‘DX 388 PRETORIA IN THE HIGH COURT OF SOUTH AFRICA L 8 GAUTENG DIVISION, PRETORIA CASE NO: 6097017 {in the matter between: HELEN SUZMAN FOUNDATION 4" Applicant FREEDOM UNDER LAW NPC 2™ Applicant and ‘THE PRESIDENT OF THE REPUBLIC OF SOUTH AFRICA 4" Respondent ‘SHAUN ABRAHAMS Respondent DR JP PRETORIUS SC 3° Respondent ‘SIBONGILE MZINYATHI 4” Respondent ‘THE NATIONAL PROSECUTING AUTHORITY 8” Respondent DOCUMENT: ANSWERING AFFIDAVIT ON BEHALF OF 1°7 RESPONDENT ON ROLL: Not Yer ALLocaTeDFILED BY: To: 4°” RESPONDENTS’ ATTORNEY STATE ATTORNEY PRETORIA SALU BUILDING 316 THABO SEHUME STREET CNR THABO SEHUME (ANDRIES) AND FRANCIS BAARD (SCHOEMAN) STREETS PRIVATE BAG X81 PRETORIA, 0001 580020177264 012 309 1623, 012 309 1649/50 I: regbetemetsa@iustice gov.za Eng: Mr J Sebelemetsa ‘THE REGISTRAR OF THE HIGH COURT GAUTENG DIVISION PRETORIA APPLICANTS" ATTORNEYS WEBBER WENTZEL 90 RIVONIA ROAD ‘SANDTON, Tel: 011 530 5000 Fax: 011 5305111 E-mail: viad.movshovich@webberwentzal.com oola.dela@webberwentzel.com divashen.naldoo@webberwentzel.com dylan.cron@webberwentzel.com Ref: V Movshovich / P Dela /D Cron / 3012607 C/O HILLS INCORPORATED HILLS INCORPORATED 835 JAN SHOBA STREET B35IAN SOBA STUEET BROOKLYN ‘BROOKLYN. PRETORIA PRETORIA, pate.02. 03.9012 0075 Too Tel: 087 2307314 ce ee ‘AEngelbrecht sih:LeMare. RECEIVED COPY: TIME: DATE:3*° RESPONDENT'S ATTORNEY ‘STATE ATTORNEY PRETORIA ‘SALUBUILDNG 316 THABO SEHUME STREET ‘CNR THABO SEHUME (ANDRIES) AND FRANCIS BAARD (SCHOEMAN) STREETS PRIVATE BAS X61 PRETORIA, 001 esaorz016249 12 309 1563 12 209 1640/50 88 507 0909 stumert@iuaee.gov.za IMeier RECEIVED COPY: TIME:INTHE HIGH COURT OF SOUTH AFRICA {GAUTENG DIVISION, PRETORIA ASE NUMBER: 60970117 In the matier between: HELEN SUZMAN FOUNDATION First Applicant FREEDOM UNDER LAW NPC ‘Second Applicant ane ‘THE PRESIDENT OF THE REPUBLIC OF SOUTH AFRICA First Respondent ‘SHAUN ABRAHAMS, ‘Second Respondent DR JP PRETORIUS SC ‘Third Respondent SIBONGILE MZINYATHI Fourth Respondent ‘THE NATIONAL PROSECUTING AUTHORITY Fifth Respondent | the undarsignsd, JACOB GEDLEVIHLEKISA ZUMA co hereby make onth sind state that: “TPage < 6| am the Prasidsal of the Republic of South Atice Guly appointed in terms of saction 86 read with section 37 of ths Constitution of the Republic of South Affica, 1996 (‘the Constitution"). | am the fret responciont in this application, The facis coniained herein fall viihin my personal knowledge, unless the coniext incicaiss otherwise, and are, to the best of miy knowledge and belief, both true and correct. | have read the founding and the supplementary affidavits supporting the epplication. | have noticed thet mest of the Issues thst the epolcant raises in respect of my alleged conduct or omission, are of @ lege! nati. ‘Accordigly, where | make sub the advice of ray lage representatives. jone of a legal nature, | do sc on Having lost the urgent application launched on the came grounds as this review, the applicanis infeted these proceedings in the normal cours, AS ! wil cemorctraia lair, this raven’ applesion is algo conceived az it shows @ lack of understanding of ihe relevant legislation on the besis of which I cen brefivie an enguiry under seaton 12 (6) (a) of the National Preseeutiag Auhorty Act 22 of 1098 (ihe NPA Set"). The aw in the damand hat | suepand 118 Prosecuics 2iPsae gr‘rom office simply on the besis that they ennouneed cherges, wich thoy later withdrow ‘Accordingly, | deny as risconcsived each end every alegaifon made by ihe applicanis, which is inconsistent vith the legal and fectust position that i eat out inthis answering affidavit ‘THE RELIEF SOUGHT 7 In this particular review the applicants seek the following: 71 to review and set asice my allaged failures io insiiuie an enquiry as against the second to fourh respondents and to provisioneily suspend them pending the enquiry, 72 to direct me io Insttuts an enquiry under eection 12 (8) (2) of the NPA Act as against the second lo fourth respondanis end to provisionally suepend them pending ths enquiry; 7.3 apuniive coats omar, if this applicalion ie opposed. The applicants also 299k that my follurss be declared unlawful emt accordingly raviowed or eet asic.APPLICATION IS ILL-CONCEIVED 9. ‘The application clearly misconcsives i the Mational Prosecuting Authorily. It equally mieundersiands tive role Jogel rsmevork that governs ‘snd cuties of ihe Presiden! of the Republis in reepect of the NPA and fis officials, In particular, the applicant seem to labour under the Incorrect belief that mere allegations of misconduct against the Prozecutors constitute sufficient grounds or jurisdictionel requiremants to institute an enquiry in terms of section 12 (6) of the NPA Act. This belief is mistaken and wrong in law. 10, | ain acvieed and submit that prima fecis evidence is more then juct allegations that the inplicated officiole sve not st and proper. | chil ‘turn to this Issue later In this aifidout, Relevant background 11, Ina leiter dated 7 November 2016, being anneiure FA io the iourvling atfidet, | advissd the applicants that | vogvired nore time to ubic Prosecutions Gauteng North Prataria ‘oot ce: iiister TM Nasutha: Hinislar of Justice anc Correctional ServecePage d0t3h » Frei, ai anys det dora tacin,‘paceratsi! rageazofae,Office of the State Attorney “jac,” Pretoria rronre aox0t ‘Avamore Faron Shao Same src sons) oo Siertoge Sonne no Fee Bao Str Sonn) te (©1300 1500 (Suro (rect Lag): ” Cae 1663. rae payed ieast 309 1820 esr Present RE: REPRESENTATIONS IN RESPONSE TO PRESENTS NOTICE OF 14 NOVEHEGR 2016 IN TERMS OF SECTION 445X8) OF THE NATIONAL PROSECUTING AUTHORITY ACT (Welter hereo is acting ee atterney on behalf of Dr Pretorius inthe above matter. ‘32. Pease find staches hereto Dr Pretors’resons 2 to why he shout not bo ‘suspendod 2 Wore ntyuva ht sb hx Z vexp faayHis Exoallency President JG Zuma Union Bulliigs Government Ave : Protoria, 001 28 November 2016 malt ntoona@presidenieyaov.za Dear President, RE: .. REPRESENTATIONS it RESPONSE TO PRESIDENT HS NOTICE GF. 1¢ MOVEMBER 2016 IN TERWS OF SECTION 42(6)(a) OF THE NATIONAL PROSECUTING AUTHORITY ACT i. Two Gril Society Organisations, Fisedom Under Lew (FUL) and the Helen Suzman Foundation (HSF) have, by way of an application end 2 letter dated the 1* of November 2018, requested iis Excollaney the Prosident io provisionaly suspend me and two cateagues pending’ an ‘enguly into our finess to hold office. 2 FUL and HSF ralsnd cancers with the manner in which meet, Acting ‘Special Director &f Public Prosecullons and had of the Proity Crimes Ligation Unit (PCL), te National Drstor of Pubto Prosecution (NDPP), ‘Adv. Shain Abrehams, and the Noth Geuieng Dirsuinr of Public Prosecuion, Adv. Sioongla zinyathi, “conducted tha intended Prosecution of Minisier Pravin Gordhen, afr. Ivan Pilay, and Mr. George: (©upa) Megachula. According to ths alsgaéons by FUL end HSF, our Conduct in ralation 1 the chang of the abovementioned people brought‘the Netfonal Prosecuting Authority (NPA) info disrepute, and consequenily ‘rendered us unfit hold our espactive postions. ‘The Presidency afforded us an opporunly to make writen submissions Why we should not be placed on suspension pending the outcome of ‘enquty into our fitness to hold office in terms of section 12(9(6) reed with section 14(3) of the National Prosecuting Authory Act, Act $2 of 19869. (the NFA Act’, for which lam grateful | compiting these submissions to-the Honourable Présideit end in an atiempt not to unduly burden this representation | accept the folowing: ( have arranged with my attorney to provide the documentaticn refered to Honourable Prasideot in_the_evont_that. isnot hereinafter. avaliable.) 441. The Honourable President is indood i possession of and will Consider the content ofthe Application heard and cismiisad by the Gautong High Court on the 24" of November 2016. This of cours Includes the opposing affidavits fled by Second to Fourth Respondents (the officals relevant to these representations) 42 The, Honourable President is in possession of the heads of _2rgument fled on behlf of Second to Fourth Responders in that ‘mentioned Application, 43. The Honourable Present is in possession of the representations ‘led un betel of Advocate Abrahems and Advocate WzinyathlGENERAL REMARKS: 6 'f appears that the complaint by FUL and HSF and their request for an ‘enquiry end suspension are based upon & complete wrong understanding Of the legal principles, 2 falture to appreciate prosecutorial policy and duties and by enlargési upon speculation, Their lack of objectivty and ulterior motive ate cleely iustrated by the lbusive language and personal attacks that mar the founding affidavit in ‘the Applcalion reerred io and tha leer dated the 1 of November 2016, ‘Their rational approach is apparent from the replying affidavit that they fed in the application mentioned above: "87. The test is not whether the NPA offvers are in fact ‘exercising thei power unlawful; insieed, the testis whether the public may vercelve the exorcise oF their puwer to be lunlawiul. This cloaly isthe case hore —as such, in erler to _rofect at less the perception of independence of the NPA, 2 imniedtate suspension ofthe NPA officers is wanantod." |t appears from the above thet their approach fe that the true and/or ‘object facte should bs dlarégarded in these very important decisions, io ‘order on enquiry and suspen! senior oficials of the HPA - Once a egative perception is created by the media itis enough fo justly the Infringement of besic fundamental rights of these ofits and hava them ‘suspend, The fect tat these perceptions may heve beon created by people ulterior police! matives should, escorting fo thei approach not be investigated —It should be disregarded.This approach wil, with respect, lead to a sluation that the President ecoinse the mere rubberstamp of the media, The Presidet is cccused of ecting trations’ insofar as he indicated any need to investigate th true facts defors he exercises his discretion in terms of the Consitulen end relevant Legislation, ‘The motes of the complainants are unclear and thelr attemet to infinge On the power of the,Execulve is undesirable. In the above regard | fully ‘align myself with the ining by the Gautong High Court when sting the Applicat from tho toll on the 24 of November 2046: “cull was il advised and cortanly unreasonable forthe applicants ‘Helen Sueman Foundation and Freedom’ Under Lau] fo rush and launch this application, brushing aside the request for more time ‘rom the president” ‘The roller sought has tho potendal for this court io sity info tre executive ferain which could, IT not properly considered, volte the ‘separation of powers doctrine. This could have the Judifary Straying int th terain of the executive. We should also quard, as a court, against creating trocedents ‘where, based an insolent grounds and inadequate furdaton, fo encourage onary otizens ... fo use the courts as © plttorn ‘otate to tha exacutve how i should do ts work"Anoroneh: 14 1. %. 4 | teepectuly submit that the suspension of senior officials of any governmental department end in paricular ol the NPA is e very serious ‘matter, It should clearly only be considered in exceptional ctcumstances {and only in the event that there are at leasi clear indicetons, based on objective facts, not mere speculation, of serious misconduct by the relevant offcisis. The principle of = presumption of innocence should surely also apply in these circurnstances. Only inthe event that there is evidence of a danger of prejudice to the offce of the NPA'and/or the ‘administration of Justice and our criminal Justice system should suspension not be ordered wilt be justifable "also have to emphasise with respect that suspension is a serious Infingement of the fundamental conetiutional righis of the ielevant Offlecio enc can only be justiad uncer very serious crcumsianoes «ven the feels dictate the necessity ofa suspension | Murther cespecifully submit that vary careful consideration is necessary in this instance where there are no objective facts thet substantiate the Fequest for suspension apart from the media perception creaied. It is table to refer to the fact ted the Full Bench ofthe Gauteng High Cousin ‘striking the application with costs on the’ 24" of November 2016 indoed ‘found thet there was no fectuel basis for the application apart fram the edie perception rlled upon by the Applicens. "Ris further respectfuly submited that t shoul! be bome in rind thet this ‘attor ectually deals vith disputes on @ poltical evel end that ths request ‘or our suspension Ia epparently used &8 & method to contrite to this police! dispute,Praliineny orasedure! sane: 46. | was eppointed by ihe Ninister of Justice 2s the Aatiag Special Director Ff Public Prosecutions in torms of sectin 79(S) of the National Prosecuting Authority Act 32 of 1998 (NPA. Ad). The provision of section 12{6) of the NPA Aci, ellowing the Président to provisionally suspend the NDPP or @ Deputy National Director fram his or her office pending an fenquity info his or her fess, is thus not applicable to me, "Notwithstanding te aforementioned, | wil address the concems regarding my fies to hold offi By and lege the atizct one (as wel as Abaheine and Mzinyati) ture or ~ and! he ere of the ratio ia ~whathr there wee a basis inka and factto instute criminal proseedings agains the abovementioned persons. From the content ofthe mentioned iter appears es ithe complainants ‘tually only boeed thor request fr an anquy and our suepensien on tho Prosecuiion against Minister Gorchan. | wil frtly address whether there ‘eas suficont sviance to prefor charges egainst Gordhen and whether those charges were sustinabla in aw, Secondly, | adinéss the specif deragrephe of tha felor addressed to the Prsilei in sequence. The silogaone contsined in FUL end HOF epplaion heve been zderessed inthe igetion papers refered to anovaMandate to doalwith the conus 47, | manage anit erect criminal prosecutions as stpulted in the mandate of tive Priory Crimes Liintion Unit POLL, which broadly handles meters Concerning stato secu, intemctionat crimes, anc other pionty crimes, The “other priory crimes" are “datecafaed by tha Mavenal Diwotn-”™ own emphesis}. 18. In Movember 2015, a number of proseoutore were transfered to the: PCLU. They handled some sensitive matter: like the Cato Manor (Booysen) matter, the McBride matter, and the South African Revenue Sewiee (SARS) Rogue Unit matter (which incldes the Gordhan, Moghashula and Pitay charge). Inevitably, Ihad to manage “investigations that these tansfened prosecute wers InvoVed in. As ‘stats! above, the HDPP deienmines ‘other priotly cies” and tis case \was specifically refered fo POL, 18, The POLL was therefore legisistvely mandated to deal with this eae. Therefore, there is nothing ieguler and confounding, as claimed in paragraph 7.8 on page 4 ofthe later ftom FUL and SF. Factual basis: 20, Favty September 20:6, | perused the SARE Rogue Unit docket und ‘ecyusiried myseli with direct and hard evidence relatng to intr ala 1) the “bueging® of (waive offices In the NPA, Heed Quarters on instrucion of ‘SARS officais; and 2) an eaty retrernent iregularty, The facis of these ‘seperate but related Issues arp cet out below.24. Inthe frst matter, Play, g formar SARS offical, geve instructions to "bug" (lant wiretaps) ofices ofthe top eiructures ofthe NPA. Mr Pillay ctaimedt bis instruction came fiom eting Preeident of the Republic at that tna, Mr. ‘Thabo ibski, with the eim to find information on the sage between tha Scorpions and Jackie Selebi matter. in excess of one milion Rend wes obtaired from a secret jun to pay or the wirelapping devices and there, is evidence that the operator involved In planting these devicer could proft from the operation. This was done under the watch of the sitting ‘Commissioner of SARS, Gordhn, 22 The second matter dealt with Play's request to take eatly retierrent at the age of 86, citing personal reasons, but also requested to be ~ ~feappolintein-the-same-posiion ~and-not-be-penalised-for-his-early-- — = ‘otiement. Chrisna Visser, heading Executive Reinunsretion, objectsc to this ee Piley’s reasons for retirement were perwonel; no hisiness reason eceted fo approve such a recueet and no such case wee approved fi the Post, Visser wes however ineinicied io continue with 2 memorencum ‘ting personel reszons for reirement, Wico Coetzee, @ senior, SARS ‘employee in the human resources department, stated that Pilay appliod {for pension as he wanted to pursue “other interests” 23. A second reviesd memorendum from Niageshula, the siting SARS Commissioner at tha tims, conteined @ diffrent raeson for Play's fetirerent. The reason cited on this memorandura wes to provide for Play's chitdron's education. ioc Costzse, @ senior cffiil in the eraploy of SARS in the Human Resouross Departrisnt, relsed further concoms ‘through e-mails, stating that if Magashula or Gordhan (Hen siting Sirister ‘of Finence) approved such s raquost itwould set a bed procedent. eakso raised concome about tha reappointment. He specifically incicated theitwo similer requesis were not asproved by, the Minister of Finance, Gootzee feafed lst the rotkement (and later ‘einstaterrent) could be Constied es SARS contributing townids Pilay’s chllren's education, Which wouid pur the Mister anc! ilayashula in difieuk posifon. Cocizee Cleary sieted that such a retiomant ene reinataternant could only be done If sufciont reasons test and strongly advised not to proceed, cinee the Stated retirement reasons were personal, 4, Notwithstanding Visser and Costzee's objections, Pilay was alowed to 2 take an early retirement, accessed his pension junds’ eaily, paid no penaty for that, and was reappointed in exacty the same position, Whereas Gorshan only approved @ three-year contact, Pilay was appointed for 6 yasrs_Just before. Gordhan left the specie Minisy (and. was appointed to @ new porfolis), he concluded another contract with Pillay (wile his previous contract vies ell val end extent), 25. On tho6 September 2018 the prosecutors in tk meter, Deputy Directors ‘Sollo Keema and JJ hiotsha, ck! © preseniation io the WPA menagesment regarding their investigation. They presenied the hard evidence on the wiretepping and proof of Piley’s InvoNement, as well 26 Pilaye ) ‘etirement, 28 From the evidence presented to menegomené that dey, | came io the pia facie conclusion that e case couki probebly bu made out that Pie land iegeshula were vere by the expaits In the HR cepermont end ‘hey had the requiete inient io act unlawful, Furthermore, Gorchsn an Pilay’s involvement in te wieienping mater was cullen io ersete & suspicion and prove & possible moive to provide Play with an unkwsul reticement package. Tho investigetion ino the wietepping s stl ongoing,but | botleved, in good faith, that tho prosecutors hed suliciené evidence rement matte. regarding ther Lyosl bene: 77, Despite the evidence the prosecutors presented, | dle quesion Gordhan's ‘criminal intent. Since the Annexures annsxect io ofthe Second Retremant Memorandum were not be provided, ! questioned whether Gordhan was ‘not “duped” by Magashula and Pillay. Deputy Director Sello Maema ‘assured me that Gordhan was the SARS Commissioner for 10 years and ‘that he was approached about the matter before the “ina” memorandum 8.sukmited to.him_| did see a memorandum that was-addressed fo Gordhan before he eppreved the final spplication. Tha prosecutor was Conident that he could prove the nent, end thus gui, of Gordhan. | =o ‘questionad Deputy Director snbclant Mlotsve separataly end he assured ‘me that he hed the fim believe thet ther was an unlawful scheme that ‘ould not be cohiaved without Gordhan's yarefpaion, 28. Its of material importance to emphasise thet the empowering legislation does not provide for a discretion io the Minister io welve the penalty clause. For corvetience and in view of the Importance of ‘his iesue | quote Rule 14.5. of the Government Employees Pension Fund (GEPF") Rules: "14.3.3 Members with 10 ysars end more pensionable service- @ we30, 34 |b) a member who ratres on account of e reasan mentioned In rules 14.3.4 (8) or (0) and who has at ‘vest 10 yore ponsicnable sarvice to his or her cred, sivall be paid the bensits refered to in rus (a) above: Provided. thet such benefits shall be reduced bone thied of one.ss22u% Sor gach. pomrete month hetween the member’. ectual dato of retrement and his_or_her _cension-etiemeni _siats. Rule 14.4.3 amended by GN 1072 of 8 Aupust 2003.7" Oy emphasis ther affidavits y Maema land Mlotswa and DPCI team consisting of infer alia a Biigadier. For Instunce the Haws tsam obiained « statement trom Kenny Govendsr, the Director Genaral of the Depertment of Publ Senvce snd Admbictrstion, Who provided peckages. Similarly the statement of Gerda Van den Hoover ftom SARS was obtained: Her situation was comparable to Ivan Plays situsion. She went ‘on pension when she reached the age of 68 but, unite Pitay, wes mace to pay the penally. In the above regerd we were also very eve to the bssic principle In our lew that there shoud be equality before the lew. The fect tet bir Gorthan wes a Minister in the central Cebinet could net axuse him fram prosecution if there wes a prima fecie cee of unlawiul conduct sgaltist him. To summariee this postion | refer tothe following:ait. 312, 314. 3ts. 318. 317. 3t8. ota ‘Mr Play epoted for exrly retirement in terms of the GEPF ulee ‘and Regulations, He was entiled todo eo in view ofthe fact thet he reached the minimum age of 55 et the siage of his application. “The Miniter Indeed had the power and authority to adhere to his request . The GEPF Rules, however, provide for the specific procadurs and mo‘ importantly to « spectic penalty that ANY PERSON will have ‘to tear in circumstances of an eaty retirement “There is no suggestion of any discretion that the Minister or for that mater any person andlor ently has to exclude the penalty prescribed in fhe Rules... Mirister Gordhan adhered to the request of ir Piley for early retherent, ‘The Wihieier futher Instructed that Mr Pillay shout! not be penalised as prescrBed in the GEPF Rules for early retrament but that SARS should accept fabifly forthe panalty referred to above, “The Mhnisier nc no discretion or power to do 50, ‘A matter thet even concomed ws more was the fect that Wir Piley was dvetly ster his eniy retirement reappobied inthe vary sane pos thal he previously hel’ in SARS with the seme benefits. It ‘could thersfore never be argued that this wee 2 bone sido erly retieinant, + ‘The reasons provided by Mr Pllay for the above esriy retirement and fo be funded by SARS to provide forthe ponelly prescribed by3. 3. the Rules of the GEPF in excess of an amount of RY, nilfion wre personal reasons. The’ cbjectho facis are that Mr Pilay was allowed to take early retrement with full bonafite Including a huge Initial seyrrent and thereafter monthly payments and he was thien lrnmediately eppolted in the eaine post with the same emunsration. Al this was funded hy the South Aftican t=xpayars {or no legitimate reason and contrary to the express Rules of Ue GEPF. 31.9. Even if It was true that this unlawful procedure had been implemented in the past, we held the view that such unlawful previous procedure ofthis nature based on similar fac, despite the tect that we endeavoured to obielniormaon In this regard. Once satisfied that a prina facie case existed | requested Dr Susan BBulkau, @ senior advocate in my office, to do research on "public interest. | made such @ note on the memorandum. | myself considered the: juthoties and she provided me with her research. 1 considered this factor and took it into sccount. Once we were salsfed wo consuled and provided! fhe NDPP with our views, As mentioned we also mlesd this Issue vith the top menagement ofthe HPA arid they slered our view that {ths principle of equality before the law should be ediered ‘o déspiie Poesia negeiiva rece ht may follow Atthat ange, Lwen ned warn of any finenciai of logal advice thet wae obtained by Megashula, Play or GGordhan which could Inicals the lack of knowlxige of unizwfunses.ate 3, 1 wil bretly desl with specie sllogations 1 the letter ofthe complainants, deter! tho 1" of November 2018. 38.4. Ad parmgeaph 10: | deny that 1 proceeded with the charges with either ulterior purposes of in # breathakingly reckless fashion, without proper investigation and regerd to the evidence. I had no influence on Gh ‘he investigation team,’ when they completed this leg of the Investigation and | dd not now when the presentaon would be made, | had no uieror purposes and adjudge the matter on the ~--facts presented fo ma.__| id not proceed in reckless fashion but = qUestioned the prosecutors end asked for further statements, 33.2. Ad peragraph 11: {did not fa my fundamental constitutional and statutory duty to censwre the charges were propery grounded and I tock en impartial, ) indspendent and objective view ofthe facts. | had no reason 10 Inteiogate oF question the investigative work performed by tho PCH at that stage. 98.9. Ad paragraph 12: ell to understand or what basis in kevr and fect thei what is stetod In regard to Mr Abreheins apply wit equel foros io me. AS