IN THE HIGH COURT OF SOUTH AFRICA (WESTERN CAPE DIVISION, CAPE TOWN) CASE NO: BDSH4/85/2024 In the matter of: ZANE JOHNATHAN KILIAN APPLICANT and THE STATE RESPONDENT AFFIDAVIT BY APPLICANT IN FORMAL BAIL APPLICATION I the undersigned Zane Johnathan Kilian states hereby under oath in English 1. | am the applicant in the above matter. | am currently awaiting trial and in custody at the Goodwood Correctional facility. | was arrested on 22 September 2020 and in custody since my arrest. 2 1 am charged with various other accused as per the charge sheet. Most | have never met up until the day we appeared together.| heres apply for bail. | confirm that I will be pleading not guilty at trial as explained below. | am confident that | will be able to convince the trial court of my innocence. 1am further aware that the record of bail proceedings form part of the trial record and that evidence that | give in this proceedings might be used against myself at trial. | have been advised that | do not have to deal with the merits of this or any other case but find it appropriate to deal with it briefly. Due to the complexity of the matter | reserve myself the right to place oral evidence before this court in addition to this statement and/or other evidence in response to the states case in opposing my application for bail. lam aware of some of the reasons why the state oppose my release on bail and will deal with it herein. 1am advised that this is a schedule 6 bail application which places the onus on me to adduce evidence to satisfy the court that exceptional circumstances exist, which in the interest of justice permit my release on bail. PERSONAL CIRCUMSTANCES: Lam 49 yeas old mle A rere SESS SSS | 0'cict « Hugenote High School in Springs during 1999.82. | am divorced with (2) two minor children dependent on me. A special needs son aged 9 and a daughter aged 15 years. The daughter reside with my ex-wife and my son with my father, Hein Kilian. 8.3. My son, Zayden Kilian is autistic and cerebral palsy. See Annexure ZK 1-5. The financial needs of my special needs child is enormous and include special school fees, therapy and medication. He is currently 11 years old and we hope to enrol him in Grade 1 for 2024. 84. My father, Hein Kilian currently assists with my financial responsibilities due to my incarceration. He is a retired South African Police member who is struggling financially in assisting me using his life savings. 85. Directly after matric | focused on my rugby and went to play in the English Rugby League. In 2002 | started playing for Cheetahs 0/21, broke my back in 2013 and stopped playing rugby. 86 I had my own business; “Zane Kilian Tracking and Investigation”. See Annexure ZK 6-9. My main income was for the repossession of motor vehicles as well as the tracing of people to collect outstanding debts eaming R20 000 per month. Attached find a list of some of the vehicles that | repossessed during January 2019 as Annexure ZK10. 87, Currently | do not own any property in South Africa or overseas. 8.8. lam an South African citizen and do not have any ties or assets overseas 9. $60(4)(a) rhw $60(5)(a)-(h) o4 | respectfully submit that should | be released on bail that | will not endanger the safety of the public or any particular person or commit a schedule 1 offence. 9.2. 1 did operate a debt collection business. | have however lost everything due to my incarceration. | have 2 current employment offers. One with my brother and another with a friend9.3, 10. 10.1 10.2, 10.3. 10.4. 10.5. 10.6. 10.7. 10.8. 10.9. | further understand that the tracing platform LAD is no longer available. $60(4)(b) riw $60(6) of the CPA | respectfully submit that there is no likelihood that | will attempt to evade my trial should | be released on bail. On the contrary | want the matter to proceed as soon as possible to clear my name in the light of the negative publicity that this case had received. Ihave strong emotional and family ties to Gauteng and South Africa My family and assets are located in South Africa. | do not have any assets abroad. | do have a passport which is in possession of my attorney with the instruction to hand it to the investigating officer should it be requested. Ihave no other travel documents. | have been incarcerated for nearly 3 years, lost my business and are reliant on the support of my father. | have no financial means to evade my trial I have never escaped from lawful custody. | have no warrants out for my arrest. My financial possession is of such a nature that | would not be in a position to have any bail money forfeited to the state. The world has become globalized and South Africa is an integral part of the international community. | am advised that South Africa has extradition agreements with most countries in the English speaking world and most countries are prepared to extradite accused persons to South Africa even where no extradition agreements exist. | accept that the charges against me are serious, that does not mean that | should be refused bail. Even convicted murderers are released on bail pending appeals, such as the recent matter of The State v Jason Rhode.10.10. 10.11 1 1141. 11.2, 11.3, 11.4. 11.6. 11.6. | understand that should | be convicted, | would most probably be sentenced to a period of imprisonment, but as already stated above | am convinced that | will not be convicted on any charges against me. | was advised by my attorney that should this Honourable Court be inclined to grant me bail, it can impose strict bail conditions including that | regularly report to the Springs Police Station. Section 66 of the CPA regarding failure to adhere to bail conditions has in depth been explained to me by my attorney. $60(4)(c) riw $60(7) of the CPA | respectfully submit that there is no evidence that | will attempt to influence or intimidate witnesses or will hide conceal or destroy evidence should | be released on bail | was informed that the investigation is complete and all witness statements was obtained. | will abide by any bail conditions and not communicate with state witnesses. To the best of my knowledge | do not have access to any evidentiary material. The evidentiary material should be in the custody of the South African Police. The South African Police Services did conduct a search and seizure at my residence. | cooperated with the police and handed over items as per the search and seizure warrant voluntarily. | note with concer that the investigating officer had obtained an affidavit from a Bradley Goldblatt hereinafter referred to as “Goldblatt” that | contacted him on Sunday 20/09/2020 instructing him to delete my profile from LAD and Marisit, platforms that his clients used to trace individuals. That is simply not true. | will deal with the statement of Goldblatt below.12. 12.1. 12.2. 13. 13.4. 13.2. 14, 14.1, 14.2. 14.3. 14.4. 15. $60(4)(d) riw $60(8) of the CPA. | respectfully submit that there exist no likelihood that | will undermine the proper functioning of the criminal justice system, including the bail system 1am not in custody on another matter, nor am | on parole. | will adhere to all bail conditions. | will not commit any offence. The investigation into this matter is complete. $60(4)(e) rw S60(8A) of the CPA | respectfully submit that should | be released on bail there is no likelihood that | will disturb the public order or will undermine the public peace or security. | reside in Springs, Gauteng and will therefore not disturb the community of Bishop Lavis. The Honorable Court my set certain bail con bail. ions with regard to jurisdiction should it consider my release on $60(9) lam already in custody at this stage for approximately 3 years. | am advised that the trial date has not yet been determined and that itis unlikely that the matter will be tried this year. If1 remain in custody my minor children will suffer further as | do not know how long my father will be able to support them. Should | not be granted bail, | will be impeded in the preparation of my defence, as in prison | do not have access to the facilities, documentation and my legal representative to properly prepare for trial, | am advised that this is a volumous case with a large amount of exhibits. $60(11B) of the CPA15.4 16. 16.4 17. 7A 17.2. 17.3, 17.4. 17.5. 17.6. | do not have any previous convictions, or any pending cases, except this matter. S62 of the CPA | undertake to abide by all bail conditions that this Honourable Court may impose, should it be inclined to release me on bail ‘The charges against me: | will plead not guilty to all counts and alternatives in the charge sheet. I want to make the following submissions with regard to the counts relating to the unlawful interception of communication and its alternatives. I note with concem that | have been charged with various murders, attempted murder as well as conspiracy to commit murder charges. From my understanding; the only fact that might link me to these charges/allegations is that | allegedly pinged the cellphones of various individuals as per a record of pings provided to my legal representative. | did ping cellular phone numbers in execution of my business, being a debt collector and repossessing agent for various clients, including financial institutions. | did have the tools to ping a cellphone to confirm the proximity of the phone. This is not very accurate as the tracing is done via cellphone towers. Locating a cellular phone based on a single cell tower can place the mobile phone in a broad area, but it cannot pinpoint it. As the phone connects to more towers, the accuracy improves. | did cellphone pinging via a platform with the aid of a code. The software and user code for this tool was obtained from Bradley Goldblatt “Goldblatt” He is well known and have already supplied a affidavit to the investigation team.477, 17.8. 17.9. 17.10. 17.11 | believe that this platform and user code provided to me by Goldblatt was also provided to other users, using the same platforms and code provided to me. Note Annexure ZK11 a document drawn from my profile with user “brad1234”. User names and passwords were used between users. Note Annexure ZK12 the username of another pinger on the same platform. Note the newspaper article alleging that Goldblatt sold pings to various Cape Underworld characters dated 05/11/2020 as Annexure 2K13-15. The pings conducted on this platform and details in possession of the state does not only include the pings that | activated, but also pings done by other individuals unknown to me. | understand that the state obtained an affidavit from Goldblatt and that he will testify at trial. | submit at this stage that his evidence is tainted and will in my opinion not stand judicial scrutiny, including evidence obtained from his platform, I found that pings bought from Goldblatt, disappeared from my account and that the disappearing pings were used by other individuals, Therefore the record of the pings cannot link me to all instances where individuals were pinged. | submit that the state will not be able to able to produce a record of the specific pings that | did. Furthermore it is unlikely that the state can proof the the location of the person that did the pings with regard to the record of pings in the case docket. Note the article with regard to the Mihalik murder attached as Annexure ZK16-17. It is noted from the article that South African Police Services members used pinging technology to apprehend the suspect in this matter. | understand now that pinging is a criminal offence,17.12. 17.13, 17.14, 18. 18.1. 18.2. 18.3. 18.4. 18.4.1. Further to my argument that ! was not the only pinger on the platform of Goldblatt is the fact that my arresting officer Wynand Olivier also also bought pings from Goldblatt. Note Annexure ZK18-19 for a list of people that received pings on the platform. The record also contain negative pings. Negative pings refer to those instances where a cellular handset could not be traced to a celiphone tower. To this day Netstar still requests me to do work for them see Annexure ZK20. My relationship with Nafiz Modack | learned of Nafiz Modack “Accused 1" through Gerhard Strydom “Strydom” another debt collector who contacted me and informed me that Accused 1 heard of my success as a debt collector and that he, Accused 1 wanted to make use of my services. | informed Strydom that Accused 1 can contact me. This was during January/February 2020. Accused 1 called me from a private number and introduced himself to me. He explained that he receives a lot of debt collecting work in the Johannesburg area and therefore needed my services. I did debt collecting work for Accused 4 as well as ‘pings’ on his request to trace people for various reasons explained below. | confirm that | did receive money from various clients for services rendered. In some instances outstanding debts were paid into my bank account. | would then calculate the fee, take my portion and pay the rest over to the client or other party as per the agreement. I deny that | committed money laundering in my business relationship with Accused 4 or any other individual I have no other connection to Accused 1; other than the fact that he was a client of my firm and that | pinged cellular numbers on his18.5. 18.6. 12. 19.1. 19.2. 19.3, 19.4. 19.5. request for compensation in terms of a business relationship. | do appear in some photographs with Accused 1. This was taken in a lighter moment. | used various reference numbers to save the information of people that | had to ping more than once on the request of Accused 1. | also drew a XDS trace reports in some instances to identify individuals. I saved numbers with names such as Donk (Donkie), Boots (William Booth “Booth"), Horse (Van der Horst), KK (Chari Kinnear “Kinnear’) and Link (Lincoln) iam Booth: All pings on Booth was on the request of Accused 1. Accused 1 told me that Booth was an attomey who owed money to a client. There was nothing strange with the explanation Many of Booth's ping results were not successful and | informed Accused 1 that it could be because Booth's wifi network or his location settings on his phone was disabled. | would in any event forward the negative ping results to Accused 1. | was not aware that an assassination of Booth was planned. | do not know any of the co-accused in the Booth matter. I have never previously met or spoken to Jacques Cronje or Sameer Vallie. | was requested to ping a number which now turned out to be that of Sameer Vallie. Without access to the data on my cell phones | am unable to say from whom | received the request to ping Mr. Vallie, but can only assume that the request came from Accused 1 1020. 21 21.4.1. 24.1.2. 21.1.3. 21.1.4. 21.2. 21.3. Charl Kinnea: Accused 1 i “Kinnear”. | did a full search on Kinnear on the same day. It was ally asked me to gather information on a Charl Kinnear normal modus operandi to obtain information whether | did a debt collection or vehicle repo for any client. The pings conducted on the Goldblatt platform and details in possession of the state does not only include the pings that | activated, but also pings done by other individuals unknown to me as explained above. This became clear in some instances when | was asked to ping certain individuals for Accused 1. Note Annexure ZK21 a WhatsApp message between myself and Accused 1 Although | pinged Kinnear, Accused 1 was well aware of his location. Note Annexure ZK22-24 an News24 article in which a Brophy admit that he had pinged Kinnear. Also note that a Franscois Nel pinged Kinnear. Annexure ZK25-26. Note the statement of Edward du Plessis Annexure ZK27-32 page 2 paragraph 10 that states Calvin Rafadi also pinged for Accused 1. 1 was not aware that anyone else pinged for Accused 1 In some instances | did not even know who | pinged. Note Annexure ZK33 a WhaisApp message which states “So / was really under the impression | was tracking a female’. Accused 1 informed me that Kinnear was a corrupt policeman to whom he has paid money in the past and that Kinnear and Jerome Donkie Boysen “Booysen” worked together; and that there were a “hit” on him, Accused 1. | am aware that Booysen is allegedly the boss of the Sexy Boys gang according to news paper articles. Accused 1 gave me various cellular numbers to ping and to check if these numbers were in the same vicinity/location. Accused 1 further informed me that the people to whom these cell numbers belong to, i21.4, 21.5. 21.6. 247. 21.8. 21.9, 21.10. want to kill him, and he needed to know where they were so that he knew which area to avoid. Accused 1 sent me a photo of a piece of paper with names that was an apparent “hit list’. Accused 1 also sent me videos where gates were forced open, dogs were shot and people assaulted. | was led to believe by Accused 1 that it was his gates, dogs and staff in the videos. | earned that Accused 1 did security at night clubs and therefore | did not find it suspicious when | was asked to ping Kinnear in the early morning hours. I was requested by Accused 1 to ping Kinnear and Booysens cellphone numbers at the same time to see if the two of them were in the same vicinitylocation. On several occasions the ping results showed that Kinnear and Booyser’s cellphone numbers were in the same vicinityllocation and this gave the credence to Accused 1 believing his story that they were working together and were planning to kill him. At that stage it became clear that there was an issue between Kinnear, Accused 1 and Booysen On one occasion that | pinged Kinnear and Booysen’s cellphone numbers, on Accused 1's instructions, the result reflected that they were in the same vicinity/location in Johannesburg. On further pinging of Kinnear's cellphone number, the results showed that he was in Brakpan, where my son's school was situated, Therefore | pinged Kinnear again and the results reflected that Kinnear was in Springs, close to where my daughter's school was situated. Further pinging reflected that Kinnear was in Nigel vici where my ex-wife resides. This caused me to be concerned for the the safety and that of my family. | then contacted Accused 1 and asked him why Kinnear and 1221.11 21.12. 21.13. 21.14. 21.15. 21.16. 21.17. Booysen were in my area. Accused 1 said that he will find out and get back to me. Within minutes Accused 1 called me back and said thet | should not worry, and that Kinnear was there for a fire-arm investigation regarding corrupt policemen After my arrest and whilst | was in prison | was informed by a fellow inmate that Booysen was there to confront me on why I was pinging his cellphone number. | was afraid for the safety of myself and that of my family. Accused 1 also informed me that he found out that Kinnear's car was, up for repo at the bank, and that he wanted to humiliate Kinnear by having his car repossessed. As this was not one of my car repo's | did not ask for details of the car. ‘Accused 1 gave me the contact number for the Sheriff in Cape Town that he had arranged to repossessed Kinnear’s oar. | saved this number as “Pablo Sheriff", meaning it was the Sheriff arranged by Accused 1 aka Pablo. For this purpose, Accused 1 requested me on a daily basis to ping Kinnear’s cellphone number as he had a ground team ready to assist the Sheriff to repossess the vehicle. The ground team always had excuses for not finalizing the repo. It was either raining to heavily or the Sheriff was not available, etc. | got frustrated and irritated as the pinging request had a negative impact my family life as | sometimes received requests from Accused 1 to ping Kinnear’s cellphone number in the early hours of the morning. leven suggested to Accused ‘ that he should pay my flight ticket and fly me down to Cape Town so that | can repossess the car of Kinnear myself. On the day of the shooting of Kinnear, which | now know was 18 September 2020 Accused 1 asked me to ping Kinnear’s cellphone 1321.18. 21.19. 21.20. 21.21 21.22 21.23. 21.24. number during the course of the day. The requests from Accused 1 stopped at about 15h25, which was the last ping of Kinnear's cellphone number on that day. I became aware, through the media of the time Kinnear was shot and I-can state that | was in a pharmacy in Springs. Note a picture as Annexure ZK34, | have also seen a video of the shooting and my observations are that the shooter had no cellphone in his hand. It would not be difficult for any person to obtain the address of Kinnear. Shortly thereafter | received a voice note from Renier Van Der Vyver, a close associate of Accused 1 saying that ‘Kinnear is dead, Christmas came early’. | was shocked. Renier van der Vyver is a close associate of Accused 1. Note birthday message as Annexure ZK35 and a picture of Van der Vyver as Annexure ZK36 Shortly thereafter | received a phone call from a Ziyaad informing me to get rid om my cell phones and if | do not want to co-operate, they will come and fetch my call phones. | asked Ziyaad, what was wrong and he said nothing serious. | did not destroy my cellular phones but handed them over to the South African Police Services two days later, 20 September 2021 when the HAWKS came to search my house. It was at that stage that | contacted Accused 1 who told me to contact attomey Eric Bryer. | had no previous dealings with Bryer but knew that he was an attorney of Accused 1. At about 21h30, if my memory serves correctly, | asked my wife to call Mr. Bryer. | cannot recall if | spoke to Mr. Bryer that evening but was informed to exercise my tight to remain silent. Note also WhatsApp message from Bryer ‘Dont say anything” Annexure 2k37 Later | had a whatsapp conversation with Bryer who requested me to cover myself, him/Bryer and Accused 1. | understood this to mean 1421.25. 21.26. 2127. 21.28. 21.29. 22.1. that | should not implicate Accused 1 in the pinging of Kinnear. | was also in telephonic contact with Bryer who told me not to say anything. Note Annexures ZK38 for communication between myself and Bryer. Worth noting that Bryer instructs me to “Keep yourself me and boss covered” Accused 1 at all relevant times paid my legal fees to Bryer. Bryer told me that Accused 1 said that | must say that | pinged Kinnear’s cellphone number on the request of a certain Mr. Mohammed. That was the version that | provided to the South African Police on advice of Bryer. | have proof of this conversation in whatsapp with Mr. Bryer. On 24 September 2020 when | was confronted by Captain Joubert, | out of fear for my life and that of my family and as instructed by Accused 1, | told the police that | pinged Kinnear on the request of Mr. Mohammed. This was a total lie. Later | told the police in the presence of Advocate Rosemann that the true identity of the person who requested me to ping Kinnear’s cellphone number was Accused 1. I never referred to Accused 1 as Mr X. 1 can recall that at some stage thereafter Bryer informed me via whatsapp that if | implicate Accused 1 that he/Bryer, myself and my family might as well pick out our coffins. | was never aware that an attempt to assassinate Kinnear was planned nor was | aware that | might be assisting in such an attempt. At some stage | did ask Accused 1 what his problem was with Kinnear and Accused 1 said that Kinnear was a “skelm’, Issues within South African Police ic What concerns me is that state witness Goldblatt par 8 of his affidavit attached as Annexure ZK39-42 already informed the Anti-Gang Unit 1522.2. 22.3. 22.4. 22.5. 227. 22.8. “AGU" of the South African Police Services on 3 September 2020 that | was apparently pinging the cellphones of Kinnear among others. From Goldblatts affidavit it appears that he had worked closely with the police and regularly gave them updates. He further states that he had already given my particulars to the AGU, the very same unit of the Police that were investigating the cases that | have subsequently been charged with. The conduct of the police is very suspicious. Goldblatt also apparently realized that their system was used in a gang war. If the interception of communication is an offence then the SAPS could have arrested me on 3 September 2020 as they had already had active cases for the attempted murder of Booth among others. | am aware of the Independent Police Investigative Directorate report “IPID report” in that General Sithole gave instructions to the IPID to investigate SAPS members for their conceivable failure to act and prevent the murder of Kinnear during the period between 3 September 2020 to 18 September 2020. See Annexure ZK43-133 for the IPID report. The report further highlights at page 18 paragraph 11.1 the so called rogue unit in the Western Cape Crime Intelligence and the allegations and suspicions that members of the rogue unit have been cooperating with gang members. On page 19 paragraph 14.1.1 the report went further that the DCPI in Gauteng had failed to initiate an investigation into the illegal monitoring of Kinnear’s phone. In @ letter from Lincoln to Kinnear it is noted that he, Kinnear was relieved of his duties at the AGU as result of pressure of his work load. Annexure ZK134-135. News 24 article dated 21 January 2021 reports that “besieged police Crime intelligence (Cl) boss Peter Jacobs is the second high-ranking 1622.9. 22.10. officer to face an intemal investigation centred on the murder of Anti- Gang Unit (AGU) detective Chari Kinnear. The probe relates to what Jacobs did, or failed to do, when police received waming of a threat on Kinnear's life. The intelligence chief is now seized with a war on meny fronts and is ostensibly on suspension while facing other serious misconduct charges, these relating to the use of the CI slush fund to buy Covid-19 PPE. Kinnear was gunned down on 18 September, two weeks after police received credible information that his phone was being illegally tracked, with fears that the surveillance was @ precursor to an attack. In an intemal police memorandum obtained by News24, Police Commissioner Khehla Sitole notified Jacobs that he was under investigation for “failing” to act on the threat. News24 previously reported that two weeks before Kinnear’s slaying, Hawks officials from the Crimes Against the State Unit had moved immediately to confirm information - channeled to them from an informant - that the decorated cop was being watched” Annexure 2K136 Further to my argument that | was not the only pinger on the platform of Goldblatt is the fact that my arresting officer Wynand Olivier also also bought pings from Goldblatt. Note Annexure 2K137 for a list of people that received pings on the platform. Goldblatt further alleges in paragraph 11 of his affidavit (Annexure ZK39-42) that | contacted him on Sunday 20 September 2020 while 40 Hawks were at my house. During this search and seizure operation the police were not able to find my phones. | realized what they were looking for and handed my cellular phones over to them willingly. | did not contact him asking him to delete my profile. This is simply not true, Goldblatt states "/ asked him why they were there” | deny that | had such a conversation with him. I was informed by my attorney that persons subject to a search and seizure warrants will 1722.11 22.12. 22.13. 22.14. 22.15. 22.16 not be allowed to make telephone calls other than to a legal sentative during such time. This is standard police procedure. | find it quite strange that 40 Hawks would allow me to make telephone calls. lam also aware that the protection of Kinnear had been taken away during January 2020 while he apparently Attach find Annexure ZK138-143 a “Report of the Portfolio Committee on Police on the Petition of Mrs Nicky Kinnear on the death of her husband, Lt.Colonel Chari Kinnear dated 17 March 2021". received death treats. In this report Mrs Kinnear is concemed with the fact that her husband was on a apparent hit list, that their home was attacked with a hand grenade on 23 November 2019 and that her husband wrote a report to the National Commissioner in which he complain that he was being monitored by a rogue unit of police officers attach to the Western Cape Crime Intelligence Unit and that these officers were intercepting his calls. From this report it further appear that the Kinnear family wes threatened by the South Airican Police Services Crime Intelligence Unit, It is also noted from this report that the Police was well aware that Kinnear's cellular phone was pinged. Why did the police not act then. The oniy reasonable inference that can be drawn is that there were several individuals with 2 motive to kill Kinnear. | had no motive to harm him, it is noted from the Committee's comments that the quite withdrawn of Kinnears protection raised suspicions and committee members asked the Ministers and Deputy Ministers to respond A portfolio committee member further pointed out that Kinnear wes killed because that there was information available that would result 1822.17. 22.18. 22.19. 22.20. 22.21 in the exposing of South African Police members and that it was not gangs that killed him, but e mafia leading the department. Other newspaper articles alleged that the IPAD report into the death of Kinnear was restricted as senior police officials were implicated. Attach find a Parliament media release dated 10 November 2022 attach as Annexure ZK144-147 that the Westem Cape High Court ruled that roque elements are operating within the Anti-Gang Unit in the Western Cape. The IPAD report into the killing of Kinnear was never released to the public. I further note with concern a News24 article dated 03/10/2023 attach as Annexure ZK148-151 headlining “Afriforum’s private prosecution unit to help investigate the murder of detective Char! Kinnear” Another article dated 27/01/2022 attach as Annexure ZK152-157 “The Independent Police Investigative Directorate (Ipid) has lodged a criminal charge against National Commissioner Khehla Sithole for failing to cooperate in an investigation into the murder of Char! Kinnear.” Also note a letter Annexure ZK158-160 dated 12 October 2023 from Miss Natasha Downe addressed to Advocate Gerrie Nel informing the latter that Kinnear, General Veary and Sergeant Lewis were all suspects in the missing R60 000 that belonged to a Faizel Domingo who was declared dead 17 days prior his murder. Note that a case was opened Lentegeur CAS 47/08/2016 see Annexure ZK161-163. Attach find a letter from Accused 1 stating that he had paid Veary R5OK. Annexure ZK164. In the matter of Asley Tabisher case number BDSH4/85/2021 Annexure ZK165-235 a AGU police officer who is charged in terms of the Prevention and Combatting of Corrupt Activities Act 12 of 2004 it is noted that he, Thabisher disposed of an affidavit stating that he 1922.22. 22.22.14. 22.22.2. 2.22.3. 2.22.4. 22.23. 22.24. at all relevant times acted within the scope of his employment as instructed by Major General Andre Lincoln. Thabisher further states that: Crime Intelligence executed a warrant issues at the house of ‘Accused 1. It is also known that Accused 1 had a civil claim against Minister of Police Lincoln Kinnear among others. Attach find Annexure ZK236, 2 newspaper report. He has audio clips and screen shots in which he receives instructions from Lincoln. The AGU knew that Kinnear's life was in danger. Case was also discussed with Blaine Lazarus. Although the matter before court is trial ready the killers of Kinnear is stil on the loose. | was informed that Greenies Carilse were the shooter in the murder of Kinnear. See Annexure ZK237-238. | know and understand the contents of this statement I have no objection in taking the prescribed oath I consider the prescribed oath to be binding on my conscience 20