMA

Tl (02 ) 2 4 1161 flaquoX 10211 432 2221

Pfl 01

Nicholls Cambanis amp Associate PO Box 8694 johannersburg 2000

K p e r f a x (011)331-^691

Dear Madam

Re a m n e s t y HEARING BOIPATONG MASSACRE

Receipt o f your letter daiad the 22ldquoldquo instant is hereby acknowledged with

We are taking up the matter with the parties referred to in your letter under reply Wc at alw of the view that the information you have requested is cwentail in the quest for truth and thus relevant from the point of view of full disclosure

We will revert to you in due courts

Your faithfully

thanks

-

Z d Ud 8 pound 0 1 9 Z 9 3 J lsquo 6 6 6 1 SS b a w b d H 3 I N w o a d

wm

Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

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HWti

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

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Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 27: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

wm

Fax covering sheetTO

For tnraquo attention of Pax No Tal No

Pram

Our Fax No Our Tal No

DateRafaranca Number of pagea

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

lt011 331 3601 (011 311 MHO

GENERAL WORKS MANAGER

HUMAN RESOURCES

(01^680 2(01laquo 89 2600

1000-0223

M H ugt

H fllP ftT ftN ff A M M P arv a p p u c a t iq n s

Y6ur fax datad 11 February 1988 m which you requet certain information regarding the inm ata of and vlaltora to tna Kvylaquo4rtsectdala hostel befora and after the Boipatong massacra r of era

regvn th m bull thlaquo laquo laquo raquo m wer laquo f l raquo r d t h m e t i e r 0 0 1 raquo BdegPon0M ainer w th r o r

mlaquoraquolaquocrraquofromto Kindly m Prlaquoon H a S L T o 6ox also Indicate on what ground you regard vouralif t m uch a Mindly

degor may still have rageiding the m S a r 9 regnttd to ar) Information that

vour faithfully

F l i t P ro d u e tt

l d Utf tgtpound 80 Z 9 3 J 6 6 6 1 t 6 9 8 I poundpound ON XHd sslaquo awao ho i n wolaquoj

i

bdquo__

t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

lsquoImjuiriTalfcfc-i r ii

i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

P o n W Fax Pad 7551 Page 0lt 1

From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

5Fa No pound 3 - 1 i

j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

1 d Hd I 6 pound 0 93 a t)N lsquo 666 tnwn

IS 98 t poundpound OH Xbd

CpoundpoundT S66T-tfcW-9gs s a awtjo h d in woad

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

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MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

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2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

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E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

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Date

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30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

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2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

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J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

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30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 28: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

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t i bull SUIO-AFRIKAANSE POUSIEDIENS

SAP 21

SOUTH AFRICAN POLICE SERVICE

V v bull

QWogt Box PQ BOX 8458 PRETORIA OOOl

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i31 Hifwwnmef 1 F txnum btr

3421 (457) Supt (F) Ahrens

01$ S39-1575 Oli 219-1530

Wa VNicholls Cambanis and Associates

f e K ) Box 8694 JOHANNESBURGBK

c 2000

THE MANAGER NODAL POINT HEAD OFFICE PRETORIA

1999-03-26I ltbull

(ATT Crystal Cambanii)

P -V gtbull bullV - D w Ml Cambanis

bull

pound BOIPATONG AMNES TY APPLICATIONS

jf V bull

Your request waa forwa-ded to the Provincial Concussion Gauteng for the necessary attention

After tavesttaation it seen that the case docket that you have requested Is wHh the office of the Attorney General Specal Task Unit under wpovtilon of Mr Basil drsquoOliviera This task unit is

Im - -- mdash m4 tkik IWIIraampTtmf bull tsituated at the following addreas

KfieUeraad Building ^i^vifld Floor r rsquo i 503 Belvedere street

1 Arcadia Pretoria

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From f g V r ^

I Co C o r ^ ic C o ^ ^

DftptRhone No 3 5 ^

Fa No 5 j ------- - mdash ------

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j g i Tel (012) 421 0796

- You are welcome to contact their office for iluiher informationf c V i

STJPT (F) MANAGER NODAL POINT TRC S AHRENS

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IS 98 t poundpound OH Xbd

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23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

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Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

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L E G A L A I D B O A R D

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J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 29: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

23 PR1999 11 i l l IESBL N O 160 p l

Our ref 23aprFPI3re Tel no (012) 307 4028Vour ref CRYSTA _ CAMBANIS Fax no (012) 307 3147

1939-04-23

Nicholls Cambanin amp Associates JOHANNESBURG

BY FAX (011)331 8891

Dear Sir

BOIPATONG AMNESTY APPLICATIONS

The above matter end rrton specifically your fay to writer hereof dated 13 April 1999 only transmitted Is the writer on 22 April 1999 refer

Writer must note his strongest objection to the last paragraph of your facsimile under reference us the return date set for ourselves to ftjmish you with the information raquinid had already expired oy the time you transmitted said document through to us We also refer to lrcors response dated 23 February 1999 and note thut to date hereof you havo not attempted to comply with the request contained therein to the extent that you ware to Indicate on which grounds you regard yourself ee being entitled to any Information that Iscor may still have In this regard

Ptaaampa take note that as this incident oecunrad some seven years ago van few documents may utill be In existence Unfortunately due to your delay In responding to our ex dated 23 February 19R9 writer has to date not made any attempts In locating the information you require

You are therefore rsquested to contact writer hereof on 28 April 1899 failing which we will oonsider tills matter as having been dealt wtth In the event of you contacting writer an you ere invited to do above the necessary arrangements can be made and neaionable time limits can be set in order for lacor to attempt to comply with your request

in light of the abowe we hereby wish to record that all our nghts in this regard remain strictly reserved

Yours faithfully

p (B RTBVnnMSENIOR LEGAL CONSULTANT LEGAL SERVICES

In U M IM OPtla ItprtatttfaUFra Ora Mm

roiwPmmOOQUfuUkenwAMcTtf (DO) 337 SBC

hi (MJJUC [Mi) HI MM

tacar LMlt4b|iilaquoire2iMM

tyrtctnn

MJ llaquokf(Skokm Qiinnt) UUnVMOwMwILAlO0 CJ CTMtu

DrfiXturrnlaquoxilaquonlaquoKR)1filaquoQ

HWti

ttwVithfiZ d Wtl 0 pound s l l pound2 altJHlsquo666 l I 6 98 T pound pound ON Xt)d SSb 8 Ub 3 H3 IN WCad

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

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Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 30: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

bullngt v

2BRPR19yy ld-4Z Lcsn NO1B9 p l

Our ref IBaprfFPSJnYour ref CRYSTAL CAWBANI8NOMSA

Tal no (012) 307 4783 Fax no (012) 307 3147 ISlt O K

1969-04-28

Nfcholl Camhanilaquo A AssociateJOHANNESBURG

BY PAX (011) 331 A6$1

Dear Sir

BOfPATONG AMNESTV APPLICATIONS

Thank you for your fax of 26 April 1996 contents which have baan noted

As discussed with your assistant Momsa writer is not avaflabto to attend to thlc matter this week and oouJd anty arranfla for an official from our Vanderbijlpark Work to attend to obtaining answers to your questions on Friday 30 April 1696 We will attempt to revart to you with the informatlcn at our dtsposel (if any) on Ihe same date fsJJng which attempt will be made to communicate the answers to you on Monday 3 May 1996

From the above It la dear that we ana attempting to accommodate you a much as possible ghan the Hme constraints you have Imposed

We also wish to record that as already noted in previous correspondence to yourselves that It Is nov the policy of I scar Limited to retain documentation In perpetuity This Is especially the ease where infOrmetlon were freely shared wrth the South African Polloe Services during their Investigation end as such information pertaining to this incident should be freely evailabia from them As e result we can unfortunately not guarantee any measure of success In obtaining the Information you have requested

We trust that you find the abovementioned in order

m h u nlafrDptpM

PCI ltSC

llwtfic if Soot AltaM (111) JO) MM taMUIflJI

(bullajajMie

Yours faithfully

p STRyDOMSENIOR LEGAL CONSULTANT LEGAL SERVICES

KaarUiMcH

qM(b a i raquo Q laquom laquo)

KraquonWJUDhmT l l raquorC|hlaquolaquoMrCTfl-JJ5WuirttrDbrarHrlaquodwii4(ynimiBMfWMjlotdaiH

Wb 8 1 8 0 6 Z a d laquo lsquo S 6 6 I 1 6 9 8 11 pound ON Xd d SStt 8 U B 3 HO IN WOM d

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 31: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

L E G A L A I D B O A R D

R E G S H U L P R A A DJoub ftrt S tree t StraaS u n n y s ld ePretoria

J L S T IT L C ^ b M N E SA D

Our ref On verw

Your ref U verw Enquiries TeltNCMtje Tel

The Senior Legal Officer TRC Legal D epartm ent CAPE TOWN

Private BagPrivaatEak x l6 3 Pretoria 0001 Docex 202

Switchboard Skakelbord lOll) 481-2700 Put JFaks(012) 341-8747 Telegrams Tttlegraxnme Juvamen

26 April 1099

Dear Sir Sirs

ACCOUNTS OF CAMBANIS ADVOCATES BERGER AND MALINDI BOIFATONG CASE

The abovementioned subject refers

Please note th a t the aforesaid lawyers are complaining bitterly abou t either non-paym ent or delay in having their TRCrsquos accounts settled by the Legal Aid Board The approach adopted by the three is to account directly to the TRC in Cape Town largely because their accounts are never in accordance w ith the Statutory Tariff The TRC is supposed to grant special authorisation to the Legal Aid Board to deviate from the S tandard Tariff as well as forward their accounts to the Board for settlem ent These never happen and th e lawyers somehow are always apprised by your office th a t the necessary h a s been done

Please note th a t due to the afore sta ted om ission by your office it becom es practically impossible to pay your Lawyers when we do no t have their accounts in our files

F urther note th a t in fu ture TRC accounts and any au thorisation m u st be m arked for the attention of Ms Nettie Loretz ph (012) 481-2763 fax (012) 341-9522)

S MAILS pp DIRECTOR

ID rsquoBd EZ78CEEM00lt mdash IQ0J 66 739Z

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 32: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30041939 0957 27-21-222221 TRCAMNESTY PAGE

reconciliationCOMMiSSlOO

AMNESTY COMMITTEEP O Box 3162 Caps Town 8000

Tel (021) 424 5161 Fax 10211 422 2221

Our Ref NDcm

29 April 1999

Adv D Berger

Per telefax O i l - 3 3 3 8 4 2 3

Dear Sir M adam

re BOIPATONG MASSACRE HEARING (3 - 21 MAY 1999)

This serves as a rem inder th a t the above hearing wall resum e on the 3 ^ May 1999 and ru n until 21st May 1999 The venue is as before Iscor Recreational Hall Vanderbijlpark

Please take further notice th a t the police docket is available a t our Johannesburg Offices for perusal Should you wish to have a look a t it please arrange with our Mr Ja n Ake Kjelberg on 082 458 4 4 4 5

Yours faithfully

NATHI DLADLA EVIDENCE ANALYST

Committee Members Judge H Mall (chairperson) Judge A Wilson (viC9 obailtvrson) Judge $ Miller Judge Pllts AJudge D PotQtoter AJudge S Khampepo Adv L Gceoasia Adv C de Jampgor Adv J Mofste Adv F Bosman Adv B SegodAdv N $andiDr Tsotsi W Mglan

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 33: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

4conciliation

AMNESTY COMMITTEEp a raquolaquok jn i cplaquo Town ROOD

29 April 1999

Tlaquol (021) 424 511 Plaquot 1021)422 2221

Our Rlaquol NQcm

M s Crytfcl C^ttbAUiB

Par t e fk - 0 1 1 bull 3 3 1 8 6 9 1

Dear SirM adam

re BOIPATOHO MA8SACRE HEARING (3 - 21 MAY 199reg)

This serves as cl rem inder th a t the a b o v e hearing will resum e on the 3 ^ May 1999 and ra n until 21laquo May 1999 The venue is a s before Iscor Recreational Hell VanderbijlpRrk

Please take further notice th a t the police docket in available a t our Johannesburg Offices for perusal Should you wieh to have a look at it please arrange irith our Mr J a n Ake Kjelberg on 082 458 444S

Yours faithfully

NATHIulADLA EVIDENCE ANjLLYST

j P o s t - i t Pax Pad 7551 Paglaquo | of I i _ -

A c - l u J l j b r r t j r c r Fr00| N O W tltV f o q

Co- ------ mdash----------- ---------------

Co U tc -L W i c [Jt gt laquo

Pep I PhOito Nu lti IFa No ldquoJ i w- - 2 lsquoi Fa No ^ f

C om m its Mraquomb rr Jixtg w ife )fc fw rpM M l Jodge A iMton (vkraquo teirpraquorznrf ju c iy S W m r Judgm PtUmy AJuetgm 0 Potplaquofer AJutstpa S KhmrTltpo Adv L Qcsbtsh$ Adv C draquo Jag- J Mntatt Ad Bovntn At S SsoadiActv N Xutitii igt now w M aw

Wtgt tl set 6pound gt)db lsquo6661 I 6 9 8 I E S ON Xt tJ ssa awtjo h j i n uoad

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 34: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30flPR1999 1434 TRC 021 245225 NO120 Pl

Legal D epartm ent P O Box 3162 CAPE TOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B s f

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (0 1 1 )3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGSYOUR S FEES

Kindly find attached hereto copies of our letters to Advocate PG Malindi and Nicholls amp Cambanis regarding the above m atter for your reference

PADDY PRIOR NATIONAL LEGAL O FFICER

E-m ail m io y i g o b a ic c 2a Im e rre fc h ttp w w w tru th o ^ g z a

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 35: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Legal Department PO Box 3162 CAPE TOWN 8000Fax +27 21 245225 Ph + 27 2124 5207

30th April 1999

Adv Malindi Group 300 City Chambers JOHANNESBURG

Dear Sir

BOIPATONG AMNESTY HEARINGS

Your fax to Adv M Coetzee dated 29 April 1999 refers

I have attem pted to contact you since yesterday 29th April 1999 but to no avail It is unfortunate tha t your account was not paid along with your colleagues (Adv Berger and MsCambanis)

As indicated by our Ms Shireen Fillies last week the m atter is receiving our urgent attention

We have in s tru c te d the Legal Aid Board to pay your account on the basis set out in our letter dated 26th April 1999 (A copy is attached hereto)

We understand that this is being attended to and tha t you shall be paid shortly

We have aJso responded to the letter of Nicolls and Cambanis and Associates dated 26th April 1999 and attach a copy herewith for your attention

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 36: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30APR1999 1434 TRC 021 245225 NO120

Whilst we understand some of your anxiety over the non-paym ent of vour fees we tru s t that they will be paid in due course What we cannot understand is th a t in the light of the fact tha t you and your colleagues have already been paid the sum of R 259 84189 there is a need to threaten the Truth and Reconciliation Commission by withdrawing from the amnesty hearing th a t are nearing completion

We encourage you to remain in the m atter However should you wish to withdraw on the basis tha t you have not been timeously paid you shall have to do so formally at the hearing on 3rc May 1999

PADDn p r i o rNATIONAL LEGAL OFFICER

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 37: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30flPRi999 14=35 TRC 021 245225 ISO 120 P4

Legal Department P O Box 3162

Cape Town 8000 Fax +27 21 24 5225

Pb +27 21 24 5207

O u r re f PPy rs b t r c le t

30 April 1999

Ms C Cambanis Nicolls Cambanis amp Associates P O Box 8694 JOHANNESBURG 2001(Per Telefax 011-331-8691)

Dear Ms Cambanis

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fax dated 26 April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid

According to our records Adv Berger Adv Malindi and yourself have to date been paid the sum of R259 84189 made up as follows

Adv Berger 201198 R71 93400130499 R5B 02600

Adv Malindi 171298 R 2121084

C Cambanis 101298 R56 07495130499 R52 69610

R259 84189

Adv Malindirsquos last account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and if the amounts are justified we shall recommend them for payment to the Legal Aid Board as we have done in the past

106 A d d e r lc y Steet C a p a T o w n 80 0 I Te ( 0 2 l) 2 4 5 161 Fifjlt(02 I ) 2 3 3 2 3 0 t 245 225

San am C e n tre I O ih Fir C o Von W ie llig h amp Jeppe S tr Johannesburg 2 0 0 IT e1 (0 I I ) 333 6 3 3 0 Fax (01 I) 333 0 8 3 2 6 3 4 I

M e tlife Bu ild ing 9 1 O th F lu o r 3 9 1 S m ith S tree t D u -b a n 40C O Td (03 I ) 3 0 7 6767 F a x (0 3 l) 3C7 6 7 4 2 4 9

MRS Bu d irifl 5 th F o n r 15 T e rm in u s S tree t East L o n d o n 5 2 0 0 TlaquoI(Q43 I ) 4 3 2 835 -poundix(Q43 I ) lsquo S ^ 3 5 2 2 7

E-rnail m ja y i^ jg lo b a lco za In te rn e t b ttfr A ^ W w tru th o rg z a

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 38: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

1999 1435 TRC 021 245225 NO120 P5

- 2 -

We have this morning been notified by Ms Faeza Brown that -

1 You have informed her that you and your colleagues shall all be withdrawing from the matter on Monday 3 May 1999

2 That you regard the non-payment of Adv Malindi as being racist

On the first point we strongly advise you not to talce this course of action and encourage you to remain in the matter

You obviously are aware of the enormous cost involved in setting up the hearings for a three week period and that your withdrawal as attorneys for the victims could result in the possible cancellation of the hearings

The Amnesty Committee views your intention to withdraw at this very late stage (i9 April 1999 by Adv Malindi and 30 April 1999 by yourself on behalf of Adv Berg and Adv Malindi) in a most serious light and the TRC shall reserve its rights in regard to any wasted costs incurred herein

We must also point out to you that Judge Ngcobo has made special arrangements to attend to this matter during the allocated period at great sacrifice to his official duties in the Labour Appeal Court

Secondly we take serious offence at this remark The correspondence in this matter will indicate the great efforts made by the TRC to assist and effect payment to Adv Malindi However if you have proof that non-payment was due to racism on anybodyrsquos part we shall be glad to receive it and refer the matter to The Minister of Justice for proper investigation

We trust that common sense will prevail and that you reconsider your position

PADDY PRIOR NATIONAL LEGAL OFFICER

Judge H Mali -Chairperson of the Amnesty Committee

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 39: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Nicholls Cambanis amp AssociatesAttornlaquoyn At Law

Suits 39151 Floor 3 3 V 6 9 I9Corlton (lt9ntf8 331 copy91UJohDnbdquo6Shrfl 331-6920 8 9

POBox 8694 Johannesburg 2000

Your Ref Our Ref

TO K v)T ___

FROM Cg-4 vTm --------- _

FAX NO____Z 3 3 i 2 k 2 1

N0 OF PAGESINCLUDING COVER SHEET_ ^ L-

Falt (011) 331-8691

Docex No 631

Date

Pfi yrbiTlt- i ( iD ^aJT A tINSTRUCTIONS___ r 1 v lsquo V n 1 C----- ------- mdash------ mdash mdash ----------------------

Carol Hluvtraded0laquo (BA UBI C W -1 H raquo Cmbmi IBA- UBI

9 f r M 0 0pound a d b lsquo66amp1 T 6 9 8 I pound pound OH X t M S S b 3 W0 3 H 3 I N WOd

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 40: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

FPT1laquo9 13 0 2 1 E03EZ3 hO-AU r 1

it r u T F F e c o cm Q ton L o K i62I f J j raquolaquoilaquoiraquoraquoiraquo PO Bose 3104I 7 C i p W l M O

Imdash ---- x J TmMi +7 21 24 9226Phi +27 21 24 5207

Our ref pprb trttet

30 April 1999

Ma C CambaiLS Nicolli Cambanis Associates P 0 Box 8694 JOHANNESBURG2001(Per Telefax - 011-331-8691)

Dear Ms Cambani

BOIPATONG AMNESTY APPLICATIONS 3-21 MAY 1999

Your fa dtlaquori It April 1999 refers The contents thereof are noted

We do not understand why you have any doubt that your legal costs will be paid-

According to our records -Adv Berger Adv Malindi and yourself have to date been paid the turn of R259 114189 made up as follows

A d v B e r g e r 20119K R71 93400130499 R58 02600

Adv Maltadi 171J98 21210gt

C CambM 1012M R36 0749513 0499 R52 69610_

R259 84189

Adv MaHndirsquos Wit account for R39 21600 is receiving urgent attention and will be paid in due course

We undertake to peruse your accounts and i f the amounts are justified we shall recommend thm for payment to the Legal Aid Board as wraquo hive done m the past

raquo - T u m i) 515 161 laquoult9JI)HJ M C M 3 1Urtrade 0 laquo i v w r n v i k n tradeltdeg raquo gt raquo raquo ldquo ltC 0 333

N a t ioo- i S UirYirut LcrCO 5JOOTi(0431gt 3 280- rraquox (bdquo41l) 93S2U

Z d Wd i f e i i e 0pound dd tj lsquo 6 6 6 T 1 6 9 8 T C 2 ON X laquo d SSd 3W03 H 0 I H WOdd

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 41: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

r o 1 1 3 r - c

2 -

Wt u n U mon be notifiedW Ifc 1B ldquo Bl0wn^ ^ ^ v m t g ftom the

1 vouhve ^ ^ ^ ^ lsquo ndyOUrrdquo Dldquo reg1purttef on Monday 5 M ty 1999mlaquoier n il laquobullbull---w

bdquom bdquo of Adv Mdndi bullraquo ldquo ldquo 2 T h it you reg ird the n l t a amp laquo lt bull ldquo

laquo raquo - laquo bull bull VdegU __raquo_ M M tln in the IttSttfif mdasha pound n r you to rem ain the m u -ung up the heenngs f a gt

-tS B sssssa rmdash^ ^ ^ - bull - r s s s r r s s s~ 7S ST- raquo laquotraquo KSSSS laquoraquomdashraquo-Malindi) is a m ost j^ n o u a UgR

wafted costa incurred amp ^ maogementa to

w - - - a - f f pound W S raquo mdash offid81 dutoattend to this master during the auooraquothe Labour Appeal Court ^ ^

^ ^ eHoua - this to A Malindi

S S r ^ s ^ - w S s s s a wahaU be glad to resetve It urnI - - mdashinvest galionb ^ 8a40n m ^ w fflp rev iil and thrt you recowidtt your portoB-W e trust that common regi9 P

S amp o r laquo m

J u d g e H M il l C h e lrp e n o n o f th e A nm eety CoUHdMereg

pound d Wd lt i tgt l 0 01 a d t ) lsquo 6 6 6 1 T 6 9 8 t pound pound OH XBd S S b 8UU3 H01H WOdd

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 42: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30APR1999 1650 TRC 021 245225 ISO 127 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 21 24 5225 Ph +27 21 24 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Innes Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm that you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3re May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as socn as is practicably possible

Yours faithfully

PADDY PRIOR NATIONAL LEGAL O FFICER

106 A d d e r le y Stnie C ape Tow n 30C I T e l (0 2 l) 245 I SI pa x (0 2 l) 233 2 0 0 2 45 225

Sanlam C e n tre 10th F lrbdquo Crv- V o r W elligh amp Jepse Str Johannesburg 2 0 0 IT e l(C I I) 333 6 3 3 0 Felx(C I I ) 333 C83263H I

M et fe ewilcfing 5 1 Oth F lo o r 391 Snnitn S tree t DuTan 4 0 0 0 ~ l(0 3 I ) 307 6 7 6 7 ^ax(Q3 1) 3C7 674249

N B S Bu ilC ng 5 th Floor I 5 T c -m ih u s S tree t East L o n ao n 520CTel(CW 3 I ) 3 2 9 8 5 F a x (0 4 3 ) 4 3 9352 27

E -m a il r r jo y g lo b amp -e o z a In te rn e t h t t p Vw w w t - J th o rg z a

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 43: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

30flPR1999 16=52 TRC 021 245225 NO129 Pl

Legal D epartm ent P O Box 3162 CAPETOWN 8001 Fax +27 2 1 2 4 5225 Pb +27 21 2 4 5207 Your refOur re f F B sf

30 April 1999

Advocate DI Berger 922 Inres Chambers 84 Pritchard Street JOHANNESBURG2001

FAX NO (O i l ) 3 3 3 -8 4 2 3

RE BOIPATONG AMNESTY HEARINGS

Your conversation with our National Legal Officer today refers

We wish to confirm tha t you and your colleagues Messrs Malindi and Cambanis have prepared for the forthcoming Boipatong hearing and will be in a position to continue with the hearing on the 3rd May 1999

We also confirm tha t we shall prevail upon the Legal Aid Board to effect payment to Advocate Malindi as soon as is practicably possible

Yours faithfully

PADDY PRIO R NATIONAL LEGAL O FFICER

E-m reg i1m joykreg globraquoLceizft Inxem e t h t lp w w w t r u tK o r g za

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 44: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Legal Aid Board Docex 202 PRETORIA

ATTENTION MR SD MAILE

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE 1 LEGAL AID REFERENCE NO 3 7206 98 BETTY LEROBANE

2 LEGAL AID REFERENCE NO 3 7207 98S MQTLOUNG

3 LEGAL AID REFERENCE NO LAB 96 19 98 JHB3165307 98

Enclosed please find statements of account in the above three matters in triplicate for your attention together w ith a copy of our letter to the TRC requesting authorization of payment to be given to you

Should you have any queries please do not hesitate to contact the writer hereof telephonically

Yours faithfully

CRYSTAL CAMBANISNICHOLLS CAMBANIS AND ASSOCIATES

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 45: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

TRC Legal Department PO Box 3162 CAPE TOWN 8000

ATTENTIONMR PADDY PRIOR NATIONAL LEGAL OFFICER

CRYSTAL CAMBANIShm 10 June 1999

Dear Sir

RE BOIPATONG AMNESTY APPLICATIONS 3 - 2 1 MAY 1999

Thank you for your letter dated 30 April 1999

We enclose herewith copies of the statements of account of Advocate Berger Advocate Malindi as well as Attorneys Nicholls Cambanis and Associates

All three accounts have been simultaneously sent to the Legal Aid Board in triplicate for the attention of Mr Maile Kindly peruse the accounts and authorize the Legal Aid Board to pay these costs

We annex hereto a copy of Advocate Malindis letter dated 31 July 1998 setting out the fee structure agreed to by Ms F Brown together w ith the Office of the Legal Aid Officers letter dated 20 October 1998 confirming that previous accounts have been drawn in accordance w ith the agreed fee structure already referred to Please note that there is still a sum of R3 13500 outstanding on Advocate Malindis last account as the incorrect fee structure was used

The matter is unfortunately still not completed As you know it has been set down for a further 2 weeks beginning 19 July 1999 We sincerely hope that the matter including argument can be finalized by the end of July 1999

Should you have any queries please do not hesitate to contact the writer hereof

Yours faithfully

CRYSTAL CAMBANISNLCHOLLS CAMBANIS AND ASSOCIATES

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

LEGAL NOTICES

Copyright Notice All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced distributed transmitted displayed or otherwise published in any format without the prior written permission of the copyright owner

Disclaimer and Terms of Use Provided that you maintain all copyright and other notices contained therein you may download material (one machine readable copy and one print copy per page) for your personal andor educational non-commercial use only

People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand

Page 46: 2000 ADV. PADDY PRIOR AND CHIEF LEGAL ADVISOR...Tina Nyane 5. J. Pheku 6. Emma Bohloko V-6 - 7. Princess Pumla Marangxa 8. Florence Molete 9. Dinah Manyika 10. Patrick S. Nonjoli 11.

Collection Number AK2672 Goldstone Commission BOIPATONG ENQUIRY Records 1990-1999 PUBLISHER Publisher- Historical Papers University of the Witwatersrand Location- Johannesburg copy2012

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People using these records relating to the archives of Historical Papers The Library University of the Witwatersrand Johannesburg are reminded that such records sometimes contain material which is uncorroborated inaccurate distorted or untrue While these digital records are true facsimiles of the collection records and the information contained herein is obtained from sources believed to be accurate and reliable Historical Papers University of the Witwatersrand has not independently verified their content Consequently the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website

This document is part of a private collection deposited with Historical Papers at The University of the Witwatersrand