Amnesty Hearings

CHAIRPERSON: Before we commence, or continue with the hearing, I would like to raise the question of Mr Bosch's application. As I understand it, he says he doesn't know if he did anything. Mr Raven has said he didn't do anything. It appears to me that it is impossible for us to grant and it would be wrong for us to grant an application in those circumstances.

We are here to hear application of people who say they have committed an act. He doesn't do so, but if evidence becomes available to show that what he did do, admitted he did, constituted part of an offence, then he would be entitled to be heard, so it appears to me that the only proper course is to adjourn to a date to be arranged Mr Bosch's hearing.

MR ROUSSOUW: Mr Chairman, as far as I understand the Act provides that should the information become available, then the TRC should notify him of that fact and then a hearing should be held.

CHAIRPERSON: Yes.

MR ROUSSOUW: I would fully concede to that. Mr Chairman, why I feel that at least myself will be present here for at least the rest of today, is that Mr Raven is still under cross-examination.

CHAIRPERSON: Yes, I am not saying you should leave now, but after today, after Mr Raven has concluded his evidence, it appears pointless for either Mr Bosch or you to remain here. There will be a record available, should it become necessary, which you can be referred to and obviously you would be, or you say the TRC should notify you. I don't think Mr Bosch is the least interested in having the TRC notify him. What he is interested in is if someone comes with a suggested indictment and has evidence to show that he did, he can then use that evidence to renew his application.

MR ROUSSOUW: Indeed Mr Chairman, thank you.

MR BIZOS: Mr Chairman, may we say something on this. It is said tentatively, it may well be that his evidence may in some way effect the credibility of Mr Raven.

CHAIRPERSON: The evidence agrees. What he has said in his application, Mr Raven agrees with. We are not here to play games Mr Bizos. If he wants to withdraw now to a date to be arranged, I don't see why we should refuse it in case it may effect.

If you want to consult with him, you are at liberty to do so.

MR BIZOS: Yes, what I am saying Mr Chairman is, that he may be called as a witness in these proceedings.

CHAIRPERSON: Well, if you want to do so, but he is no longer a party to these procedures. His application is removed from the role and adjourned to a date to be arranged.

MR BIZOS: Yes.

ROGER HOWARD LESLEY RAVEN: (still under oath)

CROSS-EXAMINATION BY MR BERGER: (continued) Thank you Mr Chairperson. Mr Raven, it came to your - when did you first experience regret about your participation in the murder of Ruth First?

MR RAVEN: I can't give a date on that sir.

MR BERGER: Well, you didn't regret the murder after Craig Williamson congratulated you, am I correct?

MR RAVEN: That could be possible.

MR BERGER: What is possible Mr Raven?

MR RAVEN: The statement you have just made.

MR BERGER: When did you first experience regret, was it a year after, a month after?

MR RAVEN: As I stated, I can't remember.

MR BERGER: Well, I put it to you that after Craig Williamson congratulated you, you had no regret, would that be fair?

MR RAVEN: I can't comment on that.

MR BERGER: You expressed regret yesterday, didn't you?

MR RAVEN: That is correct and I expressed regret when Gillian came to me.

MR BERGER: When Ms Gillian Slovo came to interview you, you expressed regret?

MR RAVEN: That is correct.

MR BERGER: Didn't you say to Ms Slovo that you had no regrets about your time as a Security Policeman?

MR RAVEN: That is correct. We were speaking in general.

CHAIRPERSON: Mr Raven as I understand your evidence, correct me if I am wrong, you at the time thought that such an attack would have been justified?

MR RAVEN: At the time, yes.

CHAIRPERSON: The persons who conducted such an attack, would have had the necessary information to (indistinct) sufficiently prominent activist, that it was part of the war?

MR RAVEN: That is correct.

CHAIRPERSON: That your regret that you expressed is regret that you started to experience later, for the whole unnecessary conflict that existed in our country?

MR RAVEN: That is correct, that was a mindframe we had.

MR BERGER: Well, then why is it so difficult for you to say that at the time Craig Williamson congratulated you about the murder of Ruth First, that you had no regret? Why is that so difficult?

MR RAVEN: I think because you are trying to place it on one specific occurrence, whereas it could have been over the whole situation that was happening in the year 1982.

MR BERGER: Mr Raven, Mr Williamson came to you in 1982, he informed you that your bomb had worked and that it had killed Ruth First and he congratulated you in that regard, correct?

MR RAVEN: Correct.

MR BERGER: When he congratulated you, and you knew that you had participated in the murder of a woman, did you feel any regret, yes or no?

MR RAVEN: Do you say a woman or do you say Ruth First because in fact it was Ruth First. If Ruth First was in the eyes of the powers that be, a legitimate target, there would have been no regret.

MR BERGER: Mr Raven, it is a very simple question really. Did you Mr Jerry Raven, experience any regret when you heard the news that Ruth First had been killed by your bomb, yes or no?

MR RAVEN: No. No.

MR BERGER: Why did it take you so long to give a simple answer?

MR RAVEN: Because I am trying to get everything in the right time frame of the mindset of 1982.

MR BERGER: Well, let's go to 1984. When Craig Williamson informed you that your bomb had killed Jeanette Schoon and Katryn Schoon, did you feel any regret?

MR RAVEN: I felt regret for the death of Katryn, but felt that if the envelope was well addressed to Marius or Jeanette Schoon, that the powers that be, would have thought this is a legitimate target, but not the child.

MR BERGER: So you had no regret about the death of Jeanette Schoon when you heard the news?

MR RAVEN: None.

MR BERGER: You had regret about the death of Katryn Schoon, but you never articulated that regret, correct?

MR RAVEN: I think I articulated it when I asked in my mind, as I put it in my - about the child.

MR BERGER: How did you articulate that regret?

MR RAVEN: I think as I said here on questioning Williamson about the Schoon incident, he said that the letter had been intended for Marius Schoon, but it served them right. Page 109 of bundle 2.

MR BERGER: Where is the regret in your statement Mr Raven?

MR RAVEN: It may not be laid out in black and white here.

MR BERGER: It definitely isn't.

MR RAVEN: But by confronting him with this statement, it implies that I was not happy with what happened there.

MR BERGER: What did you say to Mr Williamson?

MR RAVEN: I can't remember my exact words. It could have been why was the child also killed, or words to that effect. I cannot remember.

MR BERGER: Surely it came as a shock to you that a child had been killed?

MR RAVEN: It did.

MR BERGER: Surely you would remember what you said?

MR RAVEN: No, not necessarily. As I have stated, it is unfortunate but it is a fact of life that in a war situation, innocent people are killed.

MR BERGER: We will come back to that. So you are saying in 1984 you already had regret?

MR RAVEN: For the death of Katryn, yes.

MR BERGER: Why did you tell Ms Gillian Slovo that you had no regrets about your time as a Security Policeman?

MR RAVEN: Because I had no regrets of my time as a Security Policeman in general.

MR BERGER: You said you had no regrets about your time as a Security Policeman. Why didn't you say I have some regrets, but it was a war?

MR RAVEN: I think because at that time, that any statement to that effect outside the forum of this Committee, would have been detrimental to me.

MR BERGER: Just to say yes, I have regrets?

MR RAVEN: Well I said, I said to her I am sorry. Doesn't that imply a regret that I said my heart goes out to you? Does that not imply a regret?

MR BERGER: No, it was false I put to you, it was meaningless and I also put to you ...

CHAIRPERSON: How do you know that? Have you information that it was meaningless?

MR DU PLESSIS: Yes Mr Chairman, and I have to object. I have seen that video and Mr Raven says in that video in that discussion with Gillian Slovo, he says specifically I feel sorry for you, my heart goes out for you.

I find it strange that Mr Berger in the course of his questioning doesn't state that in all fairness to the witness, as well.

CHAIRPERSON: Does that appear in the video Mr Berger, I don't know nothing of any video?

MR BERGER: It does appear in the video.

CHAIRPERSON: So he did express regret, that is surely an expression of regret and you are continually saying why did you not express regret.

Are you being forthright in your questioning?

MR BERGER: Absolutely.

CHAIRPERSON: You have seen something that the Committee has not seen, something you have not disclosed to the Committee and certainly from your questions, I did not gather that there was anything like that in the video.

MR BERGER: Chairperson, I will show the video in a few minutes to the Committee and I just want to ask Mr Raven a few more questions before I show the video.

Mr Raven, correct me if I am wrong, but in the video you said to Ms Slovo, I am sorry about the fact or words to this effect, I am sorry about the fact that your mother died, but I had absolutely nothing to do with it?

MR DU PLESSIS: Mr Chairman, wouldn't the correct procedure be to show the video and then ask the questions, or is this cross-examination by anguish?

CHAIRPERSON: Are you going to show the video?

MR BERGER: I just said I am going to show the video.

CHAIRPERSON: Well, shouldn't you show it and then question the witness, the applicant about it?

MR BERGER: Mr Raven, I am going to show the video now and I want you to observe in the video how you blandly denied any involvement in the death of Ms Ruth First, how you blandly denied the involvement in the death of anyone else and how you were able to lie without batting an eyelid, without shaking, you will see that your hands don't shake, your feet don't shake, you are absolutely composed.

I want you to observe that, and I want you also to observe when Ms Slovo asks you whether you were responsible for the death of her mother.

CHAIRPERSON: Can someone assist that young lady in trying to move. Are you sure?

MR DU PLESSIS: Mr Chairman, may I enquire if the whole video is going to be shown or just snippets of it?

MR BERGER: The entire video is going to be shown.

MR DU PLESSIS: All right, thank you.

MR BERGER: And finally Mr Raven, I want you to observe how, when Ms Slovo comes in and confronts you and says I believe you are the man who made the bomb, you lift your eyelids, your eyebrows in exactly the same way as you lifted them yesterday and as I noted and put on record. Please watch the video.

Chairperson, it lasts for 20 minutes.

CHAIRPERSON: Who made the video?

MR BERGER: The video was made by - it is a filmed recording of an interview which Ms Slovo conducted with Mr Raven, the interview that he has been talking about.

MR DU PLESSIS: Mr Chairman, may I just say that I am in possession of the whole programme that was shown on SABC TV, made by Gillian Slovo about her mother. It is one programme. That programme depicts a whole lot of things, except and apart from the interview.

It is a video that is far longer than 20 minutes and if a video has to be shown, I would request that the whole video is shown Mr Chairman. It will be important because of the fact that Ms Slovo has indicated very clearly in that video, to the extent to which her mother was involved in the freedom struggle, the extent to which she supported the struggle, the extent to which she supported for instance the Church Street bomb, and all sorts of other military activities.

So if a video is to be shown Mr Chairman, I think we have a full copy of the video. We suggest that our copy should be shown.

MR LEVINE: Mr Chairman, I can confirm that to the best of my recollection, the video runs for 51 minutes and 34 seconds.

MR BERGER: Chairperson, if I could be allowed to present this evidence, if my learned friends had evidence which they wanted to present, they could have done so at an appropriate time. In fact my learned friend, Mr Du Plessis informed you Chairperson, that they intended to show this video that was shown on SABC during the re-examination of Mr Williamson, but the video that I am talking about Chairperson, is not the video that was flighted on the SABC.

Part of that video was incorporated in the programme which was flighted on SABC. The video that I am showing is the full, unedited interview that Ms Slovo conducted with Mr Raven, which I submit is more appropriate to Mr Raven's cross-examination than the video that my learned friends are talking about.

Please can I show it?

CHAIRPERSON: Carry on.

MR BERGER: And Chairperson ...

CHAIRPERSON: As I understand it, Ms Slovo is going to give evidence?

MR BERGER: Indeed.

CHAIRPERSON: And if Mr Du Plessis, you desire to question her, you have the video, you can put it to her and question her on it. I don't think you can compel to put it in at this stage when all we are doing is questioning Mr Raven.

MR DU PLESSIS: Yes, no I have no objection, especially if it is the full video Mr Chairman.

MR BERGER: But I said that.

MR DU PLESSIS: Yes, but I am saying that I have no objections, thank you very much.

MR BERGER: Chairperson, I don't know if any members of the public are going to want to move perhaps, they can move in advance.

CHAIRPERSON: If anybody in the rear of the television screen wants to come forward and watch, they can do so. There are one or two chairs available on this side of the screen, so they can see what is being shown.

MR BERGER SHOWS VIDEO OF INTERVIEW DONE BY MS GILLIAN SLOVO: .

CHAIRPERSON: Can you tell us who the third party was, who was apparently present during that interview, whom they avoided photographing?

MR BERGER: They didn't avoid photographing that person, he was the camera person.

CHAIRPERSON: Was he the person who spoke about Dirk Coetzee?

MR BERGER: And there was a person holding the sound boom, those ...

CHAIRPERSON: Someone intervened, he was talking about Dirk Coetzee and Mr Raven turned and spoke to this other person. Who was that?

MR BERGER: The camera person.

CHAIRPERSON: Who was he?

MR BERGER: Dewald Aukema. Aukema, we think. Mr Raven, do you confirm that what you have just witnessed is a complete tape of the interview that Ms Slovo had with you?

MR RAVEN: I confirm that.

MR BERGER: And do you confirm that that interview was conducted in April or May of 1996?

MR RAVEN: I can't remember the date, but if that is the date you say, I concede.

MR BERGER: You stated on that video tape that Craig Williamson has said some wild and wonderful things. What were you referring to?

MR RAVEN: That statement that I made there, was a complete denial of anything that Craig had said, knowing that some of the things he said was true, as in the case of the London bomb, where he names us.

But in the shop, in front of unknown people, that is not the forum to make any confessions of anything which may have happened in the past. That was the forum for such exposures would be here at either the Committee or the TRC, not in front of complete strangers.

MR BERGER: But you knew who Ms Slovo was, didn't you?

MR RAVEN: I knew the name.

MR BERGER: You knew that she was the daughter, that she is the daughter of Ruth First?

MR RAVEN: Yes, I knew that.

CHAIRPERSON: She said who she was. Did you in fact know who she was when she arrived?

MR RAVEN: I had never seen her with my eyes before.

CHAIRPERSON: Because the tape commenced with the words, he doesn't know we are coming. So she hadn't arranged to see you, this person just appeared before you and told you who she was?

MR RAVEN: That is correct.

MR BERGER: Did you know of her existence before she introduced herself to you?

MR RAVEN: Yes, I knew of her existence.

MR BERGER: And you knew that Craig Williamson had named you as the person responsible for making the bomb that killed Ruth First?

MR RAVEN: No, I think in the other tape that Mr Du Plessis spoke about, in the interview she had with Craig over the telephone, she said a name that Craig dropped, was the name of Jerry Raven, the bomb - the person who built the bomb.

I listened to that interview on the tape and I couldn't hear my name mentioned at all.

MR BERGER: You say that this wasn't the proper forum to make, to confess?

MR RAVEN: That is correct.

MR BERGER: And the proper forum was the TRC and the Amnesty Committee?

MR RAVEN: That is correct.

MR BERGER: You recall I asked you yesterday, I said that during this interview, Ms Slovo asked you what would you do if Craig Williamson names you at the TRC and you said that you would deny it. Do you remember I asked you that question yesterday?

MR RAVEN: No, I don't remember that question.

MR BERGER: And you said no, she never asked me that question.

MR RAVEN: Quite frankly, I can't remember that question.

MR DU PLESSIS: Mr Chairman, I think he said he can't remember. I can't remember but my Attorney remembers that Mr Chairman.

MR BERGER: That question was definitely asked Mr Raven, and you said it wasn't asked during the interview.

ADV DE JAGER: My note is that I can't remember that she discussed the TRC or what I would say if Craig names you at the TRC.

MR BERGER: Mr Raven, do you remember the question now?

MR RAVEN: I can't remember her asking that question.

MR BERGER: No, do you remember that I asked you the question yesterday?

MR RAVEN: Well, if the Committee has it on record, then it was asked. I physically can't remember it.

MR BERGER: The point is that you said you would deny it. You saw that on tape this morning?

MR DU PLESSIS: No Mr Chairman, as I understood you, you said that the answer was that he said he can't remember.

MR BERGER: No, I am moving on, I am talking about the tape.

MR DU PLESSIS: All right.

MR BERGER: In the tape Ms Slovo says what will you do if Craig Williamson names you at the TRC and you say I will deny it. You saw that?

MR RAVEN: Yes.

MR BERGER: You said I have nothing to ask amnesty for?

MR RAVEN: Yes.

MR BERGER: Part of this video you have seen before you gave evidence today, am I right?

MR RAVEN: That is correct, it was the video that was on television, South African television.

MR BERGER: Yes, and the video that my learned friend has been referring to this morning?

MR RAVEN: That is correct.

MR BERGER: And you saw that how long ago?

MR RAVEN: It could have been about a week ago.

MR BERGER: Sorry Mr Raven, so from April or May of 1996, we know at the very latest from then, until May of 1997 when you finally submitted your application for amnesty, you knew that you would have to answer at the TRC for your role in the killing of Ruth First, Jeanette Schoon, Katryn Schoon?

MR RAVEN: Yes, that is correct, but the date is incorrect.

MR BERGER: Which date is incorrect?

MR RAVEN: I think you said May, am I correct. I think I said it was in December 1996.

MR BERGER: You said what was in December of 1996?

MR RAVEN: When I made my statement for the TRC.

MR BERGER: If you have a look at page 26 of bundle 1, you will see that your application was received by the TRC on the 9th of May 1997.

MR RAVEN: If you look on page 114 of bundle 2, it was signed in December the 11th, 1996. That was when the document was made.

MR BERGER: So why did it take you from December 1996 until May of 1997 to submit your application for amnesty.

CHAIRPERSON: I regret to say that I do not think it is safe to assume that the date the date stamp was put on by the TRC, is the date that the document was received.

As those of you who have had dealings with the Amnesty Committee from the beginning know, there was a shambles at the office in Cape Town at the commencement, files were piled up all over the place. I think it will be extremely dangerous to make use of a date in that way.

MR BERGER: I will accept that. Mr Raven, so you made your application, you signed your application in December of 1996?

MR RAVEN: That is correct.

MR BERGER: What changed between April/May of 1996 and December of 1996?

MR RAVEN: I don't understand your question.

MR BERGER: Well in April of 1996 you were not going to make application for amnesty.

MR RAVEN: Are you talking about now the time of the tape recording, of the video?

MR BERGER: Correct.

MR RAVEN: As I stated, that was not the forum, I was not going to admit anything to anybody. It was a silly thing to do to admit to anything to a total stranger that walked in with two people and as we have before us here, my submission, I had come and I have said and I have admitted to what I have done.

MR BERGER: So you had plenty of time to formulate your application for amnesty, am I correct?

MR RAVEN: I didn't have all that much time.

MR BERGER: Well, you were probably thinking about an application for amnesty before Ms Slovo came to see you, because Mr Williamson had gone public in February of 1995? Am I right?

MR RAVEN: If you say so, I don't remember the date.

MR BERGER: So from February of 1995 until December of 1996, that is plenty of time to formulate an application for amnesty, wouldn't you say?

MR RAVEN: If I had that in mind. At that time, my mind frame was that these acts had been committed, specifically the London bomb, no one had approached me and said hell Jerry, come we better get together and do something about this and find some lawyers.

At a later stage that I think under correction, I think it was Colonel Waal du Toit that came to me and said Jerry, have you got an Attorney for the TRC and I said no, no one has come to me at all and suggested listen, use this guy, use that guy and he asked me if he could then give my name as reference to my Attorney and I said please do that.

After that I had my first consultation, the date of which I can't remember.

MR BERGER: When did you decide to apply for amnesty?

MR RAVEN: When Colonel Waal du Toit brought it to my attention, he said listen Jerry, you better do something about this now, because the cut off time is coming close.

MR BERGER: When did Mr Du Toit say that to you?

MR RAVEN: I don't remember the date.

MR BERGER: So it was as a result of that that you decided, well, I better apply for amnesty?

MR RAVEN: That is correct.

MR BERGER: Just because he said you better apply for amnesty?

MR RAVEN: No please, I mean, I knew all these things would be coming out, I would have to apply for amnesty at a stage. It was just that the date came up, it was coming up closer to the cut off date and Waal came and he said listen Jerry, you better come and do it now, here is the guy to go and see. Because I had no knowledge of any of the Attorneys who would be handling these applications.

MR BERGER: Any Attorney can handle an application.

MR RAVEN: Well, I don't know any Attorney.

MR BERGER: You didn't know any Attorney and you didn't know how to get any Attorney?

MR RAVEN: No, I could have picked the telephone book and phoned one, but I would have liked to have been referred to one.

MR BERGER: Well, did you ask any of your colleagues, erstwhile colleagues what are you guys doing about amnesty?

MR RAVEN: I had no contact with any of my erstwhile colleagues.

MR BERGER: You couldn't phone Mr Craig Williamson because you didn't have a Johannesburg telephone directory?

CHAIRPERSON: Wasn't Mr Waal du Toit an erstwhile colleague?

MR RAVEN: Yes, he is the one that came into the shop that day.

MR BERGER: Then why didn't you ask him?

MR RAVEN: I didn't ask him, he told me.

MR BERGER: No, but beforehand? Mr Raven ...

MR RAVEN: But I never saw him beforehand. I saw him on that occasion when he came in to the shop.

MR BERGER: You had no contact with any of your erstwhile colleagues and you didn't know how to contact any of them, is that your evidence?

MR RAVEN: As far as I can recollect, yes.

MR BERGER: Mr Raven, it is not that long ago. This is an important event in your life, you have been named, there are amnesty hearings coming up, if you don't get your application in in time, you know that you are liable to be prosecuted. Surely that focused your mind on what do I have to do to get amnesty?

MR RAVEN: And as I said Waal du Toit came to me, he gave me my Attorney's name and I went to, I went an appointment, I went and saw him.

MR BERGER: So if Mr Waal du Toit had not come into your shop on that day, you would not have applied for amnesty?

MR RAVEN: I never said that.

MR BERGER: Isn't there a Department in the Police which has contact addresses for all people who have previously served in the Police?

MR RAVEN: Not as far as I know.

MR BERGER: You didn't know that?

MR RAVEN: That people that have left the Police Force, they have their addressed?

MR BERGER: Indeed.

MR RAVEN: I don't believe such a Section existed because in the time since I have been out, I have never received any messages or saying right, please if you change your address, send that in. I don't believe such a Section exists.

MR BERGER: If Mr Waal du Toit had not fortuitously come into your shop to talk about amnesty, you would not have taken any steps to apply for amnesty?

MR RAVEN: I would have taken steps. As I said, I would have then gone out and made a real effort to find out who is the best person to go and see.

MR BERGER: But the date was fast approaching, the first cut off date?

MR RAVEN: As I said, I can't give you date, time, place, it was approaching.

MR BERGER: I want to suggest to you Mr Raven, that you were really, you were fully aware of the fact that you might have to apply for amnesty.

MR RAVEN: I knew I would have to apply.

MR BERGER: Yes, and you were waiting to see what comes out, who is going to apply, what do I need to do, what do I need to say. So you waited until the last moment to see what was already known, am I right?

MR RAVEN: No.

MR BERGER: Can you explain your comment to Ms Slovo where you said I will wait and see what happens in relation to the TRC? Isn't that what you did?

MR RAVEN: No. It could have been in the case of, I seem to remember at the stage there was some talk of blanket amnesty for both sides and I could have been referring to that, to see if that blanket amnesty came about.

If it didn't, naturally I would have to go before the TRC, I would have to go see a lawyer, I would have to draw up these applications.

MR BERGER: Please continue.

MR RAVEN: I have just answered your question.

MR DU PLESSIS: Mr Chairman, may we perhaps just for Mr Berger's sake and interest, and to assist him in this regard and to assist the Committee in this regard, we have a note in my Attorney's file that the first date of consultation was the 6th of November 1996.

All our clients' applications were signed in December, or most of them, in December. They were all handed in in May, the cut off date.

CHAIRPERSON: It was in May?

MR DU PLESSIS: It was in May and I believe the same situation pertain to Mr Wagener's clients, except that his applications went in in December. His applications went in in December, but they were all handed in at the last time and there was a big rush in December, after the Cronje hearings in this regard Mr Chairman.

ADV DE JAGER: The first cut off date was in December.

MR DU PLESSIS: Yes.

ADV DE JAGER: I think somewhere ...

MR DU PLESSIS: The 14th of December.

ADV DE JAGER: The 14th of December, yes. And then the date was extended to somewhere in May of the next year.

MR DU PLESSIS: Yes, just to make that clear Mr Chairman. I don't want to object to Mr Berger's line of cross-examination because I think he is wasting time Mr Chairman, with respect, but it is going nowhere. I don't know what the intention of the cross-examination is, I don't know what he is trying to achieve.

CHAIRPERSON: I also noticed that during the tape at the time he is referring to, mention was made also of indemnity. Perhaps some regard should be had to the fact that prior to amnesty, there was an Indemnity Act which also had a cut off date.

I regret I don't have my copy of the Act with me, but we think it was probably in 1992, I don't know if Mr Bizos can remember when the indemnity cut off was.

There was an earlier cut off date before one got to the amnesty cut off date?

MR BIZOS: Yes, it was the 1990 or 1991 Indemnity Act Mr Chairman and then the second Indemnity Act was passed with a limited period, with authority to extend it. But I don't remember whether it was extended into 1993 or not.

ADV DE JAGER: I think it was extended until October 1992, somewhere in October if my recollection is correct and I've got a note.

MR BIZOS: If you have the schedule of the amending Acts, the schedule of the amending Acts, at the end of the present Act gives the dates. They are referred to also in one of the last sections that their contents will be taken into consideration. Section 20 and it may be that the amendments and extensions of those are at the end of Section 20 Mr Chairman.

MR LEVINE: Mr Chairman, I think it is Section 48.

CHAIRPERSON: That merely repeals the Act, it doesn't give the dates of the cut off dates.

MR DU PLESSIS: Mr Chairman, I will have that on my little computer which is unfortunately in the car, perhaps after tea I might ...

CHAIRPERSON: Well, I don't think the date is of vital importance at the present stage. I merely draw attention to the fact that there had been a cut off, earlier cut off date before the amnesty cut off date.

ADV DE JAGER: The Indemnity Act was Act 151 of 1992.

MR BIZOS: For a year.

ADV DE JAGER: Yes.

CHAIRPERSON: The Indemnity Act itself was Act 35 of 1990, the Indemnity Amendment Act was 124 of 1992 and the Further Indemnity Act was 151 of 1992.

MR BIZOS: May I say Mr Chairman, that the word indemnity was in fact used, but I think it was used by Ms Slovo and she will tell you Mr Chairman, in due course, that she didn't make the nice distinction between indemnity and amnesty.

MR BERGER: Mr Raven, it wasn't you who mentioned indemnity was it?

MR RAVEN: Well, we heard now it wasn't me, then it wasn't me.

MR BERGER: Mr Waal du Toit's application is dated the 20th of December 1996, which would have been after the first cut off date. So it is your evidence Mr Raven that Mr Waal du Toit came to you before the first cut off date in early November and said Jerry, you better do something about applying for amnesty and then he did nothing about applying for amnesty until after the first cut off date, is that your evidence Mr Raven?

MR RAVEN: I don't know what the date of his amnesty application is.

MR BERGER: Well, I can show you if you have a look at page...

CHAIRPERSON: Can you say he did nothing if he consulted Attorneys, gave them all the information and left it to them to complete the forms? He had done something.

MR BERGER: Who Chairperson?

CHAIRPERSON: Mr Waal du Toit, you said he did nothing but he may have consulted his Attorneys, he might have done a great deal. You don't know.

MR BERGER: Mr Chairperson, his application was only signed on the 20th of October?

CHAIRPERSON: Yes, that doesn't mean he didn't consult his Attorneys three months before.

MR BERGER: Point taken.

MR DU PLESSIS: Mr Chairman, just to help Mr Berger again. Mr Waal du Toit together with Mr Raven arrived at Mr Britz' office. During that period there was a group of about 25 prospective applicants and from there on consultations were held with separate applicants.

Mr Waal du Toit is not Mr Britz' client any more, but that is what happened.

MR BERGER: Mr Raven, who were the people that you arrived at Mr Britz' office with?

MR RAVEN: I arrived by myself. I drove there by myself, I was alone in the car.

MR BERGER: Yes, but there was an arrangement that 25 of you would meet at Mr Britz' office?

MR RAVEN: I know of no such arrangements. I arrived and there were people there.

MR BERGER: Isn't it correct Mr Raven, that the purpose of your waiting and not going to see an Attorney in 1995 or in 1996, April, May, June, July all the way up to October, the purpose of your delay was to wait and see who came forward, who said what and what you would have to disclose in the light of that.

Isn't that really why you delayed?

MR RAVEN: Not at all.

MR BERGER: Isn't that really what you meant when you said to Ms Slovo I will wait and see what happens?

MR RAVEN: Not at all.

MR BERGER: And isn't it correct that if Gen Coetzee had admitted responsibility in the deaths of Ruth First, Jeanette and Katryn Schoon, you would have included him in that, am I right?

MR RAVEN: I don't understand your line there?

MR BERGER: What I am saying to you is you only disclosed as much information as you thought was necessary to disclose in the light of what everyone else was saying, isn't that right?

MR RAVEN: No, I only disclosed what I knew to be facts.

MR BOOYENS: Mr Chairman, not an objection but just to rectify something put by my learned friend. At page 200 of volume 3 it is Mr Du Toit's application, it is not the 20th day of December, but if you look at it you will see what is written there is the 2nd. It is the second day of December. If you take that as two 0's, it looks like the 200th day of December.

MR BERGER: I will accept that. My point still remains Mr Raven, your unexplained delay can only be for one reason and I have already put that to you.

ADV DE JAGER: Mr Berger, in all fairness, if an Act allows you to make application before the 15th of a certain date, it is right you have got, you are entitled to wait up till that day.

MR BERGER: Absolutely.

ADV DE JAGER: So if the Act said you are entitled to make application until the 1st of January and you would wait until the 30th of December, you are waiting until the 30th of December if you wanted to. Or you could make it in October if you want to.

MR BERGER: Absolutely, I am not saying that there is anything technically wrong with that, what I am putting to the witness goes to his state of mind, as to what he was prepared to disclose and when he was prepared to make a clean breast of it.

The proposition I am putting to the witness is that he was only prepared to disclose what was already public knowledge, so he kept it back to see what else would come into the public arena and only when it became essential for him to submit his application, did he do so.

MR SIBANYONI: I am sorry Mr Du Plessis, one question Mr Raven. When you went to Mr Britz, was it your first attempt to contact or consult an Attorney to take the TRC process?

MR RAVEN: That is correct yes.

MR DU PLESSIS: Mr Chairman, my learned friend says what was already public knowledge. I don't know does he refer to the contents of the amnesty applications or what does he refer to when he says that?

MR BERGER: When I say public knowledge, I don't mean in the public arena, I mean within the arena of the Security Policemen, who was saying what, what was coming forth?

MR DU PLESSIS: What does my learned friend know about that Mr Chairman, with respect, I object against that kind of comment.

MR BERGER: My learned friend has told you Chairperson, that they had the amnesty applications of a number of people, we know at least of 25 which were held back until the last moment in May of 1997, and they were all being represented by the same Attorney.

My learned friend himself has said that.

MR DU PLESSIS: I never said Mr Chairman, that all the applicants read each other's applications. I never said that.

CHAIRPERSON: Apparently the presumption is that if an Attorney acts for various clients, he discloses to one another what would interest them and has no regard for the privacy of his clients. That is what the question appears to be based on? Have you any authority for saying that Mr Britz would have disclosed to all of his clients what the others had said?

MR BERGER: Where the clients are all involved in the same transaction, Chairperson ...

CHAIRPERSON: The 25, what transaction are we talking about now?

MR BERGER: The London bomb for example.

CHAIRPERSON: Yes, you say he would disclose to each separate client what the others have told him?

MR BERGER: No, but it is natural that the clients would have...

CHAIRPERSON: It is not natural that Attorneys would, I don't think it is natural. I may be a little old fashioned, I do not think it is natural for Attorneys to disclose confidential information given to them by a client to other clients.

If you have evidence to say they came as a group and applied as a group, that is a different matter. The fact that they came there at the same time, does not imply that they were there as a group in my view.

MR DU PLESSIS: In any event Mr Chairman, we only represent Mr Raven in these proceedings. The other applicants are involved in other proceedings.

MR BERGER: Chairperson, my learned friend yesterday told you that the amnesty applications of all his clients, were put together in such a way that when it came to for example political motive, there was a generalised approach.

CHAIRPERSON: They put in a general thing about political motives in those matters, he did not suggest that they disclosed the personal details of each application to one another, did he? And you are now putting that.

MR BERGER: Chairperson, there had to be a consultation with all of them, so that their political motive at least, was constant?

CHAIRPERSON: He doesn't, he tells them. He has settled what he considers to be the best possible wording which he then uses in each application he draws up, isn't that the evidence? Isn't that what was suggested?

MR BERGER: There is no evidence of that Chairperson.

CHAIRPERSON: It was, we had evidence yesterday that the Attorney put in that political motivation and the other general things.

MR BERGER: Chairperson, I won't take this point further. Mr Raven, you talk about the need to know and you say that that is why you don't know more than you have already disclosed, correct?

MR RAVEN: Correct.

MR BERGER: Now, why did you need to know that the authority for the London bomb came from Gen Coetzee?

MR RAVEN: I didn't know it at the time.

MR BERGER: At page 162 of bundle 3, do you have it?

MR RAVEN: I have it.

MR BERGER: You talk about catching a flight to Frankfurt. On arrival at Frankfurt I saw the rest of the team. We all managed to get on the same flight to South Africa.

MR RAVEN: That is correct.

MR BERGER: Upon our return, we were summoned to the office of Gen Johan Coetzee, Head of the Security Branch?

MR RAVEN: That is correct.

MR BERGER: His greeting words were "yes Raven, you have once again laid a rotten egg". Thinking the device had been discovered or had malfunctioned, I was very dejected.

MR RAVEN: Correct.

MR BERGER: That is all that was said in that meeting?

MR RAVEN: As far as I can remember, yes.

MR BERGER: So how did you know that Gen Coetzee had given authority for the London bomb?

MR RAVEN: I am not implicating here at all that he gave authority for it. I am saying we were called in after the fact, and congratulated.

MR BERGER: No, you weren't congratulated?

MR RAVEN: Or whatever, well.

MR BERGER: In fact, it was quite the opposite?

MR RAVEN: Yes.

MR BERGER: So what knowledge did Gen Coetzee have?

MR RAVEN: I can't speak on behalf of Gen Coetzee. I can't say yes, he knew about it before the fact, but it is quite obvious that he knew about it after the fact.

MR BERGER: You weren't told before the fact that the authority for the London bomb had come from up high?

MR RAVEN: I presumed it came from up high.

MR BERGER: You weren't told?

MR RAVEN: Not that I can recollect.

MR BERGER: You weren't told by Mr Williamson that Gen Coetzee had given authority for the London bomb?

MR RAVEN: I cannot recollect that.

MR BERGER: You cannot recollect that, but you can't deny it?

MR RAVEN: That is what I said. I cannot recollect that he said that.

MR BERGER: You cannot recollect that before the London bomb, Craig Williamson informed you that it had Cabinet approval or the Minister of Police's approval?

MR RAVEN: That is correct.

MR BERGER: What, you can't recollect?

MR RAVEN: I can't recollect that.

MR BERGER: But you can't deny it?

MR RAVEN: If I can't recollect it, I can't deny it.

MR BERGER: What about the need to know? Why did you need to know that Gen Coetzee had approved of the London bomb?

CHAIRPERSON: He said he doesn't know if he knew. How can you now ask him why did you need to know? If he did not know, listen to the answers to the questions you are putting.

MR BERGER: Chairperson, I am listening to the answers to my questions. Mr Raven, why should Gen Coetzee say to you, "yes Raven, once again you have laid a rotten egg"?

MR RAVEN: I don't know.

MR BERGER: That statement to you would have disclosed that Gen Coetzee knew about the London bomb, knew about the operation?

MR RAVEN: Can you explain how I would know that?

MR BERGER: Yes. Because in the very next sentence you say thinking the device had been discovered or had malfunctioned, I was very dejected. So you knew that he was referring to the London bomb, that is how.

MR RAVEN: Correct, and I agree with you.

MR BERGER: So then I go back to my question, when he said to you "yes Raven, you have once again laid a rotten egg", you knew that Gen Coetzee knew about the London operation?

MR RAVEN: That is after the fact. As I said after the fact, it is possible that he knew about it.

I couldn't say before the fact, if he knew about it or not, because it wasn't necessary for me to know about it.

MR BERGER: Why should Gen Coetzee disclose to you, a Warrant Officer, that he knew about the London bomb?

MR RAVEN: Because it wasn't necessary any longer, he couldn't contaminate or I couldn't contaminate or nobody else could contaminate the fact that the South African government had carried out this operation within the circle.

MR BERGER: So after the event, one can breach the need to know rule?

MR RAVEN: No, because this was said within the group of people who were in the operation. It wasn't said to a stranger who was in the office as well, and say here are the guys that blew up the London office.

MR BERGER: No, but you see before the operation you didn't know that Gen Coetzee knew?

MR RAVEN: Correct.

MR BERGER: After the operation, you didn't need to know that Gen Coetzee knew.

MR RAVEN: But if Gen Coetzee decided that he wanted to congratulate me, because he is a senior officer, I do not find that strange.

CHAIRPERSON: What Counsel has put to you before and you now have come to the same, that you didn't think it strange that Gen Coetzee as a senior officer wanted to congratulate you, but what you have said in your application was that he said "you have again laid a rotten egg", which is hardly congratulating you.

MR RAVEN: I should have put it in here that he said it jocularly.

CHAIRPERSON: Because you said, thinking the device had been discovered or had malfunctioned, I was very dejected. That is hardly the reaction to something that was said jocularly, is it? You were very dejected by what he said, you didn't think he was joking?

MR RAVEN: I will concede to that Mr Chairman.

MR BERGER: Well, then why did you a minute ago say that he said it jocularly?

MR RAVEN: Because that is how I remember it.

MR BERGER: No Mr Raven, that is not how you remember it. How you remember it is that he wasn't joking. You were very dejected.

MR RAVEN: Well, if he said it as a reprimand, surely he wouldn't have said "you have already laid a rotten egg", surely he would have then used the terms and reprimanded me.

MR BERGER: You see, Mr Raven, you are just changing your evidence as you go along, to fit in with what you think is the best possible answer. Isn't that what you are doing now?

MR RAVEN: I can't see how I can change what is on here, because this is what happened.

MR BERGER: You knew at the time that you wrote this, that Gen Coetzee had applied for amnesty for the London bomb, am I right?

MR RAVEN: I don't think I knew that.

MR BERGER: What did Gen Coetzee mean when he said once again, what was he referring to?

MR RAVEN: I think we have been through that. I can't say what he meant when he said that.

MR BERGER: He is referring to other incidents in which you have been involved and which you haven't disclosed, isn't that the obvious inference?

MR RAVEN: It would seem the obvious inference to that remark.

ADV DE JAGER: It would at least refer once again, that the others were also failed attempts because if it is referring to rotten eggs, it wasn't attempts that succeeded?

MR BERGER: Yes, some of them may well have been failed attempts. Did you make any other attempts at blowing up anyone or anything?

MR RAVEN: No, I did not.

MR BERGER: Unsuccessful attempts?

MR RAVEN: No, I did not.

MR BERGER: But you never asked the General what he was referring to?

MR RAVEN: No, I didn't.

MR BERGER: Why not?

MR RAVEN: It was not my place to question a senior officer.

MR BERGER: But you thought he was joking.

MR RAVEN: It was still not my place to question a senior officer.

MR BERGER: Or you didn't think he was joking, you thought he was serious and that is why you were dejected.

MR RAVEN: It is still not my place to question a senior officer.

MR BERGER: You see what I am suggesting to you is that, or what it appears to be the fact Mr Raven, is that need to know on your own evidence falls away after the mission has been successfully completed?

MR RAVEN: Not at all.

CHAIRPERSON: I can understand you saying Mr Raven that it is not your function to question a senior officer, but here a senior officer who is apparently saying that you had failed in your task, was it not perfectly proper for you to say I am very sorry Colonel, what went wrong with it?

MR RAVEN: That could be the case Mr Chairman, but I didn't question him.

MR BERGER: Well, who did you question?

MR RAVEN: I didn't question anybody.

MR BERGER: Who was in the office?

MR RAVEN: I think the team that was in London.

MR BERGER: Who was that?

MR RAVEN: Mr Williamson, Mr De Kock, Mr Adam, Mr McPherson and myself as far as I can remember.

MR BERGER: Now Mr Williamson knew that the bomb had gone off?

MR RAVEN: No, I don't think Mr Williamson had returned to South Africa at that time, so excuse me, because then Brigadier Goosen would have been in the office as well. I don't think Mr Williamson was there.

MR BERGER: You see, that is why I asked you the question Mr Raven.

MR RAVEN: I would have said Brigadier Goosen, if the whole team was there, which I left out, so I am sorry, Mr Williamson wasn't there then.

MR BERGER: Why - oh so, the team that was summoned to the office of Gen Johan Coetzee, were all the junior members of the team. The person in charge, Brigadier Goosen and his second in command, Captain Williamson, were not summoned to Gen Coetzee's office?

MR RAVEN: If I remember correctly, this happened when we landed in South Africa, we were taken immediately to the General's office.

If I remember correctly Mr Williamson and Mr Goosen was still overseas. They hadn't returned yet.

MR BERGER: And all that happened was you went into Gen Coetzee's office, he said "yes Raven, you have once again laid a rotten egg"?

MR RAVEN: He might have said other things as well which I can't recollect.

MR BERGER: But nobody mentioned the fact or you definitely did not get the impression that the mission had been successful?

MR RAVEN: At that time, with that remark, I was under the impression because we had heard no news, I was under the impression that something had gone wrong.

MR BERGER: Yes. Not only that remark, but the entire tenor of the meeting was such that you thought the mission had been unsuccessful?

MR RAVEN: I wouldn't say the whole tenor of the meeting, I would say the words uttered by the General, gave me that impression.

I can't remember what the tenure of the meeting was, if it was tea and cakes we were having, I can't remember.

MR BERGER: Well you see, if the tenure of the meeting was that the mission had been successful, then I put it to you, you would not have thought that the device had been discovered or had malfunctioned, and you would not have been very dejected.

MR RAVEN: As I said I don't know what the tenure of the meeting was, these are the words that were uttered to me and that is how I felt about it and that is what I thought.

MR BERGER: In the interview with Ms Slovo, right towards the end, you mention again need to know and you said to Ms Slovo everyone covers themselves. Do you remember that?

MR RAVEN: Yes.

MR BERGER: And isn't that what you are doing now in relation to the bombs which were sent to Ruth First and to Jeanette and Katryn Schoon?

MR RAVEN: How do you mean I am covering myself? I have admitted to it.

MR BERGER: Because you have put yourself between a self confessed murderer, Mr Williamson, and a dead man. Haven't you covered yourself Mr Raven?

MR RAVEN: I don't understand what you are saying.

CHAIRPERSON: Nor do I. Do you gentlemen?

MR BERGER: I will explain. Your version about the large official envelope which is not mentioned anywhere in your amnesty application, is a fabrication, is it not?

MR RAVEN: No, it is not. Because I didn't mention it in my application, does not mean that it didn't happen.

MR BERGER: You mentioned it in your evidence because Mr Williamson mentions it in his evidence?

MR RAVEN: We are going back 16 years. One's mind does get rusty.

MR DU PLESSIS: Mr Chairman, in all fairness to the witness, perhaps my learned friend should also put that he did mention the same in the video.

MR BERGER: I beg your pardon?

MR DU PLESSIS: He mentioned the envelope in the video. He mentioned the envelope in the video, before the amnesty application was done in April 1996.

MR BERGER: No, my learned friend is incorrect. I am referring to the large official envelope.

MR DU PLESSIS: All right, he mentioned the envelopes. I just have to put that.

MR BERGER: No. In the video he says that an envelope with no name on it, could be placed into another envelope which could then be sent on.

I am not talking about that, I am talking about the large official envelope and we have made it very clear. In fact my learned friend made it very clear that the large official envelope is not the intercepted item.

MR DU PLESSIS: All right, if we are clear on that, thank you Mr Chairman.

MR BERGER: That is what I said. Mr Raven, nowhere, not in the interview with Ms Slovo, not in your amnesty application in relation to the death of Ruth First, nor in your amnesty application in relation to the death of Jeanette and Katryn Schoon, do you mention the large official envelope, correct?

MR RAVEN: Correct.

MR BERGER: The reason you don't do that, is because it wasn't there, correct?

MR RAVEN: Incorrect.

MR BERGER: The reason that you do it now is because Mr Williamson mentions it in his amnesty application, and in his evidence, and you are accommodating his version in yours, correct?

MR RAVEN: Incorrect.

MR BERGER: And you see what I want to suggest to you is that on the probabilities it couldn't have happened the way you and Mr Williamson say it happened. It couldn't have happened that there was just an order which came from Brigadier Goosen to Mr Williamson, ask Jerry if he can make a bomb.

Do you agree or disagree?

MR RAVEN: I disagree.

MR BERGER: What I am going to suggest to you is that there had to be a discussion amongst the interested people involved, or as you described in relation to the London bomb, the circle of people involved in this operation. There had to be a discussion about we have now got this intercepted item, what can we do with it, will it be effective, and at that discussion, I suggest to you, there would have been you, there would have been Mr Williamson, there would have been Brigadier Goosen and there would have been the Head of the Security Police, Gen Coetzee?

And then there would have been this whole discussion about whether Ruth First was a legitimate target, whether you would achieve any aims. Isn't that what happened?

MR RAVEN: No, it is not.

CHAIRPERSON: Why could that discussion not have taken place elsewhere, and they decided let's see if somebody can make a bomb that fits into this envelope and then asked?

Have you any evidence to suggest that there was such a discussion?

MR BERGER: Chairperson, I prefaced this remarks ...

CHAIRPERSON: Or is this another conclusion of yours?

MR BERGER: Chairperson, with respect, that is an unfair comment because I prefaced my remarks to the witness by saying, on the probabilities.

MR SIBANYONI: Mr Raven, just for clarity, at the almost beginning of your evidence, I heard you saying after Mr Craig Williamson called you to his office, he requested you to manufacture a bomb.

He didn't tell you where the intercepted post was going to, but you assumed that it was going to a high ranking official of the ANC. On what did you base your assumption? Had there been any discussions before that bomb should be sent to some high ranking officials of the liberation movement?

MR RAVEN: No, no discussions were made, but it would be a futile exercise if this IED was sent to a nonentity. To have the effect of demoralising the enemy, one would have to take out or eliminate a high ranking or well publicised target, otherwise it would be pointless.

MR SIBANYONI: You said you were also involved in either tracking down organised crime. Wouldn't this bomb be targeted to some of those?

MR RAVEN: No, when I talk about organised crime, it was help given to them in bugging telephones and I think at one or other stage, some computer access that I had in my capacity in counter-espionage that we could help them with certain particulars on suspects.

MR SIBANYONI: Thank you.

MR BERGER: Mr Williamson told you that Brigadier Goosen had asked him, that is Mr Williamson, to ask you if you could make an IED to fit into the intercepted mail item, am I correct?

MR RAVEN: Correct.

MR BERGER: If one applies need to know, you did not need to know that Brigadier Goosen requested Mr Williamson to ask you to make a bomb, am I right?

MR RAVEN: No, you are not right. It was Major Craig Williamson's prerogative to tell me where his orders came from and not mine to question him and to say why do you tell me that Brigadier Goosen gave you the order.

MR BERGER: Why did you need to know, my question is on need to know, why did you need to know that the orders came from Brigadier Goosen?

MR RAVEN: I haven't the faintest idea.

MR BERGER: You will agree with me, you did not need to know?

MR RAVEN: I did not need to know.

MR BERGER: But Craig Williamson breached that?

MR RAVEN: That is correct.

MR BERGER: Why don't you mention that in your amnesty application?

MR RAVEN: I don't see the relevance of it.

MR BERGER: Well, you will see that nowhere in your amnesty application is mention made of Brigadier Goosen. I am talking about your application in relation to the death of Ruth First and your application in relation to the death of Jeanette and Katryn Schoon.

Do you want to check?

MR RAVEN: I am checking.

ADV DE JAGER: Do I understand you correctly, are you referring now to the fact that Goosen's name wasn't mentioned by him?

MR BERGER: Yes.

ADV DE JAGER: That is the ...

MR BERGER: I can help you Mr Raven, if you turn to page 48 of bundle 1. Do you have it?

MR RAVEN: Yes.

MR BERGER: Paragraph 11(a)?

MR RAVEN: Yes.

MR BERGER: This is in relation to the death of Ruth First. Was the act, I am leaving out words, committed in the execution of an order, of or on behalf of or with the approval of the Security Force concerned and you say Craig Williamson.

MR RAVEN: That is who I received the order from.

MR BERGER: And have a look at page 112 of bundle 2, question 11(a), the same question, Craig Williamson?

MR RAVEN: Correct.

MR BERGER: Now, you were checking to see if perhaps you did mention Brigadier Goosen somewhere in the application, am I right?

MR RAVEN: I was just checking to see if what you said, was correct and it is correct.

MR BERGER: So my question to you is why did you not make any mention of Brigadier Goosen in either of your applications?

MR RAVEN: Because I didn't see the necessity of it as a lot of, you pointed out, a lot of the things that are written here, I haven't gone into detail.

MR BERGER: Who else ...

MR RAVEN: Especially in connection with the envelope. You pointed out, I wrote nothing about the three envelopes, the official envelope, the intercepted envelope haven't been mentioned here.

MR BERGER: Who else haven't you mentioned in your application Mr Raven?

MR RAVEN: Nobody that I can think of.

MR BERGER: That is why I put to you that you covered yourself in your application.

MR RAVEN: Do you have names that I haven't mentioned here or is this a supposition of yours?

MR BERGER: Chairperson, perhaps this will be an appropriate place to take the adjournment.

COMMITTEE ADJOURNS

ON RESUMPTION

ROGER HOWARD LESLEY RAVEN: (still under oath)

ADV DE JAGER: Mr Raven, did you hear of Goosen's death at any stage?

MR RAVEN: I know he died. I can't remember when it was.

ADV DE JAGER: Was it before you completed, were you aware of his death before you completed your application?

MR RAVEN: Yes, I think I was.

ADV DE JAGER: So, you didn't mention his name here with Craig Williamson as giving an order?

MR RAVEN: Yes.

ADV DE JAGER: It wouldn't have prejudiced him if you had mentioned his name?

MR RAVEN: No sir.

ADV DE JAGER: Thank you.

CROSS-EXAMINATION BY MR BERGER: (continued) Mr Raven, you say that you used sheet explosives for the two letter bombs that you made?

MR RAVEN: That is correct.

MR BERGER: Identical explosives?

MR RAVEN: Correct.

MR BERGER: Of what make?

MR RAVEN: As I said, I don't remember if it was American or made by Nobel, that I couldn't tell you. It was a Western country.

MR BERGER: And for the London bomb, you used plastic explosives?

MR RAVEN: Yes, of communist, East Block country origin, yes.

MR BERGER: Now, plastic explosives are not the same as TNT, am I right?

MR RAVEN: Correct.

MR BERGER: Mr Waal du Toit in his amnesty application, bundle 3, page 195 says that Russian TNT was used.

MR RAVEN: I don't know of Mr Du Toit's knowledge of explosives.

MR BERGER: Have a look half way down page 195, "after completion I notified Craig and later Jerry Raven, his rank unknown to me, arrived from his office with a cardboard box at my office. The contents of the box namely equipment and blocks of Russian TNT explosive was sealed in plastic and packed in the newly manufactured consoles".

So you are saying Waal du Toit is mistaken?

MR RAVEN: He is mistaken.

MR BERGER: It definitely wasn't Russian TNT explosives that he packed into the containers?

MR RAVEN: No, it was Russian plastic explosives. TNT, trinitrotoluene is different to plastic explosives which is RDX, (indistinct), a completely different composure.

MR BERGER: So he is completely wrong?

MR RAVEN: In so far as that type of explosive, yes.

MR BERGER: But he did pack the explosives into the two containers in your presence, correct?

MR RAVEN: That is correct.

MR BERGER: And you say that the amount of explosive that was packed into those two containers, was one kilogram?

MR RAVEN: That is correct.

MR BERGER: Definitely not more than that?

MR RAVEN: Well, it was four blocks of 250 grams, which makes it one kilogram.

MR BERGER: Not 4.5 kilograms?

MR RAVEN: Definitely not.

MR BERGER: Not more than 4.5 kilograms?

MR RAVEN: Definitely not.

MR BERGER: Okay. And all the explosives that were packed into those two cartons, was used in the London bomb?

MR RAVEN: No, it was only packed in one carton.

MR BERGER: Well, Mr Du Toit talks about consoles?

MR RAVEN: Yes, as I have explained to the Chairman as well, when it comes to explosives, you never pack detonators and explosive in the same container.

MR BERGER: Okay, so the detonators were packed in a different container?

MR RAVEN: That is correct.

MR BERGER: And how many detonators did you have?

MR RAVEN: I took about four I think it was.

MR BERGER: You would have to have taken four, because you needed two for each bomb? Correct?

MR RAVEN: Correct.

MR BERGER: Now you used two in the London bomb, what did you do with the other two?

MR RAVEN: They were stuck into the explosives as well, so they would detonate and destroy themselves.

MR BERGER: How large were the containers?

MR RAVEN: I can't remember the exact dimensions.

MR BERGER: Approximately?

MR RAVEN: 300 x 350 x 15 cm.

MR BERGER: You say 300 mm x 150 mm?

MR RAVEN: Yes, approximately.

MR BERGER: Each one of them separately?

MR RAVEN: Approximately, as I am saying this is a long time ago, I can't remember sized. You wouldn't need a colossal container to carry a kilogram of explosives.

MR BERGER: You could have packed five kilograms of explosives into those containers, couldn't you?

MR RAVEN: I don't know, I would have to have the consoles or the containers rebuilt to the exact specifications and then see how much they would take. I can't answer that.

MR BERGER: And the batteries you say, the batteries were in a separate container?

MR RAVEN: No.

MR BERGER: I beg your pardon, you said the detonators?

MR RAVEN: The detonators in a separate container.

MR BERGER: I am sorry, my mistake. The batteries, where were they?

MR RAVEN: The batteries were purchased in London.

MR BERGER: Where were they purchased?

MR RAVEN: The shop where I bought the soldering iron and the wires or various shops, because I didn't buy everything at the same place.

MR BERGER: Oh, was that just around the corner from the ANC office?

MR RAVEN: No.

MR BERGER: That was, sorry, that was the film. My mistake.

MR RAVEN: It wasn't a film either, it was a camera lens.

MR BERGER: Oh. What type of battery was it?

MR RAVEN: If I remember correctly, it could have been a Duracell. I don't know the exact manufacture of the battery.

MR BERGER: That was the same type of battery that you used for the letter bombs?

MR RAVEN: The letter bombs I used a component of a Duracell battery.

MR BERGER: Now, did you use any semtex in the bombs that you made, either in the London bomb or Ruth First, the bomb that killed Ruth First or the bomb that killed Jeanette and Katryn Schoon?

MR RAVEN: No, I did not.

MR BERGER: You are absolutely certain about that?

MR RAVEN: I just said I did not, that means I am certain about that.

MR BERGER: What is semtex is a plastic explosive manufactured as far as I know, in Czechoslovakia and was used reportedly, according to the press, by the Libyans and the IRA.

MR BERGER: And is it a very powerful explosive?

MR RAVEN: It is the same power as ordinary plastic explosives, either locally manufactured or Soviet manufactured.

MR BERGER: So it would have had the same power as the explosives that you used in the London bomb?

MR RAVEN: Yes.

MR BERGER: And it would have had the same power as the explosives that you used in the bomb that killed Ruth First and the bomb that killed Jeanette and Katryn Schoon?

MR RAVEN: Very, very close.

MR BERGER: One wouldn't be able to discern the difference by having a look at the site after the bombing?

MR RAVEN: No, you would have to take forensic smears of that and have it analysed.

MR BERGER: The point I am trying to establish is that the nature of the damage, would be to the naked eye exactly the same whether you use semtex or whether you used the explosives that you used?

MR RAVEN: Well, I would have to have two cases of the various natures to look at them to say yes it is. I can't do a supposition and say yes, it is, because it may be.

MR BERGER: I am sorry, maybe I said nature, I meant extent of the damage. The extent of the damage could be the same?

MR RAVEN: Could be very close to each other.

CHAIRPERSON: Depending on the amount of explosive used?

MR RAVEN: Exactly.

MR BERGER: Yes, no my question was based on the supposition that you used the same amount of semtex and the same amount of whatever explosive material you used.

MR RAVEN: But I said I didn't' use semtex.

MR BERGER: Mr Raven, I heard you say that. What I am saying and what I think you have agreed with, is that the extent of the damage whether you had used say a kilogram of semtex or a kilogram of the plastic explosive that you used, the extent of the damage would be the same?

MR RAVEN: Correct.

MR BERGER: And similarly if you had used 100 g, the extent of the damage would be the same?

MR RAVEN: In principle, yes.

MR BERGER: In the first interview that Mr Williamson had with Ms Slovo, the following is recorded and I am referring to page 42, do you have page 42?

MR RAVEN: No, I don't. Which bundle?

CHAIRPERSON: Which Exhibit is that?

MR BERGER: It is Exhibit X2 Chairperson. Do you have it now Mr Raven?

MR RAVEN: I have it now.

MR LEVINE: Mr Chairman, this tape has been analysed for errors and this particular page 42, the tape is virtually unintelligible because it is very disjointed, so I can't comment on the accuracy, but I place that on record, because of the original issues raised in regard to that particular recording.

MR DU PLESSIS: Mr Chairman, I also just want to say that obviously the correctness of the tape is being checked. It is in dispute, I don't necessarily want to object against cross-examination on this, but it has to be on the basis that the correctness of the transcript is not accepted or agreed to.

MR BERGER: I will cross-examine on that basis, but I would just point out and I am looking at Mr Levine’s corrected version, along the side of the page it says "unintelligible", but in the portion that I want to read to you from, is actually a correction that there is a single word left out.

Do you have the corrected version in front of you?

MR RAVEN: No.

MR BERGER: Okay, I will read to you ...

ADV DE JAGER: Exhibit X2(b)?

MR BERGER: 2(b). I will read it to you Mr Raven. It starts from the previous page. Ms Slovo, was Soviet stuff better than SA stuff? Mr Williamson, that is military. Military? Mr Williamson, yes, I mean that is military. It could have even been Semtex which you know which is Soviet or Czechoslovakia-Slovakian. Mr Williamson, both. Number one, the Secretary knows the SA connection to it, so it takes everything it needs and develop experts to go and check everything. Well, he would report. He would have, Ms Slovo. Mr Williamson, yes. And that report may be to East German. There was some East Germans there and look, they would collect the fragments sent off to East Germany and would report about this, it is more out stuff. But that was one reason, but a secondary one, you know that Semtex is probably the best military explosive in the world. I suspected it was Semtex' because I can't understand what else it could have been, the force of that explosion and the size of the device was very disproportional. As I say, it wasn't a big bomb, it was actually a very small and then Mr Levine’s clerk has inserted the word package. It was actually a very small package from what I saw.

Now, let's assume that that is what Mr Williamson said and I want to ask you some questions, and if there are certain corrections, well, we will just have to live with them.

The nub of what he says here, and that is really what I am concerned with, he says that the explosion that killed Ruth First, caused so much damage that it couldn't simply have been, or it was out of proportion to the kind of damage that a letter bomb, talk about a small package here, would cause.

You appreciate that that is the gist of what is being said here?

MR RAVEN: I appreciate that.

MR BERGER: Now you have said that Semtex isn't any more powerful than anything else, or than the explosives you used. What is your explanation for the fact that the damage caused by the bomb, was so great that it seemed to be out of proportion to a letter bomb?

MR RAVEN: The question I would like to ask then is, on what authority did Mr Williamson make that remark? As far as I know, he is not a bomb disposal expert, he has never used explosives as far as I know. I can't see how a amateur can make a remark and that remark be then taken as the gospel.

MR BERGER: All right. Let's factor Mr Williamson out of the equation for the time being.

If it is said that the damage caused by that bomb, was out of proportion to what on would expect from a letter bomb, from 100 g of explosives that you used, what would your response be, would you say that is not so?

MR RAVEN: I would like to know on what authority that statement is made.

MR BERGER: What sort of damage, well, let me ask you this, what sort of damage would you have expected your bomb, the bomb that was sent to Ruth First, to cause? Assume she is at her office, she is standing at her desk and she is opening her mail.

MR RAVEN: That is an assumption, I mean she could be sitting at her desk which would have made a difference.

If she was standing and bending over, bearing in mind that sheet explosives, plastic explosives, detonates at a speed of approximately 7 000 m per second, so it is not going to wait until something is moved out of the way, it is going to move through the object or the obstruction.

So bearing in mind the speed, the power, the heat, I could - the damage that was caused, I would say is equivalent to what would have happened, or what we saw there.

MR BERGER: You saw the photographs?

MR RAVEN: I saw two photographs that Gillian showed me.

MR BERGER: Ms Slovo.

MR RAVEN: Ms Slovo, sorry.

MR BERGER: Were those the only two photographs that you saw in relation to that scene?

MR RAVEN: That is correct.

MR BERGER: You never discussed the damage caused by your bomb, with anyone else? I am talking about at any time from 1982 onwards?

MR RAVEN: Prior to 1982, we had no knowledge as far as I know, of the damage that was caused.

MR BERGER: Mr Williamson never came to you to discuss the damage that was caused by the bomb which killed Ruth First?

MR RAVEN: Not to my knowledge.

MR BERGER: Well, if he had discussed the bomb with you and the damage that your bomb had caused, you would remember that?

MR RAVEN: I would remember it.

MR BERGER: So then you can state confidently as a fact that neither Mr Williamson nor anyone else, ever discussed, other than Ms Slovo in the interview, ever discussed the damage caused by the bomb which killed her mother?

MR RAVEN: Not to my recollection.

MR BERGER: Do you know that a wall was blown out by your bomb?

MR RAVEN: I didn't know that.

MR BERGER: When I say blown out, there was like a cavity blown through that wall, partially demolished the wall?

MR RAVEN: Well, in the photographs that Ms Slovo showed me and on the video that was shown where they showed the room there, I didn't see any structural damage there at all.

MR BERGER: Would you have expected your bomb to cause structural damage?

MR RAVEN: Maybe the table it was laying on, it was opened on a table, yes, but not as far as walls blown out, etc.

Unless of course it was sitting against a wall.

MR BERGER: You would not have expected your bomb to partially destroy a wall?

MR RAVEN: It is quite possible, depending on so many things.

MR BERGER: Isn't - you know you are being asked to build a bomb to kill one person, the person who opens the letter, correct. Isn't that what you are being asked to do?

MR RAVEN: Correct.

MR BERGER: So, you don't have to create a bomb that is going to knock out parts of walls, do you?

MR RAVEN: Correct.

MR BERGER: And if your bomb did knock out part of a wall, then it would mean that you made a bomb which was far more powerful than what you needed to make in order to kill one person?

MR RAVEN: There that is a supposition, because as I said it depends on a lot of things. Can you tell me what was the wall construction? Was it a dry beaverboard wall or was it a two brick wall or was it a concrete wall? Where was the table or where was the letter opened in conjunction with or the distance from the wall?

MR BERGER: Would it make a difference Mr Raven?

MR RAVEN: Yes, it would.

CHAIRPERSON: It is obvious it makes a difference what the wall is made of, isn't it? If it is a brick wall or a beaverboard wall, if it is three ply wall?

MR BERGER: Not the wall. I should have been more specific Mr Raven, would it matter where in, whether Ms First was standing or sitting as to what damage your bomb would cause?

MR RAVEN: To what?

MR BERGER: To the room, to the wall?

MR RAVEN: As I said, depending on the construction.

CHAIRPERSON: We have heard in evidence at this hearing, in connection with the London bomb, that if you place the explosive against the wall, it will blow into the wall of the building, and cause damage to the building.

MR RAVEN: Correct Mr Chairman.

CHAIRPERSON: Does the same apply if there is a desk against the wall, and the letter is being opened on that desk against the wall, rather than a desk standing in the middle of the room somewhere?

MR RAVEN: Correct.

MR BERGER: Let me refer you to another extract. It is in the second interview that Ms Slovo had with Mr Williamson, it is Exhibit X1 and at page 17. Do you have it?

MR RAVEN: I have it.

MR BERGER: You will see there in the middle of the page, weren't they worried it would be checked at the University, that is Ms Slovo. Mr Williamson, yes.

MR RAVEN: Hang on a second, okay, I have where you are.

MR BERGER: Which is why they would have made sure that even if it was, there would be no come back. Aha, Ms Slovo. Mr Williamson, it would have been Soviet explosives. It would fit in with the cover story which was that it was Ruth was being a nuisance inside the ANC, and therefore was eliminated and that it couldn't have been a letter bomb because the explosion was too powerful.

Now, what Mr Williamson is saying there is that there is this cover story, did you know anything about a cover story?

MR RAVEN: No, I didn't.

MR BERGER: And in order to sustain this cover story, you need to use Soviet explosives?

MR RAVEN: That is what is being implied here.

MR BERGER: But you say you didn't use Soviet explosives?

MR RAVEN: That is correct.

MR BERGER: You used Western explosives?

MR RAVEN: That is correct.

MR BERGER: So the cover story wouldn't even fly?

MR RAVEN: Are you aware, you should be aware then that Soviet explosives are used by the IRA, which is a Western country. For the same matter a Soviet country, can use a Western explosive, if it fits in with the project that they are going for.

MR BERGER: No, no, but you see the cover story is that when people point fingers at the South African government to say you killed Ruth First, the South African government could say no, no, look at the make of the explosives, they are Soviet explosives. In fact Ruth First was killed by the ANC. We all know they are backed by the Soviets.

MR RAVEN: For the same reason they could say right, this is sheet explosives, but in South Africa we don't make sheet explosives. We don't manufacture it in this country.

So I mean, your story or your supposition cuts ice both ways.

MR BERGER: Why would Mr Williamson have said it would have been Soviet explosives?

MR RAVEN: I don't know, you would have to ask Mr Williamson that.

MR BERGER: Why would Mr Williamson have said that extra powerful explosives were used so that the South Africans could deny that it had been a letter bomb?

MR RAVEN: Where, I do not see him saying that anywhere here?

MR BERGER: Well, have a look. It would fit in with the cover story which was that it was Ruth was being a nuisance inside the ANC and therefore was eliminated, and that it couldn't have been a letter bomb, because the explosion was too powerful.

CHAIRPERSON: Doesn't that mean that is part of the cover story?

MR BERGER: Indeed, indeed it does. And that is my point Mr Raven, that (a) you used Soviet explosives so that the finger couldn't be pointed at the South Africans, and (b) you made the bomb far more powerful than you had to make the bomb, so that the South Africans could claim that it wasn't even a letter bomb that was sent, it couldn't have been a letter bomb, because as Mr Williamson says, the explosion was too powerful?

MR RAVEN: Mr Williamson can say what he likes, in my application I said what I used. I said the amount I used, and that I stand by.

CHAIRPERSON: Is it disputed that it was a letter bomb? I understood from Mr Bizos that he had four witnesses that he wanted to call who were present when the bomb went off, when it was being opened?

MR BERGER: It is not disputed that it was a letter bomb sir. But that is not the point that I am making Chairperson.

CHAIRPERSON: It is exactly the point that you have been making, that a letter bomb couldn't damage walls, a letter bomb couldn't do this? Letter bombs do not have fixed sized do they, or fixed explosives, it merely means an explosive was sent in a letter?

MR BERGER: Chairperson, can I explain? This is my argument, it was a letter bomb, we all know that it was a letter bomb that was sent.

But when the South African government or the officials that were responsible, anticipated that when Ruth First was killed, fingers would be pointed at the South Africans. In order to have a plausible story to rebut that, in other words the "dekstorie", Soviet explosives were put into the letter bomb, so that the South Africans could say it wasn't us, it was the ANC.

Secondly the explosives that were put in, semtex, were so powerful, so much more powerful that what one would normally put in a letter bomb, that the South Africans could subsequently claim that we hadn't sent a letter bomb, in fact no one had sent a letter bomb, because the damage which was caused was out of proportion to that which one would expect from a letter bomb.

CHAIRPERSON: And would there be evidence to that effect?

MR BERGER: That the damage was out of proportion?

CHAIRPERSON: And the semtex was so powerful and was used?

MR BERGER: Mr Williamson says that.

CHAIRPERSON: Williamson says it might have been, doesn't he?

MR BERGER: No, he says it would have been. He says it would have been Soviet explosives.

MR DU PLESSIS: Mr Chairman, I can't recall in cross-examination of Mr Williamson that he was examined on this, asked questions about this or asked to confirm this.

MR BERGER: He was.

MR DU PLESSIS: It may be, I can't remember it.

MR RAVEN: May I ask a question. This is the first now that I have heard that there was somebody in the room, apparently it seemed like three people were in the room with Ruth when the ...

MR BERGER: Ms First.

MR RAVEN: Okay, Ms First, when the letter was opened, am I correct?

MR BERGER: Yes.

MR RAVEN: And such extensive damage was done to her according to the photographs and the whole was broken into the wall?

MR BERGER: Correct.

MR RAVEN: Can you tell me what damage was done to the other three people?

MR BERGER: They were injured.

MR RAVEN: To what extent?

MR BERGER: Evidence will be led in due course.

CHAIRPERSON: The passage you referred to originally in X2(b) was where Williamson said it could even have been a semtex. He didn't say it was. The bottom of page 41 which you have referred us to.

MR BERGER: Yes, that was in the first interview, then in the second interview he says it would have been Soviet explosives.

And then over the page, page 18 at the bottom ...

CHAIRPERSON: It may even have been.

MR BERGER: Correct.

CHAIRPERSON: So there is no evidence it was? Unless you have evidence, unless checks were done after the explosion.

MS PATEL: Honourable Chairperson, he was questioned about this, if you want to check your notes on the 17-09. Do you want to check your notes, on the 17-09 he was questioned about this passage wherein he states that explosives of Soviet origin were routinely used because it allowed South Africa a window of deniability.

MR DU PLESSIS: Mr Chairman, two points. I can't remember that he specifically in evidence said semtex was used, and secondly to question Mr Raven on the extent of the damage of the bomb without putting to Mr Raven, what happened to the other three people and what injuries they suffered in relation to this bomb, where the supposition is that the bomb was much stronger than a letter bomb, I find incredible.

My learned friend says that there will be evidence in due course, but it is not put to the witness. I am just placing that on record.

CHAIRPERSON: We will have regard to that.

MR BERGER: Then if you would turn to page ...

CHAIRPERSON: I am sorry, that was part of the arrangements for next week.

MR BERGER: You say that you never involved anyone else in the acquisition or the making of the bomb? This is now the bomb that killed Ruth First and the bomb that killed Jeanette and Katryn Schoon?

MR RAVEN: That is correct.

MR BERGER: You did it all yourself?

MR RAVEN: That is correct.

MR BERGER: Have a look at page 29 of Exhibit X2(a).

MR RAVEN: Which page?

MR BERGER: 29. Do you see in the middle of the page, I mean I can tell you who the person was who actually involved, was Brigadier Piet Goosen. Do you see that?

MR RAVEN: Yes.

MR BERGER: The famous one, Biko Goosen. And the orders were issued that an explosive device be put in the package. And then there is this part, that is where we came in. Because it part of G Section, there was a Technical Section, who also didn't do it themselves.

They, the Technical Section, took it off to another you know, the overall. I can't remember which Group it was, but there was a Group, I can find it out for you, who actually, it was probably, we were G, so it was either J or K or one of these Groups. Was there another Group J or K?

MR RAVEN: Without an (indistinct), I can't say.

MR BERGER: What Section was, yes what Section or Group was Mr Waal du Toit in?

MR RAVEN: A Technical Section. As I said what the letter is, I don't know.

MR BERGER: There was another, there was a Technical Section that dealt with bombs in your, in the Security Police and it wasn't your Section?

MR RAVEN: When you say dealt in bombs, the only Section that I know of that dealt in bombs, was my previous posting, which was to the Directorate Explosives which is Bomb Disposal.

MR BERGER: Mr Waal du Toit was in your Group?

MR RAVEN: No, he was not.

MR BERGER: Group G?

MR RAVEN: Not to my knowledge, never.

MR BERGER: Just bear with me for a moment. Group D? And there was a Technical Section of Group D that Mr Waal du Toit was a member of? Do you have any knowledge of that?

MR RAVEN: No, I don't.

MR BERGER: So who is Mr Williamson referring to here where he says there was a Technical Section, that is you, who also didn't do it themselves. They, the Technical Section, that is you, took it off to another you know, the overall. I can't remember which Group it was, but there was a Group? And you will recall when my learned friend, or maybe I don't know if you were here when he did it, but my learned friend, your Counsel Mr Du Plessis, questioned Mr Williamson on this page and he said to Mr Williamson when you referred to they, are you referring to Mr Jerry Raven and he said yes, I am referring to Mr Jerry Raven.

So, you can take it that when he talked about the Technical Section taking it off to another, he is talking about you taking it off to another? Who did you take it off to?

MR RAVEN: I took it off to nobody.

MR BERGER: So where did Mr Williamson get this from?

MR RAVEN: I suggest you ask Mr Williamson.

MR DU PLESSIS: Mr Chairman, Mr Williamson was asked the use of they, was it meant in a broad sense and he testified that it was meant in a broad, general sense Mr Chairman. That was, I recall that Mr Williamson also testified that at that stage the reason why he testified it in such way is that he didn't want to disclose Mr Raven's name.

MR BERGER: Exactly.

MR DU PLESSIS: Then Mr Chairman, I request that my learned friend put the whole correct version of the evidence to the witness.

MR BERGER: Mr Williamson was referring to you Mr Raven, you were the Head of your Technical sub-Section in the Group, am I right?

MR RAVEN: That is correct.

MR BERGER: Mr Williamson knew that he had given it to you to make, this is on his own evidence?

MR RAVEN: That is correct.

MR BERGER: And he then says that you, your Section, you couldn't make it yourself, you had to take it off to another Group?

MR RAVEN: I don't know why he made a statement like that because I made the letter bomb.

MR BERGER: Maybe because and this is what I keep on suggesting to you, maybe because the circle of people involved in this crime, is larger than you want to admit?

MR RAVEN: That is your supposition, but it is not correct.

CHAIRPERSON: Where did you take the envelope afterwards?

MR RAVEN: The envelope was placed in my office in my filing cabinet, locked up.

CHAIRPERSON: And then you went off to where?

MR RAVEN: I went up to the workshop that we had, where we gave our lectures on explosives to bomb disposal people in the various branches, behind which was a little workshop and that is where I constructed the bomb.

CHAIRPERSON: In the same building?

MR RAVEN: Outside in the Police College, not in the same building as Head Office.

CHAIRPERSON: No, you went to another building, another section where you made the bomb?

MR RAVEN: That is correct.

CHAIRPERSON: And then you brought it back?

ADV DE JAGER: And that other building is about, am I wrong, Headquarters is Wagtehuis and the other building would be at the Training Centre in Pretoria West or where?

MR RAVEN: That is correct.

ADV DE JAGER: So it is kilometres apart?

MR RAVEN: It is a long way apart.

MR BERGER: But it wasn't that you took it to another Section, you took it to another place for you, yourself to make the bomb?

MR RAVEN: That is correct.

MR BERGER: Then Mr Williamson goes further, or the interview goes further, Ms Slovo why didn't the Technical Section do it themselves? Mr Williamson, no because I mean my Technical Section didn't have, oh, I mean we didn't have explosives you know. I mean that main group, that other Technical, there was one Group that was Technical completely, that did all electronic or explosive things. He is saying that is where you took it.

Ms Slovo, is it because you know the names but you don't want to give the names to me? Mr Williamson, I do know. No, I do know the names. Ms Slovo, what would be the harm in telling me the names? I am not going to go out and ... Mr Williamson, yes, well, that is why I said to you that is where, because I've also got to tell you, you see the way these things work, if somebody, people have told me and I am sure you have heard the name Waal du Toit ... Mr Williamson, no, I don't know if Waal made it or not, he was the second in charge, he was the main guy at that Technical Section, that did make these things or that did all sorts of things. They may not even have told them what it was for, I don't know either.

ADV DE JAGER: But didn't he refer to the explosive being brought from another place, or given to Mr Raven from another place, or by somebody else?

MR BERGER: No. He says ...

ADV DE JAGER: They had the explosives and other things.

MR BERGER: Yes. Right at the middle of page 29, there was a Technical Section, that is part of G Section, who also didn't do it themselves. They, the Technical Section took it off to another you know, the overall.

So in other words, and then if one reads it with the next page, Mr Raven took it to Mr Waal du Toit's Section and there they made the bomb.

CHAIRPERSON: Are we getting anywhere cross-examining this applicant on what purports to be a recording of an interview with another applicant?

MR BERGER: Chairperson, after our learned ...

CHAIRPERSON: He says that is not true, he has told you his version.

MR BERGER: Indeed, and I will move on from there, but after the tapes have been verified by our learned friends, then this will be before the Committee and I won't have an opportunity to cross-examine Mr Raven at that stage, that is why I am doing it now.

You say Mr Williamson is incorrect?

MR RAVEN: I made the bomb, Mr Williamson is incorrect in this statement he made.

MR BERGER: And then Mr Raven, do you know what the letters EMLC stand for?

MR RAVEN: Not to my knowledge off the cuff.

MR BERGER: E for Electronic, Military - does that not ring any bells?

MR RAVEN: Not at the moment.

MR BERGER: And do you know a person by the name of Grive?

MR RAVEN: Who?

MR BERGER: Grive or Grieve?

MR RAVEN: Doesn't recollect that name at all.

MR BERGER: Do you know a person by the name of Freeman?

MR RAVEN: No.

MR BERGER: If you would look again at the second interview between Ms Slovo and Mr Williamson, Exhibit X1, to see about a third of the way down.

MR RAVEN: Which page?

CHAIRPERSON: Which page?

MR BERGER: Page 20.

MR RAVEN: Thank you.

MR BERGER: Ms Slovo, and was Jerry Raven in a position to do this technically? Mr Williamson, well Jerry together with the, I mean it is not only him, it could be the whole Technical staff plus the Defence Force guys from where they got the, I mean between them, you know, those people, you know, I mean at the end of the day Jerry Raven's job was basically as the Intelligence Section Technical guy, to liaise with his counterparts in the main Technical Section and then, then with their counterparts in the Military and together to come up with a device?

Is Mr Williamson incorrect?

MR RAVEN: Correct.

MR BERGER: Mr Raven, you agree with me, I am not saying it, you are saying that Mr Williamson's, what is attributed to him here, is not correct?

MR RAVEN: That is correct.

MR BERGER: You didn't liaise with anyone in the Military, with your counterparts in the Military or in any other Section in your putting together of this bomb?

MR RAVEN: That is correct.

MR BERGER: Now I want you please to have a look at Exhibit GG. GG is the article from the Star, dated 14 July 1984 "Who killed Ruth First". Do you have it?

MR RAVEN: I have it in front of me.

MR BERGER: Have a look please at the third last paragraph in the first column. It says there, press reports gave few details of the assassination, but new information emanating from British and American sources, indicates that the bomb was attached to her desk.

We know that the bomb was not attached to her desk and we know that this is a Stratcom operation, but I want to ask you some questions based on this. The next paragraph, though reports at the time claimed that only a small letter bomb was involved, the resultant blast demolished her office. Do you see that?

Now if you also look at Exhibit HH, it is also an article in The Star, 14 July 1984, reports claim Slovo responsible for wife's letter bomb death, and it talks about a rift between Mr Slovo and Ms First and that they had become estranged and that Mr Slovo had killed his wife.

Have a look on the second page, the third last paragraph. With these events as a background ...

MR RAVEN: Hang on a second. Right I have it.

MR BERGER: Sorry. With these events as a background, do you have that?

MR RAVEN: Yes.

MR BERGER: The rift between Slovo and First widened irrevocably. Slovo has long been believed to be the power behind the ANC reporting directly to Moscow.

First's serious deviation from the ideological line was obviously a serious concern and embarrassment not only to Slovo and Soviet and also Soviet intentions in the region. Next paragraph, her death by an alleged letter bomb was immediately blamed on the South Africans acting with the American Central Intelligence Agency. The explosion in her office at Mondlani University was so severe, it wrecked the office.

This indicated the device was far too big to have been a letter bomb and would have had to have been planted beneath her desk. The British and American sources say and we know these are the South African sources, even Mozambican Security was not so lax as to allow such a device to have been planted in her office without their being in collusion with other parties.

Those parties could only have been Slovo and the ANC intent on a cleansing of the ideological line. Now, the information that was being fed through by Stratcom agents in South Africa was this, that there was this rift, that the explosion was so powerful that it couldn't have been a letter bomb and therefore it had to have been the ANC on instructions of Mr Slovo, who had killed Ms First.

What I want to put to you Mr Raven is that you as the person who made the bomb, would have been intimately involved in the creation of the Stratcom. Not that you put it out, but that you would have known in advance what the Stratcom was going to be, so that what you did with the bomb, accorded with the Stratcom. Do you understand what I am putting to you?

MR RAVEN: You are saying quite a lot, but if you are saying that I had a finger in the pie with the drawing up of the Stratcom, the answer is no.

MR BERGER: No, I am saying you were aware in advance of what the Stratcom would be and that is why you placed explosions in the letter bomb which were far more powerful than what one would normally attribute to a letter bomb?

MR RAVEN: So what you are saying in a nutshell is that before the explosion, this committee came together and they worked out the cover up story, or the Stratcom?

MR BERGER: Correct?

MR RAVEN: Well, that is incorrect because at the time of manufacturing the bomb, I didn't know who it was going to, so how could I have been part and parcel of this Stratcom party?

MR BERGER: That is if you didn't know who it was going to, but if you did know who it was going to, then you could have been part and parcel, do you agree?

MR RAVEN: If I knew, but I didn't know, so I wasn't part and parcel.

CHAIRPERSON: When was the bomb?

MR BERGER: When was the bomb? 1982.

CHAIRPERSON: When?

MR BERGER: 17th of August 1982.

CHAIRPERSON: About two years before this Stratcom story came out?

MR BERGER: Indeed. Let me refer you Mr Raven in case you are going to suggest that this Stratcom story was only devised in 1984 to the second interview of Mr Williamson.

First of all to a passage I have already referred you to, on page 17.

ADV DE JAGER: Mr Berger, apart from that, were there any newspaper or any other documents where this rift between the couple surfaced before 1984?

MR BERGER: My learned friend Mr Du Plessis referred to an article, he referred to a number of articles some of which were the articles that I have put in as Exhibits. My learned friend referred to an article that came out in 1982. I haven't had sight of it, I don't know if that said anything about the ideological rift.

Perhaps my learned friend could assist. The Transvaler and the Rand Daily Mail article.

MR DU PLESSIS: Mr Chairman, I will gladly assist. I've got all the known articles on this incident as far as I know. I will go through them and see if there is any mention of that in 1982.

MR BERGER: Could we please have sight of the Transvaler article and the Rand Daily Mail article from 1982?

ADV DE JAGER: Mr Berger, perhaps you could continue in the meantime.

MR BERGER: I will continue. The first passage Mr Raven was the one at page 17, where Mr Williamson said it would have been Soviet explosives, it would fit in with the cover story that it was Ruth was being a nuisance inside the ANC and therefore was eliminated and that it couldn't have been a letter bomb because the explosion was too powerful.

What I am putting to you is that you didn't, you say you didn't use Soviet explosives. If you had used Soviet explosives, then it would have been something out of the ordinary for you, you would have used Soviet explosives because you would have known what the cover story was going to be and so therefore your use of Soviet explosives would then fit in with the cover story. In other words that is why I put to you that the cover story was thought up in advance.

But I have more ...

MR RAVEN: Can I just interject there please?

MR BERGER: Yes.

MR RAVEN: The reason why, I explained why Soviet, plastic explosives weren't used was because of the oily stain that it gives off, the smell that it gives off, etc.

MR BERGER: There are no Soviet explosives that don't give off an oily texture, is that what you are saying?

MR RAVEN: No, I am not saying that. I am just saying that I didn't use as intimated here, the use of Semtex which is a plastic explosive.

MR BERGER: Soviet explosives could have been used which did not have an odour, which did not leave a trace, am I right?

MR RAVEN: Not to my knowledge.

MR BERGER: Okay. And then have a look if you would, at page 22. You will see there at the top of the page, a little way down, that is why I had some feeling.

Well, let me go a bit higher, it was some time really, I don't know, but it was several weeks. Ms Slovo, that is why you assumed that it wasn't sent by post? Mr Williamson, that is why I had some feeling that because I thought that either it hadn't been sent or if it had, it had been detected you know.

And then one morning, you know we monitored BBC every morning of Africa news just for general, and of course the ANC, the operation, I can't remember, I think it was called Valk, I think, he was listening to the ANC coms between Maputo and London and Lusaka. On the phone? On telex, yes.

Ms Slovo, and that is when you had the Stratcom meeting? Mr Williamson, yes, that is when the Stratcom guys were told because of course the press then started running around saying you know who had done this, and that is when the second aspect of the thing and internal and then asked about who were the Stratcom guys.

Then, if you have a look over the page to page 23, Ms Slovo tells Mr Williamson that her father, Joe Slovo had sued The Star as a result of this article, middle of the page, Ms Slovo, I don't think it was ever in The Citizen because Joe sued The Star.

He would have sued The Citizen as well if it had been in The Citizen. Mr Williamson, no, I remember that he sued The Star. It is quite possible that The Citizen, you know, refused to print it.

That happened often enough like with the Boesak story too, it was The Star that printed it, The Citizen didn't. Ms Slovo, hm. Mr Williamson, but it's, again I don't, it is not something that I've got. Now that you mention it, I think I remember that I, we were quite surprised that the story then came out after having unsuccessfully fed it through. Yes. And I would image what happened was that you know, when one then feeds these things, these rumours and stories into the network, it ends up coming back to people from the most sort of surprising sources.

So he never said exactly where he got the story from? You see Mr Williamson was questioned on this passage as well. The Stratcom was fed through to the media at the time of Ruth First's death.

MR DU PLESSIS: Mr Chairman, may I just point out on page 22 at the bottom of page 22, Mr Berger's own client says because the story actually only came out in 1984, she says the story that Joe had killed Ruth was only in the papers as far as I can see and I went back and read the papers in 1984.

MR BERGER: Yes, but we know that that is the position.

CHAIRPERSON: Apparently Williamson's version is now accepted as all the other points have been put of Williamson, he is accepted as a truthful witness when he says he put the story out in 1982, but the press only used it in 1984.

MR DU PLESSIS: Thank you Mr Chairman.

MR BERGER: Chairperson, I am taking Mr Williamson on his word. I am asking Mr ...

CHAIRPERSON: You are accepting him as being correct and putting it to this witness. It is interesting to see that you are accepting Mr Williamson as a reliable witness.

MR BERGER: Chairperson, that is clearly not our position.

CHAIRPERSON: Well, then how can you put it to this person to say he is wrong because this is what Williamson said, if you don't accept what Williamson said?

MR BERGER: My learned leader put it to Mr Williamson on several occasions that he was not telling the truth, so I don't know how you ...

CHAIRPERSON: Then what is the point of putting Williamson's version now if it is that he is not telling the truth?

Are you just going to select those portions of his evidence that suits you and say that is the truth?

MR BIZOS: Mr Chairman, may I be permitted with the greatest respect, in defence of my colleague's cross-examination with which I agree fully.

A member of the Committee Mr Chairman, asked a legitimate question, was there any publicity about the Stratcom story before 1984. It now appears Mr Chairman, if Mr Williamson is telling the truth, that a Stratcom was in fact put out in 1982, but apparently the ladies and gentlemen of the press and so we will argue, thought it so fantastic a story that they did not publish it.

That is a direct answer to Adv De Jager's query with the greatest respect, and also as to whether or not the Stratcom was put together prior to the actual killing.

Matters which we will argue Mr Chairman in due course, are of fundamental importance. Mr Chairman, with the greatest respect, it is well known that the mere fact that a person may take a witness or one of his opponents on his word, on a particular issue, does not mean that he accepts the evidence of that witness on other issues Mr Chairman.

CHAIRPERSON: What you are relying here is not the evidence he gave here Mr Bizos, it is something that was recorded on an inefficient recording device at some hearing long before this.

MR BIZOS: Yes Mr Chairman, extra-judicial admissions of fact against a particular person's interest, have always been regarded...

CHAIRPERSON: But these are not admissions of fact against Mr Williamson's interest. These are matters that were not put to Mr Williamson. He was not asked to comment on them, but this applicant is now being asked to accept the correctness of what Williamson said.

MR BIZOS: He was. He was. Mr Chairman, with this and a number of other interjections with the greatest respect, is what Your Lordship has just said, that this was not put, is in fact and we do not blame you for it, Mr Chairman, because we ourselves forget, this was in fact put to Mr Williamson by me in cross-examination Mr Chairman.

CHAIRPERSON: The only portion you put of this Mr Bizos, was Mr Williamson, but it is you know again, I don't, it is not something that I've got. Now that you mention it, I think I remember that I, we were quite surprised that the story then came out having unsuccessfully fed it through.

That is the portion you put?

MR BIZOS: I think that I put much more, but even if that is all I put Mr Chairman, it is an acceptance of Mr Williamson's word that a Stratcom was put out before the event and that it was not taken up.

That is all with respect, that Mr Berger is putting.

CHAIRPERSON: (Microphone not on)

MR BIZOS: If we accept for the purposes of testing this witness' credibility Mr Chairman, that this is what Mr Williamson said and that that is true, we are taking him on his word in order to establish an improbability with the greatest respect, that this witness acted completely alone and he was not assisted by anyone else and he didn't know anything about a Stratcom story.

What I would appeal Mr Chairman with the greatest respect, is a certain amount of patience. I know that it is a painful process, a certain amount of patience in order to do our duty to our clients Mr Chairman, to the best of our ability and I submit with the greatest respect that the last question which led to the intervention is with the greatest respect, a proper question and a proper line to follow Mr Chairman.

CHAIRPERSON: What was your question Mr Berger?

MR BERGER: My question Chairperson was, on the basis of what Mr Williamson says in the passages that I have quoted to Mr Raven, it would appear as if the Stratcom was devised before Ms First was killed.

MR DU PLESSIS: Mr Chairman, I have to object again. If you read the middle paragraph of page 22, it is clear, he says yes, that is when the Stratcom guys were told, because of course the press then started running around saying, you know, who had done this. Clearly that is after the incident Mr Chairman?

CHAIRPERSON: Yes.

MR BERGER: But one can't ignore what he says at page 17?

ADV DE JAGER: Where exactly did you read from?

MR DU PLESSIS: That is page 22 in the middle Mr Chairman, of Exhibit X1.

MR BERGER: Chairperson, can I ask my - sorry. You said it was on the 19th of August 1982 and Rand Daily Mail, 19 August 1982.

CHAIRPERSON: I see that Mr Du Plessis has now made two photostats of cuttings available.

MR BERGER: That is correct Chairperson. It is the Rand Daily Mail article of the 19th of August 1982 and the Transvaler article of the 19th of August 1982.

If you will just give me a moment. Chairperson, the Transvaler article headed infighting perhaps the reason for murder by Chris Vermaak. It reads as follows Ruth First, her maiden and writing name, was apparently the victim of clashing elements within the ANC and the banned Communist Party, SACP, who is seated in London. Then there is a different debate, but that seems to be the only indication at the time that there was talk of an internal struggle in the ANC.

MR DU PLESSIS: In the Rand Daily Mail you will remember there was that story that it may have been the Mozambican Resistance Movement, something in that line, I think I marked it in the Rand Daily Mail.

MR BERGER: That they had claimed responsibility?

MR DU PLESSIS: Yes.

CHAIRPERSON: So there appears to be no Stratcom story of this type in either of those newspapers on the 19th of August?

MR BERGER: No. Let me then move to the bomb which killed Jeanette Schoon and Katryn Schoon. Have a look if you would, at Exhibit EE, that is the Rapport article of the 1st of July 1984. Do you have it Mr Raven?

MR RAVEN: Letter bomb murder - work of the ANC? Is that the one?

MR BERGER: That is correct yes.

MR RAVEN: Yes, I have it.

MR BERGER: Now this article so that I can put it in context for you, was written by two reporters, one of whose name appears there, Johan Botha, the other one was Jacques Pauw after they had had an interview with Gen Johan Coetzee.

The article came out on the 1st of July 1984 and Mrs Schoon and her daughter were killed on the 28th of June 1984.

ADV DE JAGER: Did both Botha and Jacques Pauw have the interview or one of them?

MR BERGER: Both.

ADV DE JAGER: Both? And I don't know if you were here Mr Raven, I read this to Mr McPherson when you were away. I was reading form page 194 of Mr Pauw's book Into the Heart of Darkness and he says that a day after the explosion, his News Editor sent him to do an interview with Gen Johan Coetzee.

He says Coetzee told me that the Security Police had information that Jeanette and Katryn had been killed by the ANC as a result of an internal struggle within the organisation.

ADV DE JAGER: Mr Berger, that is why I asked, because you read Pauw says his News Editor sent him. You have just told me he went with Botha?

MR BERGER: Correct.

ADV DE JAGER: The two of them?

MR BERGER: Correct. So if you see at the top of the first column, just after the lead article Rapport was informed of this yesterday on good authority. That good authority is the Commissioner, or was the then Commissioner of Police, Gen Johan Coetzee.

I want to refer you to the middle column where it starts Rapport was however informed - do you see that?

MR RAVEN: Yes.

MR BERGER: That the ANC possibly could be responsible for the murders itself. It is a recognised propaganda method among terrorists to get rid of some of their cohorts and then point an accusatory finger at their enemies. It could be in order to get sympathy from overseas after the number of throwbacks that the ANC has had in the last time, especially with regard to the Nkomati Accord and the opposition which the ANC has in South Africa's neighbouring States, such as Mozambique, Swaziland and Lesotho which are thorns in the side of the ANC, it was told to Rapport.

And then if you have a look at Exhibit FF which is the Sunday Times article of the same day, 1 July 1984 by Stefan Terreblanche read "Assassins blamed for parcel of death", you will see there at the bottom of the second column, a little way up it says according to Security Branch sources, do you have that?

MR RAVEN: Yes, I do.

MR BERGER: This is after it said that they were working as English teachers, do you see that? Just a little bit above there?

MR RAVEN: I see that.

MR BERGER: All right, according to Security Branch sources the SACP has an active death squad which it has used to eliminate dissidents within its own ranks. "A further coincidence in the Schoon affair which is suspicious is that on Wednesday the day before the killings, the ANC released a press statement accusing South African Security Forces of planning to kill members of the ANC leadership", the sources said.

"We see this as part of its modus operandi which coincides one hundred percent with the Ruth First case". No South African organisation can be held responsible for the deaths of Mrs Schoon and her daughter. It would be virtually impossible for a South African or a stranger to move undetected in a small community like Lobango or to get anywhere near them.

Now, you see there that the - let me finish, look again in that third column, just under the heading Powerful, are you there?

MR RAVEN: Yes.

MR BERGER: According to Ms Bergeral, the Schoon flat was destroyed by a very powerful explosion. Do you see that?

MR RAVEN: Yes, I do.

MR BERGER: I can tell you that the Schoon residence was extensively damaged by the blast. What I am putting to you is that again the force of the explosion was huge.

You have seen from the two articles that I have referred you to and in particular the one which says that it would be very difficult to get anywhere near to the Schoon's in Lobango, that the suggestion is that it was not a letter bomb, that somebody actually took the bomb to Lobango. Do you see that?

MR RAVEN: No, I don't see that.

MR BERGER: Somebody put a bomb in the Schoon house in Lobango, that is why the Security source is saying it would be virtually impossible for a South African or a stranger to move undetected in a small community like Lobango or to get anywhere near them.

MR RAVEN: Does it say here that a Security person put the bomb in the house? I am trying to see that?

MR BERGER: No Mr Raven, it doesn't say that. The Security sources are giving out this information, Security Branch sources are giving out this information. They are saying it can't be us because no South African agent or stranger would be able to move undetected in a small community like Lobango or get anywhere near them.

MR RAVEN: I see that section yes.

MR BERGER: In other words saying it wasn't a letter bomb, it was a bomb which was placed there by somebody and it couldn't have been us because we couldn't have placed it there.

MR DU PLESSIS: No Mr Chairman, it says - all it says is, it wasn't possible for a South African and that is the tenor of it, wasn't possible for a South African to place a bomb there. It is a denial of the South Africans being involved in placing a bomb there, that is all.

MR BERGER: Well, if it was a letter sent in the post, then it wouldn't need anybody to move in a small community like Lobango?

Mr Raven, again what I am putting to you is that in putting together the bomb that you did which killed Jeanette and Katryn Schoon, you once again used far more explosives or far more powerful, let me put it that way, explosives than you would have needed to kill the person opening the letter.

And you did it because of this Stratcom, the strategy by the Security Forces, by the Security Police, to use, to send a letter bomb, but to use such powerful explosives that it could then thereafter be claimed it wasn't a letter bomb.

MR RAVEN: Are you saying that this so-called Stratcom was then devised prior to the letter being sent?

MR BERGER: Correct.

CHAIRPERSON: But this article, it may not say it is not a letter bomb, it says it is a parcel bomb if you read the first paragraph?

MR BERGER: Yes.

CHAIRPERSON: Doesn't that imply it is something sent by post?

MR BERGER: No Chairperson, if it was sent by post, then it wouldn't need somebody to move undetected in Lobango.

CHAIRPERSON: No, but they've got two versions there. If you are taking something undetected moving there, you wouldn't call it a parcel, would you? You would leave a bomb. When you used the word parcel bomb, indicate a bomb sent by post as a parcel?

MR BERGER: No Chairperson, with respect, not necessarily.

CHAIRPERSON: What does it mean then?

MR BERGER: It means that a parcel containing a bomb, was placed in the house of Marius and Jeanette Schoon or the flat of Marius and Jeanette Schoon.

CHAIRPERSON: Disguised as a parcel?

MR BERGER: I beg your pardon?

CHAIRPERSON: Disguised as a parcel, is that what you are saying?

MR BERGER: Yes.

CHAIRPERSON: And a letter bomb is disguised as a letter?

MR BERGER: Chairperson, the difference between a letter bomb which is sent in the post, and a parcel bomb which is delivered to the house, to the flat and placed there by a person moving through the Lobango community, is that in the former case no agent needs to get anywhere near Lobango, but in the latter, the agent actually has to get very close to the Schoon's in order to place the bomb.

That is the gravamen of the Stratcom which is put out in the Sunday Times article.

ADV DE JAGER: But a parcel can be delivered by somebody from the Post Office?

MR BERGER: It could.

ADV DE JAGER: Like the letter could have been delivered by somebody from the Post Office.

MR BERGER: Indeed, indeed, but then it wouldn't need a stranger or a South African agent to move undetected in Lobango?

ADV DE JAGER: Yes, no I agree with that.

CHAIRPERSON: No, but if they had not intended, they would have just said of a bomb, for the bombed deaths of, but they used the word parcel bomb. Parcel-bomb.

MR BERGER: Chairperson, then at best for the Security Police, they were covering themselves for two possible scenarios.

CHAIRPERSON: Yes.

MR BERGER: The point of my questioning Mr Raven, I have already put to you and I think you have answered that you say you didn't deliberately use more powerful explosives to create the impression that it wasn't a letter bomb and that it had been something which had been placed there, like in the case of Ruth First, attached to her desk as the one article wrote.

In the case of Jeanette and Katryn Schoon, placed in the residence by somebody. You are saying you were never party to any of that?

MR RAVEN: What I asked in answer to that question was, is the implication that this Stratcom in both cases, was put together prior to the explosion?

MR BERGER: Indeed.

MR RAVEN: Prior to the explosion I didn't know who the letters were going to, so I couldn't have been part and parcel of this Stratcom to say how big or how small or what would happen.

MR BERGER: But if you did know who the letters were going to, then you could be part and parcel of such a Stratcom, correct?

MR RAVEN: No, because my line is not Stratcom, there were people who were trained in Stratcom.

MR BERGER: You are not, I have dealt with this and I am not going to go through this, but I pointed out to you that I wasn't saying that you put together the Stratcom, I am saying to you that you were advised of the Stratcom so that you could put together a bomb which would accord with the Stratcom which the Stratcom people were putting out?

And if you had known that the bomb was going to Jeanette Schoon and if you had known that the bomb was going to Ruth First, then you would have been able to devise a bomb which would comply with the Stratcom, am I right?

MR RAVEN: Well, those are suppositions. It is a suppose, suppose, suppose. I cannot answer on a supposition, because it didn't happen. I am talking now on facts, not on suppositions.

CHAIRPERSON: We have been told as I recollect the evidence, that Colonel Goosen originally said he wanted a bomb the size of a handgrenade, which Major Williamson understood to mean containing the same explosives as a handgrenade which would be 100 g.

Were you told to make a letter bomb using 100 g of explosives?

MR RAVEN: That is correct Mr Chairman.

CHAIRPERSON: So it wasn't left to you to decide, you were asked to make a bomb of a certain size?

MR RAVEN: That is correct.

CHAIRPERSON: The size was somebody else's idea?

MR RAVEN: That is correct Mr Chairman.

CHAIRPERSON: And can you tell us just how much explosive force would 100 g normally have?

MR RAVEN: Well, 100 g is the standard load used in the fragmentation handgrenade.

CHAIRPERSON: So it has a lot of explosive power?

MR RAVEN: It has a lot of explosive power Mr Chairman.

CHAIRPERSON: Because in the fragmentation handgrenade it has to fragment the whole of the case of the handgrenade and then distribute the shrapnel a considerable distance around?

MR RAVEN: At considerable speed and force.

CHAIRPERSON: So this was, you were asked to make a powerful bomb, not one that would just injure someone who is holding it 30 cm away from his chest?

MR RAVEN: That was the idea I got when I had the request, 100 g would be enough to kill or seriously injure whoever opened or handled the device.

CHAIRPERSON: But it would also cause other damage around it?

MR RAVEN: Exactly.

CHAIRPERSON: Thanks.

MR BERGER: Well, on that you conceded yesterday that a letter bomb may kill innocent people?

MR RAVEN: That is correct.

MR BERGER: And you knew that at the time when you made the bombs?

MR RAVEN: That is correct.

MR BERGER: That bomb could have been sent to a member of the ANC? In fact when you got the instruction, you say you thought it was going to a member of the ANC.

CHAIRPERSON: I think he qualified it a little bit by saying a high profile or senior member, didn't you? Remember you did tell us you thought it was going to?

MR RAVEN: Yes sir.

MR BERGER: It could have been going to a personal enemy of Mr Williamson's, correct?

MR RAVEN: It could possibly.

MR BERGER: It could have been going to the leader of the Opposition?

MR RAVEN: It is possible, highly unlikely, but possible.

MR BERGER: And whoever was blown up by your bomb, then you could always turn around and blame the ANC and say that they had sent the bomb?

MR RAVEN: That wouldn't have been my job.

MR BERGER: Yes, but you knew that that was possible at the time?

MR RAVEN: It is a possibility, yes.

MR BERGER: Well, you knew that the bomb was going to the ANC, that is what you say.

MR RAVEN: Well, a high profile member, right.

MR BERGER: Yes. And sooner or later somebody was going to be killed by a letter bomb, you knew that?

MR RAVEN: Correct.

MR BERGER: And you knew that fingers would be pointed at the South African government?

MR RAVEN: That is correct.

MR BERGER: And what did you think the South African government would say?

MR RAVEN: Denial.

MR BERGER: And the basis for that denial?

MR RAVEN: It would be one or other Stratcom or cover story by whoever is making up the cover stories.

MR BERGER: You knew that in advance?

MR RAVEN: I didn't know it, a supposition yes, but I didn't know it for a fact.

MR BERGER: It could have been a bomb to a University lecturer?

MR RAVEN: As I have stated, not knowing the addressee, it could have been sent to anybody.

MR BERGER: Yes. Including a University lecturer?

MR RAVEN: Well, anybody ...

ADV DE JAGER: Or an Advocate or a preacher or a house servant or whoever?

MR RAVEN: Whoever.

MR BERGER: And whoever you sent it to, be it a University lecturer or a preacher, there was a strong possibility that there would be other people around that person when that person opened the letter?

MR RAVEN: Can I just qualify there, it wasn't who I sent it to, I would rather you say that the person who it was sent to, not who I sent it to.

MR BERGER: Well, you were making a bomb that you knew would be sent on by some or other of your colleagues to the intended victim.

MR RAVEN: Correct.

MR BERGER: And you knew that that intended victim could open that letter in the presence of a whole lot of other people?

MR RAVEN: He could also, she could also, they could also open it alone.

MR BERGER: Yes, but the very real possibility existed that they could open it in the presence of other people?

MR RAVEN: But reality you have it as well, that it could be opened while they were alone.

MR BERGER: Mr Raven, please just listen to me.

CHAIRPERSON: Isn't this pure argument?

MR BERGER: No.

CHAIRPERSON: The probability is very considerably. He has conceded there was a danger, it could be opened in the presence of others, I don't think you can take it further than the danger is a real danger.

MR BERGER: Well, this is the point of my question.

CHAIRPERSON: It could have been opened in a post office when there was a queue of people behind the recipient, couldn't it?

MR RAVEN: Yes Mr Chairman.

MR BERGER: You see, the bomb could have been intended for Helen Joseph and then you would have said that was fine, right?

MR RAVEN: Correct.

MR BERGER: It could have been intended for Bishop Tutu and you would have said that was fine?

MR RAVEN: If, let me just restate that, if it was sent as you say to Bishop Tutu then the powers that be, would make that decision.

I would make the bomb, the powers that be would then designate the target.

MR BERGER: And it could have been and this is the last person whose name I am going to mention, it could have been sent to Helen Suzman, Mrs Helen Suzman?

MR RAVEN: For the same matter it could have been sent to Mr George Bizos.

MR BIZOS: I very much fear you, if that gives you pleasure. And I would have expected you to be ashamed.

MR BERGER: And Mr Bizos could have opened that letter in the presence of his children and grandchildren and his wife, correct?

MR RAVEN: Correct. These are all possibilities.

MR BERGER: All possibilities which were present in your mind when you made that bomb. Now my question to you is, surely you needed to know to whom the bomb was being sent?

MR RAVEN: For what reason?

MR BERGER: Because you had to exercise a judgement Mr Raven, you had to act within some limit of decency and morality, that is why?

MR RAVEN: Mr Chairman, as I said we were in a state of war. I was given the instructions to make, manufacture an improvised explosive device which I did. The knowledge of the addressee was unknown to me.

I think that the question placed before me now, would have to have been taken by whoever gave the orders or whoever posted the IED or the letter.

MR BERGER: You see Mr Raven, there will be argument on this in due course, but I have to give you an opportunity to deal with my propositions.

I am putting to you that it is not good enough for you to say I was simply following orders. You had to be bona fide in what you were doing.

ADV DE JAGER: Mr Berger, really, I don't want to introduce other matters, but I am sitting here, I've also got to judge about bombs being placed on farm roads, the Church Street bomb, all the other bombs. Did they consider whether it could kill children or women or churchgoers or whoever?

MR BERGER: Mr De Jager, that is for argument in that application.

CHAIRPERSON: But isn't your argument here what you are putting to the applicant, you should never have made a bomb in these circumstances when you knew it was going by post and it might be opened and kill innocent people?

MR BERGER: No.

CHAIRPERSON: That is what you are coming to. It doesn't matter to him, the danger is not in knowing who the target was because the target has been selected by those above him as being a proper target, so he doesn't have to know that. He can rely on those above him to select a proper target.

What you have been questioning him about is the danger to others, people who have not been selected?

MR BERGER: There are two bases in there Mr Chairman. The one is the danger to others and the other is the person to whom it was sent.

That is why I mentioned the name ...

CHAIRPERSON: But he is not an expert, he does not know what the choice is based on. He has said and I think we have heard it again and again, he relied on those who placed the order, to have chosen the target. He didn't want to know.

MR BERGER: Chairperson, and that is what I am questioning because ...

CHAIRPERSON: If you are saying that everybody acting under military orders has to know what the target is before they open fire, before they drop a bomb, matters of that nature, you are going to have an awful lot of persuasion to do.

MR BERGER: It is not the same Chairperson and that is why I mentioned the names of Helen Joseph, Bishop Tutu and Helen Suzman.

If you had known that the bomb was being sent to them, would you nevertheless have made the bomb and sent it on?

MR RAVEN: I wouldn't have known it was going to them.

MR BERGER: If you had known?

MR RAVEN: But I wouldn't have known, so I can't make that supposition.

MR BERGER: Mr Raven, please just answer my question. If you had known that the bomb was being sent to Helen Joseph, would you have continued to make that bomb and sent it on?

CHAIRPERSON: You are asking two questions, which he will immediate refute. He has told you a hundred times, he did not send the bombs on.

So leave the send on, out of it.

MR BERGER: As you please.

CHAIRPERSON: If you had been told that you are being asked to make a bomb that was going to be used against Helen Joseph, would you have made the bomb?

MR RAVEN: If that orders came through the channels, I would believe that the powers that be, had selected the individual as a legitimate target and I would have made the bomb.

MR BERGER: You see what I am going to suggest to you is that you needed to know to whom the bomb was being sent and you had the means to know, without asking anyone. All you had to do was to look at the intercepted mail item and you would have seen to whom the bomb was being sent.

And you needed that information.

MR RAVEN: On what grounds is that supposition made?

MR BERGER: That you needed it.

MR RAVEN: That I needed to know who it went to?

MR BERGER: So that you could act within reasonable limits, so that you didn't act without regard to any limits.

MR RAVEN: I don't understand the statement that you are making.

CHAIRPERSON: What is being put to you as I understand it Mr Raven, is that it is going to be argued that it is not sufficient for you to simply say I was ordered to do something, so I did it.

That you should have endeavoured to discover for what purpose the explosive device you have been told to make, was going to be used and then exercised your mind as to whether that was a proper purpose.

MR RAVEN: Is that the question that is being asked?

MR BERGER: Yes, that is the question.

MR RAVEN: The principle of need to know, comes in. I mean it wasn't important to the manufacturer of the device to know who it was going to.

I have parameters, 100 g, I have an envelope, A4. I don't need further information or particulars to construct the device.

MR BERGER: If the bomb was going to Helen Suzman and you knew that, you could have said I draw the line here, I am not making a bomb for Helen Suzman.

MR RAVEN: I could have said it.

MR BERGER: That is why you needed to know. Mr Raven, as far as the size of bombs are concerned, the London bomb you say was only a kilogram. Please have a look at Exhibit K.

Whilst you are looking at Exhibit K, and this really Chairperson, is for the assistance of the Committee more than anything else, there have been a lot of maps put in of the ANC offices, we have got a map drawn by a person who was in the office and which will assist the Committee in seeing where exactly everything was placed, the school, the yard, the ANC office and so on.

I suggest that is more accurate than my learned friend, Mr Visser's map.

MR VISSER: It is not my map.

MR BERGER: It is not drawn to scale, but it sets out where everything is situated.

ADV DE JAGER: This must be Mr Berger's map?

MR BERGER: Yes, we can call this Mr Berger's map.

MR VISSER: Mr Chairman, while we are at Annexure K, interestingly enough I just noted in this newspaper article in the third column it mentions there that ANC researcher, Mr Mbatha who was asleep in the building, narrowly escaped injury. I just want to point that out Mr Chairman.

It mentions researcher, not refugee.

MR BERGER: Chairperson, could this map be marked Exhibit NN.

CHAIRPERSON: This disrupts all that we have been told of before, that there was no office sticking out at the back of the ANC office, with the printing press in it.

MR BERGER: That is why I thought Chairperson, it would be useful if I handed it up to you. This is a map not drawn to scale, but drawn by the Deputy Minister of Finance, Gill Marcus.

ADV DE JAGER: This demolished after blast as unsafe?

CHAIRPERSON: This is a wall.

MR BERGER: Yes.

ADV DE JAGER: Was that only a wall or was it a room?

MR BERGER: No, it was a little building behind the Italian delicatessen and it was an Italian delicatessen and not a Greek delicatessen.

And Mr Raven, this now may assist you in describing things a bit better about London, the London office. Would you agree that this map is accurate?

MR RAVEN: No, not to my knowledge.

MR BERGER: Where it says there shops and an arrow, Chairperson, it doesn't mean that the shops ended there. They continued down Penton Street.

CHAIRPERSON: I would suggest that we take the adjournment now and people can consult with their various colleagues as to this new map which now shows, a new plan now shows a fence, 12 ft back from the wall at the back of the ANC office, which nobody has mentioned up to now.

It doesn't show the trench that we were told about where the explosives were put in and all sorts of other problems now arise. Because none of this previous evidence was as far as I can recollect, challenged.

Perhaps you will now use the opportunity to try to reach some agreement on what in fact existed there.

MR DU PLESSIS: (Microphone not on)

CHAIRPERSON: Well, we offered to do that at the commencement of this hearing, and received no support whatsoever. Quarter to two.

COMMITTEE ADJOURNS

ON RESUMPTION

ROGER HOWARD LESLEY RAVEN: (still under oath)

CHAIRPERSON: As far as the London ANC building, we may have an opportunity of getting someone to take photographs there next week. A young lady who has been with us here, is going back to London - somebody suggested that she might.

MR BIZOS: (Microphone not on)

CHAIRPERSON: Do you think you can be of any assistance?

MR BIZOS: ... change since 1982.

MR LEVINE: I am instructed Mr Chairman, that it has been quite significantly rebuilt, but I can't speak to the extent.

CHAIRPERSON: The layout may be the same. The photographs showing the front of the streets and the back ...

Okay, let's go on.

CROSS-EXAMINATION BY MR BERGER: (continued) Thank you Chairperson. Chairperson, before I forget, might I hand in the video that was shown this morning as an Exhibit, and could it be marked, I think it is Video 6.

CHAIRPERSON: 6.

MR VISSER: Mr Chairman, may I just comment on the plan that was handed to us, Exhibit NN. I have given, we have given due consideration to this plan Mr Chairman, but there are various aspects that we differ with and therefore we cannot agree or admit the plan.

If it is introduced on the basis that there will be evidence, or somebody who drew this plan will come and testify, Mr Chairman, then I won't object against further cross-examination. However, if it is introduced on another basis, that there won't be any witness coming to testify about this plan and who drew the plan and when it was drawn, Mr Chairman, then I object against it.

MR BERGER: No, Ms Gill Marcus drew the plan as I indicated and she will be called to give evidence.

CHAIRPERSON: While we are on the subject of plans, etc, I think I have available at home a map of London, but I won't be getting that till after the hearing.

Has anybody here got a map that we could get an opportunity of looking at to get some idea of the geographical layout of where this was? Could we borrow it? I don't want it as an Exhibit, merely ...

MR VISSER: There is a small one floating around here, but I have a large one at home.

CHAIRPERSON: If you can bring it here tomorrow morning, we can all have a look as to where this ...

MR BIZOS: Not tomorrow morning.

CHAIRPERSON: No, don't come near us tomorrow, Monday morning. I think it might, I don't know if the rest of you have been able to see geographically where it is with regard to the hotels they stayed at and those things, but I certainly I think, would find it helpful if you could bring it Mr Visser, we would be obliged.

MR BERGER: Thank you Chairperson. Mr Raven, you have had an opportunity to look at this plan, Exhibit NN?

MR RAVEN: That is correct.

MR BERGER: And you have discussed it with your erstwhile colleagues at lunch? Correct?

MR RAVEN: Yes.

MR BERGER: What part of the map do you disagree with?

MR RAVEN: Number 1, on the left hand side, in White Lion Street is written there fence and gate, not wall. It wasn't a fence in the sense of a diamond meshed fence. It was a fence in the case of corrugated iron sheeting.

Secondly ...

MR BERGER: And that was corrugated iron that you couldn't see through?

MR RAVEN: You couldn't see through it. Secondly this wall demolished after blast as unsafe, I don't recollect a wall there at all.

The fence with this, where it is marked backspace plus minus 12 ft, there was no fence there. They haven't got the what shall we call it, gully, trench, it is not marked on here at all. And the annexure which housed the printing press is not depicted on this map at all.

MR BERGER: The what?

MR RAVEN: The annexure, the outbuilding, out-part where the printing press was against which wall the bomb was placed, is not depicted on this map at all.

MR BERGER: Well, where you see Gill's office, that would be the printing press.

MR RAVEN: Well, then you would have to push it out into the yard then. So, there is a number of things I don't agree with on this.

MR BERGER: Okay.

MR RAVEN: This map was this drawn now recently of her recollection of how it looked at a stage?

MR BERGER: That is correct.

CHAIRPERSON: Now, do I understand from this that the school was not to the north of the building, at the back of the yard, it was on the other side of White Lion Street?

MR BERGER: Indeed.

CHAIRPERSON: Or was there another school?

MR BERGER: No, the school that we have all been talking about, is the White Lion School which is on the left hand side of White Lion Street, yes. Would you agree with that Mr Raven?

MR RAVEN: I don't recollect seeing a school there at all.

MR BERGER: And then where is this empty yard, at the top of Exhibit NN, that line denotes the start of another building which was bordering onto the empty yard?

MR RAVEN: That is correct. So we have a wall to the east and a wall to the north.

MR BERGER: You've got a building to the north and a wall to the east.

MR RAVEN: Well, a building to the east, wall, building. I don't know what was on the other side of the wall.

MR BERGER: All right. Now, the windows in that building to the north of the empty yard, they were blown out by the blast?

MR RAVEN: I don't recollect there being any windows there.

MR BERGER: You don't recollect that?

MR RAVEN: No.

MR BERGER: Okay. The school on the left, to the west of White Lion Street was also damaged by the blast?

MR RAVEN: If that is the case, then this wall that has been demolished after the blast as unsafe, how high was that wall then?

MR BERGER: Well, this wall, this was a small building, an outbuilding behind the Italian deli that was destroyed. That is what is being indicated there, demolished after the blast as unsafe.

This outbuilding was destroyed by the blast. The blast continued over into White Lion, over White Lion Street and damaged the free school.

MR RAVEN: I have no knowledge of that.

MR BERGER: And then if you have a look at Exhibit K, which was what I had also referred you to, you will see there the top of the second column ...

MR RAVEN: Just hold a second please.

MR BERGER: Sorry. Do you have it Mr Raven?

MR RAVEN: Yes, I do.

MR BERGER: Top of the second column, this is the article entitled ANC blames boss bomber for London blast, 15 March 1982. The rear of the building is practically destroyed. It was a hefty bomb and we think it was placed rather than thrown.

A little bit further down, there is talk about the elderly woman who was taken to hospital. A little bit further down, a person on the scene says I ran into the Athens Cafe next door to call the Emergency Services and found people trapped behind a jammed door. The place was full of gas fumes and smoke was billowing out.

And then in the third column, middle of the column, you see there it says the back wall, this is the back wall of the ANC office, was blown away. The blast carried through the premises, ripping out shop windows up to 50 metres away on both sides of the road.

In other words through the building into Penton Street, and then ripping out shop windows up to 50 metres away on both sides of the road.

Would you have expected your bomb to cause, your one kilogram bomb, to cause this much damage?

MR RAVEN: It is possible.

MR BERGER: Did you do any recognisance of the office?

MR RAVEN: Yes, I did.

MR BERGER: You say you were there on the Sunday before and you did not see any children playing at the free school?

MR RAVEN: No, I didn't see any children there. I didn't even know it was a school.

MR BERGER: Were you informed by anyone, or did you observe anyone working in the ANC office on the Sunday before?

MR RAVEN: I didn't observe anybody there, and I wasn't told anybody was there.

MR DU PLESSIS: Mr Chairman, may I just come in here again. I believe we are still dealing with this issue on the basis on which you have indicated. You have asked us to present Heads of Argument to you about parties who are not opposing amnesty applications and the issue surrounding that.

I just want to enquire Mr Chairman, because the cross-examination is going on and on now about the London bomb, what is the relevance to that pertaining to the Schoon and First incidents?

MR BERGER: This particular witness as opposed to Mr McPherson, is directly involved in the amnesty applications relating to the death of Ruth First and Jeanette and Katryn Schoon, so his credibility is a key issue in the application.

MR DU PLESSIS: Mr Chairman, now we are back to exactly the same point. The point that was raised was can the credibility of a witness in one amnesty application, be used against him in respect of another amnesty application?

Is that relevant, firstly, and secondly, it goes further than this now. We find out now that not just is there cross-examination. Persons who are not opposing the applications, are now going to call witnesses to come and testify.

MR BERGER: No, when I referred to Ms Marcus giving evidence, she will be giving evidence on other issues as well.

MR DU PLESSIS: But she is also going to give evidence on this issue, Mr Chairman, so it takes that matter much further.

With respect Mr Chairman, I understood the ruling that you made that the cross-examination should have a relevance in respect of the Schoon and First incidents.

In my submission, just the answer that it relates to credibility, Mr Chairman, is not enough, with respect.

MR BERGER: Chairperson, the cross-examination of Mr Raven on a number of issues, I have hoped to demonstrate that he has been less than open with all material facts, in other words, he hasn't made full disclosure, that is what it relates to.

If we can show a pattern of a failure to make full disclosure, that is what we are trying to do. I am fully aware of the rules of cross-examination relating to issues of credibility, and that is why I put the question to the witness about the school. He gives an answer, I move on to something else. That is the basis of the cross-examination.

CHAIRPERSON: Let's try to get on with this now. How much longer do you think you will be?

MR BERGER: Less than an hour Chairperson.

CHAIRPERSON: Right.

MR BIZOS: Mr Chairman, if the concern is in relation to fitting in Gen Coetzee, I pick up the signal, I didn't know but speaking for ourselves, we are not going to detain the General in relation to this aspect. I don't know what our learned friend was going to do.

MR VISSER: Mr Chairman, Visser on record. I may inform the Committee that we have come to an agreement with my learned friend Mr Cornelius, and it will not be necessary to call Gen Coetzee Mr Chairman.

MR BIZOS: Well, that makes it easier, yes.

MR BERGER: Mr Raven, did anyone inform you that members of the ANC worked in the London office and in particular Ms Gill Marcus worked in the London office, every Sunday morning and had been doing so for many years?

MR RAVEN: Not to my knowledge.

MR BERGER: Did anyone inform you that members of the ANC had been working in the London office that Saturday, the Saturday immediately before, in other words the day before the bomb, that banners were being made in the office and that members of the ANC stayed there until nine or ten o'clock in the evening?

MR RAVEN: Not to my knowledge.

MR BERGER: We do know that the banners were still there when the bomb exploded, they hadn't yet been collected for the rally. Mr McPherson said so?

MR RAVEN: No knowledge of that at all.

MR BERGER: Why did you say in your application that it was a Sharpeville rally?

MR RAVEN: That was the information we had when we had the discussion prior to commencing with the operation.

MR BERGER: And that information you got from Mr Williamson?

MR RAVEN: No, I think it was Mr Taylor that told us.

MR BERGER: Where was that?

MR RAVEN: At the flat.

MR BERGER: Oh, you mean at that discussion the night before?

MR RAVEN: That is correct.

MR BERGER: Mr Williamson was there?

MR RAVEN: That is correct.

MR BERGER: In fact it wasn't a Sharpeville rally, Sharpeville was the following week, the 21st of March.

MR RAVEN: Which rally was it then?

MR BERGER: It was an anti-apartheid rally from Hide Park to Trafalgar Square.

Although the bomb was intended to blow into the building, you concede that it could and did blow out as well, and that is how the windows behind, on the north of the yard, were smashed.

CHAIRPERSON: He said he didn't see that and you accepted that.

MR BERGER: Let me put it this way, although the bomb was intended to blast inwards, do you accept that the bomb also blasted outwards, in a northerly and a westerly and an easterly direction?

MR RAVEN: There would have been displacement of air at that speed in the other directions. That is why if I may use as an example Mr Chairman, in the case of a claymore mine which is explosive ordinance, it is a flat mine with ball bearings on one side encased in resin and explosives on the back.

It is detonated in such a way and you know when you lie there, and you detonate it, it has a blast area back where the air is moving backwards, but the projectiles are moving forward. So there would be a movement of air at a terrific rate, going backwards.

MR BERGER: Did you know that there was a market, a Sunday market one block away from the ANC office?

MR RAVEN: I didn't see that.

MR BERGER: You say that when you set the bomb, you never had a minute hand, you only had an hour hand?

MR RAVEN: That is correct.

MR BERGER: You placed the hour hand at nine o'clock, is that correct?

MR RAVEN: No. One would have to work from nine o'clock backwards, from where the screw was inserted through the glass.

MR BERGER: Is it just coincidence that Mr McPherson in his amnesty application at page 133 of bundle 3, says that the bomb was programmed to explode at 9 am in the morning, and according to Exhibit K, according to the Police, the explosion occurred at 9 am. Would that just be coincidence?

MR RAVEN: No, I am not disputing the fact. The hand wouldn't be put at nine o'clock, because then it would go off, if it is at nine o'clock, it would go off three hours later.

MR BERGER: All right. I am not an expert on bombs.

You then appear to agree with me that the bomb was timed to explode at 9 am?

MR RAVEN: Well, between eight and nine o'clock, 08:30 and nine o'clock.

MR BERGER: I am putting it to you that it was timed to explode at nine o'clock, that is what Mr McPherson says at page 133 and that is what in fact happened.

MR RAVEN: I am not disputing the fact about what happened, I am saying that because it is only the hour hand, it wasn't possible to make it exact. But as I say, I am accepting what you are saying about nine o'clock, if the Police say it happened at nine o'clock, it happened at nine o'clock.

MR BERGER: No, what I am suggesting to you is that at your meeting that Sunday night, I beg your pardon, Saturday night, it was discussed that the bomb would be set to explode at 9 am and everyone knew that.

MR RAVEN: And I think the reason for that was that the last member of the team, if I remember correctly the instructions were that the team must be out of the United Kingdom when the bomb goes off. I think nine o'clock was the, let's call it the window when the last member would get a flight out of England to Frankfurt.

MR BERGER: So we are agreed that the bomb was set to explode at nine?

MR RAVEN: Yes.

MR BERGER: When you left for London, or before you left for London, Mr Williamson said we are intending to blow up the ANC office and the SACP office, correct?

MR RAVEN: No, he said we were going to target them.

MR BERGER: Yes.

MR RAVEN: All right.

MR BERGER: Both offices, and then you looked at the photographs and you said you needed to do an in loco inspection?

MR RAVEN: No, I said I need new or further information and photographs on the ANC office, but I would have to go in loco to go and look at the SACP office in Goodge Street?

MR BERGER: Correct. So by the time, when you left Mr Williamson and you left for London, both you and he was still of the view that if possible, the SACP offices would be targeted?

MR RAVEN: If possible, at the time before I left, I still said I don't think that the Goodge Street offices of the SACP were viable.

MR BERGER: Yes. No, what I am saying to you is that when Mr Williamson sent you ahead to still establish whether it will be possible and if so, then an attack would be launched on the SACP offices?

MR RAVEN: That is correct.

MR BERGER: Please turn to page 143 of bundle 3. Now I am using these pages, although the come from the London bomb, I am not concentrating on the London bomb, these pages are common to all your applications, so we might as well look at these.

These deal with your political objective and motive. Am I correct if one has a look at page 145 influencing of white voters, and this, you dealt with this in your evidence in chief, am I correct that what you have set out here, or what you have agreed to here, creates the impression that white voters were manipulated by the Police in general and by the Security Police in particular?

MR RAVEN: Is that your question?

MR BERGER: Yes.

MR RAVEN: I would say in the timespan of 1982, taken what was going on in the country, I would say not only the Security Police, I would say the Security Forces.

MR BERGER: Including the Security Police?

MR RAVEN: Well, I just said that.

MR BERGER: Okay. If you have a look for example, at B2, a disinformation campaign regarding the effectiveness of the war against communism and terrorism, had the effect that white voters were under the impression that the Security Forces were easily winning the war, because activists either disappeared or were murdered in secretive ways without the guilty parties ever being caught or prosecuted. What you are saying there is that the Security Forces knew what the correct position was, but white voters were duped into believing that the situation was otherwise?

MR RAVEN: Well, that is basically, yes, the perception was created that we were winning the war.

MR BERGER: Same as in 4, the public had suspected what the Security Police were doing in regards to the elimination of terrorists and activists and were brought under a false impression as to the effectiveness of the war against terrorism and the Red Danger?

MR RAVEN: Correct. The people were brought under the impression that we were winning the war and that actually we were doing better than what we really were doing, we were less effective than what we were putting up to be.

MR BERGER: Then you say in 5 that the aforementioned had created trust in the apartheid government, moving whites to once again vote for that government. Would I be correct in saying that one of the things that motivated you in the actions that you took, was to support the apartheid government?

MR RAVEN: Well, I was working for the apartheid government, that is why I supported the apartheid government which was the National Party.

MR BERGER: And does that mean that you supported apartheid?

MR RAVEN: Yes, I did.

MR BERGER: And that is why anyone who was suspected of being an enemy of the National Party, was regarded by you as a fair target?

MR RAVEN: Broadly speaking, yes.

MR BERGER: The reason I say that is because of what you say at page 142, bottom. Again this entailed the surveillance of suspected agents of the ANC and anyone suspected of being enemies of the National Party?

MR RAVEN: Yes.

MR BERGER: Then, at page 148 disinformation. The picture that was sketched to the general public was that it was only black on black violence which destabilised the black townships specifically. It was painted to be a struggle between blacks. Do you have that, page 148?

MR RAVEN: Yes.

MR BERGER: And you told the Committee that what you were alluding to there was Third Force activities?

MR RAVEN: That is correct.

MR BERGER: So not only was the white electorate being duped as you said, into thinking that the war was being won, but the white electorate was also being duped into who was actually fighting that war, correct?

MR RAVEN: That is correct.

MR BERGER: And in fact, the Third Force or - and we know that the Third Force was certain elements within the Police and the Army, that the Third Force was fuelling the war so that the white voters would think that they were under threat from black citizens of the country, so that they would vote for the National Party?

MR RAVEN: That is correct.

MR BERGER: And point 2 is, you say that the above led to a fear amongst whites as to the dangers in the above regard, particularly that such actions could possibly run over into white areas?

MR RAVEN: Which in fact it did do.

MR BERGER: Yes, because of the actions of the Third Force, is that correct?

MR RAVEN: Not necessarily. I mean we have the Church Street bomb. The Church Street bomb definitely wasn't Third Force.

MR BERGER: No, no. Look at what is said here in your application and as you have said that the war was being fuelled by members in the Police and the Security Force ...

MR DU PLESSIS: No Mr Chairman, it stated there the picture that was sketched to the general public was that it was only black on black violence. It is nowhere stated and Mr Raven didn't testify that a Third Force fuelled the war. My learned friend is making deductions which are not true.

MR BERGER: He has just conceded that point a few minutes ago.

MR DU PLESSIS: But then the question my learned friend asked, was wrong, because that is not what is stated there. It is stated there the picture that was sketched to the general public, was that it was only black on black violence and the question my learned friend asked, was premised on the basis that the Third Force is fuelling the war, which is wrong, because that is not what is stated there.

CHAIRPERSON: As I understood it, the question was that it was not in fact only black on black violence, some of the violence was caused by the Third Force, but the picture that was put to the public was that it was black on black.

MR DU PLESSIS: Yes, as long as we understand it Mr Chairman. I just don't want confusion.

ADV DE JAGER: Yes, my recollection is that the witness himself in evidence in chief, or under cross-examination when referred to this paragraph, he referred to a Third Force.

MR BERGER: Indeed. And you see Mr Raven, after you have, for example in 4 you say voters were once again persuaded to vote for the National Party in the light of the Black Power in order to keep the government in power. So it was a Black Power tactic which was fuelled by Third Force activities, correct?

MR RAVEN: It is possible.

MR BERGER: 5, the disinformation campaign had therefore worked and was fully effective. Now, what I want to suggest to you is that on this evidence it would appear that you knew that the picture that was being painted for white voters, was an incorrect picture and that if the true picture had been sketched to white voters, they might not support the National Party?

MR RAVEN: In 1982, that is quite correct.

MR BERGER: And in 1984 as well?

MR RAVEN: Yes.

MR BERGER: So whilst one can talk about the atmosphere that was being created on television and on the radio and in the newspapers, this Black Power and Red Danger, the Security Police and I am singling out the Security Police because you were a member of the Security Police and the Intelligence Section of the Security Police, which you were a member of, knew that that was not the correct position. Would I be correct?

MR RAVEN: Well, it would not be totally correct.

MR BERGER: What would not be totally correct?

MR RAVEN: Well, incidents did happen, incidents, we might have fuelled more incidents, but if 10 incidents happened, where of three or four were put at our doorstep, which is quite possible, but the fact remains that there was violence in the country in 1982 ad 1984.

MR BERGER: You said in your evidence that the whole point of this exaggeration, this disinformation, this influencing of white voters was to preserve western norms. Do you remember saying that?

MR RAVEN: Yes, I do.

MR BERGER: And would you agree that it is a western norm, not only a western norm but it is certainly a norm in the west, that all people have the right to vote?

MR RAVEN: That is correct.

MR BERGER: And did you know at the time that the ANC was calling and had been calling for decades for all citizens of the country, to be given the right to vote?

MR RAVEN: That was laid out in the Freedom Charter.

MR BERGER: Indeed. And that that is what the struggle of the ANC was about, it was a liberation struggle for a universal franchise. You knew that, didn't you?

MR RAVEN: I knew that.

MR BERGER: And that was the struggle that you were fighting against?

MR RAVEN: That is correct.

MR BERGER: Now I don't want to go through each and every item because it will take long and it will be laborious, you have said that - it starts off at page 143 to 153 if bundle 3, it is 33 to 43 of bundle 1 and it is 97 to 197 of bundle 2, it is all the same. Also 46 to 48 of bundle 1, and 110 to 112 of bundle 2, that is where you set out all your political arguments or political motivation.

I would like you please just to state specifically what of that motivation applied specifically to Ruth First, to Jeanette Schoon and to Katryn Schoon?

MR DU PLESSIS: Mr Chairman, I have to come in here. My learned friend still doesn't understand apparently. This was set out as a general motivation in respect of the Security Forces with which they all acted.

This is a general motivation with which the Security Forces acted and with which Mr Raven agrees in respect of that time. If Mr Raven had known that Ruth First or Jeanette Schoon was a target, on his evidence, this question would have been fair. But it is immensely unfair to ask Mr Raven what his motivation was for killing Jeanette Schoon and Ruth First at the time, when he was in a position that he didn't know they were targets.

If the question is phrased what was Mr Raven's political view in respect of his actions at that time, against the liberation movements, that would be a fair question Mr Chairperson.

MR BERGER: Chairperson, one of the questions on the prescribed form and I know exactly what the background to all of this was, but one of the questions on the prescribed form is that the applicant for amnesty must state and I have the Afrikaans here, name the political objective which was to be achieved and then (b), your motivation why your deed is connected with a political objective.

CHAIRPERSON: And what he has said, his deed was to make a letter bomb on the orders of his seniors. He has not mentioned that he had any knowledge of these particular individuals.

MR BERGER: Yes.

CHAIRPERSON: He is not making out a case for amnesty in that regard. He is making out as I understand his case, I was a member of the Police Force, I was ordered to do this, I was satisfied that those giving me the orders, knew what they were doing so I carried out the orders.

MR BERGER: Chairperson, that is not the case that is made out in the application.

That is why I am asking the witness now.

CHAIRPERSON: What is made out in the application? I had a motive for Ruth First which was the following, show me that in the application.

MR BERGER: As far as political objective are concerned, there are pages and pages and pages, and it is an application in relation to the death of Ruth First.

MR VISSER: With respect Mr Chairman, the Act makes provision in Section 22(b) that your actions could either have been against a member or supporter or against a publicly known liberation movement. The case of Mr Raven is that he acted under orders, he made a bomb and his actions were at all relevant times, done with a political motivation because his evidence was that he thought he had acted against the liberation movements, that the Security Police had all acted against the liberation movements, and what is set out as this general motivation, was the general background and motivation with which the Security Police acted at that time.

He also testified that he didn't know that the bomb was going outside the country, or inside the country. The bomb could have gone to a Trade Unionist in South Africa, the bomb could have gone to some other leader in South Africa, the bomb could have gone to somebody outside South Africa. And for that purpose, the general background in respect of his political motivation is set out there.

There was also evidence led in respect of the fact that the Security Police acted on a political basis, that they were the Political Police of the National Party and that is the case of Mr Raven.

That is why I mention Mr Chairman, if the question is pertaining to this, can he indicate if one takes him back to the time when he got the order, with what political motivation did he make the bomb, what did he believe was the Security Forces doing at that time, and what was he participating in, that is a fair question.

MR BERGER: Chairperson, my learned leader Mr Bizos, would like to say something, but before he does ...

CHAIRPERSON: Mr Bizos has elected not to lead evidence in respect of this witness, this applicant. What do you want to argue about now Mr Bizos?

MR BIZOS: Mr Chairman, the question raised is a question of interpretation of the Section. I don't want to argue anything now.

We certainly, but may I finish Mr Chairman.

CHAIRPERSON: I think you said you didn't want to argue.

MR BIZOS: Not to argue the merits of the application Mr Chairman, the matter is going to be argued when all the evidence is heard Mr Chairman.

What I would suggest is that the cross-examination be allowed without my arguing now why I believe that the submission made by Mr Du Plessis, is not well founded Mr Chairman, unless you want me to in support of that suggestion.

But I think that it would be easier if we hear the evidence Mr Chairman, allow the cross-examination ...

CHAIRPERSON: We have heard the evidence at great length, similar questions have been put by your junior again and again Mr Bizos.

MR BIZOS: Mr Chairman, let us deal with the matter in issue Mr Chairman. The suggestion is that the cross-examination about his personal motivation should stop, because we hear from Mr Du Plessis ...

CHAIRPERSON: No, we have heard from the applicant repeatedly that there was no personal motivation. Have you not?

MR RAVEN: No. No Mr Chairman.

CHAIRPERSON: Has he not said that repeatedly?

MR BIZOS: He has said that and it is based upon the assumption that the Committee will make a finding of fact that he did not know against who the article was directed.

Assume that we do persuade you Mr Chairman, that he is being untruthful about that.

CHAIRPERSON: Then he has not made a full disclosure and he is not entitled to amnesty.

MR BIZOS: But in addition to that, in addition to that Mr Chairman, in addition to that it may well be that if he did know and additional ground to the failure of full disclosure, is the proportionality case as to whether a person in the position of Ruth First or the Schoon's was a proper target ...

CHAIRPERSON: But he has said Mr Bizos, he didn't apply his mind to them. He did nothing, hasn't he?

MR BIZOS: On the assumption that he is believed that he did not know to whom they were addressed Mr Chairman. We may find ourselves in a position at the end of it Mr Chairman, that we may successfully persuade the Committee that he is not to be believed as to whom they were directed, and then be deprived of the opportunity of saying that he did know and if he did know, he had no right to make them and allow them to be sent out to the ...

CHAIRPERSON: But that has been put to him at great length by your junior, that he knew the target, he had no right to target people like that, hasn't it?

MR BIZOS: Yes, it has.

CHAIRPERSON: Hasn't that been put?

MR BIZOS: It has Mr Chairman, but he has given a list of political motivations and it is a permissible line of cross-examination show me which ones you are relying on and which are of a general nature Mr Chairman.

First of all Mr Chairman, ...

CHAIRPERSON: Mr Raven, do you rely on any of these grounds of political motivation for having prepared a bomb to kill these people?

MR RAVEN: Yes, I do. Yes, I do.

CHAIRPERSON: Which one?

MR RAVEN: Intimidation, 1, 2, 3, 4.

CHAIRPERSON: All in general, do you say that is applicable?

MR RAVEN: 5 and 6, yes sir.

CHAIRPERSON: Intimidation, page what is that?

MR RAVEN: Page 34, bundle 1.

CHAIRPERSON: You say you rely on all of those?

MR RAVEN: That is correct sir.

CHAIRPERSON: Carry on.

MR BERGER: Thank you Chairperson. Which of those that you rely on Mr Raven, have a direct bearing on Ruth First, Jeanette Schoon or Katryn Schoon?

MR RAVEN: I would say number 1.

MR BERGER: That is on page 34(i)?

MR RAVEN: That is correct.

MR BERGER: This was to prevent further action taken by them and to take preventative measures and to eliminate potential activists or terrorists? Anything else?

MR RAVEN: Bearing in mind, this is as I would take it now, in 1982 a lot of these things would be applicable as well, but more in a general sense like number 2, freedom organisations such as the ANC were being dissuaded to give public support and momentum to the freedom struggle.

By these actions, they were forced underground or even further underground and a lot of the members of potential members were scared to join the organisation because they saw well, no matter where we are, these people can get at us, so it put the fear of God into them.

Number 3, there was a total feeling of distrust between MK and ANC members and supporters as to who to trust or not. That was a Stratcom cover up action, where we could then claim denial.

Number 4, the modus operandi of the Mosad of immediately retaliating after operations of activists. There we have the London bomb.

MR BERGER: Not Jeanette Schoon or Katryn Schoon or Ruth First?

MR RAVEN: No, number 4, I would say would pertain to the London bomb. Number 5, elimination took place in regard, now if number 5, at that time, we are now having a supposition that I knew that the bomb that killed Ruth First, if I was known or if I knew that it was actually aimed at Joe Slovo, that would have been correct, because there was no way that we could arrest Mr Slovo, we couldn't afford to arrest him and bring him before a Court because if he was arrested and sentenced, on his release we would have a second Nelson Mandela.

We would have a hero which is now part of the struggle, which is now being set free.

CHAIRPERSON: You say there is no way you could have arrested and sentenced Joe Slovo?

MR RAVEN: Well, we wouldn't be able to get him out of the country wherever he was hiding.

CHAIRPERSON: And if he was arrested and sentenced to 30 years, did you seriously in those days think that that would mean he would come out a hero in 30 years' time?

MR RAVEN: Well, it happened to our President after 28 years Mr Chairman.

CHAIRPERSON: Yes, and did anyone believe it when they first arrested him?

MR RAVEN: I couldn't say that.

CHAIRPERSON: No.

MR BERGER: Anything else Mr Raven?

MR RAVEN: And number 6, all the above had to lead to the demoralisation of MK and other military wings of the freedom fighters, it would lead thereto that they could not act as sufficiently in the struggle to reach the targets and goals of the liberation movement.

There they would see the ability of the Security Forces to eliminate high profile activists or people even in foreign countries.

MR BERGER: Yes? Anything else?

MR RAVEN: Influencing the white voters. That is all in the timespan of that time, but not relating directly to the cases of Ms First and Schoon.

MR BERGER: So you are saying that the death of Ruth First and Jeanette Schoon was not intended to have any influence on white voters?

MR RAVEN: In a general term, it could.

MR BERGER: How?

MR RAVEN: Showing them that the Security Forces are in a position to take out enemies of the State, activists, terrorists, whatever in foreign countries.

MR BERGER: Or international speakers? All right, continue. So all of (b) the influencing of white voters in a general sense, was achieved by the death of Ruth First and Jeanette and Katryn Schoon?

MR RAVEN: Broadly speaking, I would say yes.

MR BERGER: In the protection of information and the prevention of deeds of terror, I would say point 4, where activists wanted to go into training either in the country or abroad, they necessarily had to be eliminated to prevent the destabilisation of the country and as people by way of deeds of terror, such as bomb attacks on Security Forces as well as soft targets.

As soon as the activists had received training, he was in a totally different class than normal activists, and his knowledge and skills were similar to those of the Security Police and he could therefore be much more effective in military operations.

Now the elimination of activists in foreign countries, made the potential terrorist scared if I can use the word, to leave the country, because he saw now inside the country, we are running around trying to evade the Security Police, but outside the country they were getting killed as well.

MR BERGER: So the death of Ruth First, Jeanette and Katryn Schoon is related to point 4?

MR RAVEN: That is correct.

MR BERGER: Okay. Point 4 has two paragraphs, both of them relate to the deaths of Ruth First, Jeanette and Katryn Schoon?

MR RAVEN: Yes sir.

MR BERGER: Okay. Bomb attacks?

MR RAVEN: I think point 2, if activists or supporters had become too militant because they had effectively influenced the security consciousness of a particular community, there were to be retaliations against them by way of bomb attacks and the supporters had a strong suspicion as to where the bombs came from.

This led to the dissuasion of the supporters to support the liberation struggle, because they did not know who would be next on the list. Here we have the case again of Ms First and Jeanette Schoon and Katryn.

MR BERGER: Anything else?

CHAIRPERSON: So that is in respect of people who had become too militant or had effectively influenced the security consciousness of a particular community? Do you say that that is related to these two women, that they had become too militant or that they had effectively influenced the security consciousness of the Angolan or Mozambican communities?

MR RAVEN: No, I would say if they had sufficiently influenced the security consciousness of a particular community, community being our community.

CHAIRPERSON: Which community?

MR RAVEN: Well, the whites in South Africa.

CHAIRPERSON: By living in Angola and Mozambique, they were influencing the security consciousness of the white population in South Africa?

MR RAVEN: By the deeds, planning or whatever things they were carrying out on behalf of the ANC/SACP.

MR BERGER: You did know of course at the time that Ruth First was a named person, she couldn't be quoted in South Africa?

MR RAVEN: No, I didn't know that in 1982.

MR BERGER: So she couldn't influence the white voters at all. And Jeanette wasn't being quoted by the SABC or any media inside South Africa?

MR RAVEN: Well, in 1982 that was the broad sense of mind. I mean ...

MR BERGER: No, no, but we are relating it specifically to the people that I have named.

MR RAVEN: Yes, but now we are taking this back to 1982, 1984.

MR BERGER: You say it is applicable?

MR RAVEN: Yes.

MR BERGER: As well as point 3, you say it is also applicable?

MR RAVEN: That is correct.

MR BERGER: What activities had Ruth First become too effective and too successful in?

MR RAVEN: That I do not know because at the time that the device was sent, I didn't know it was going to her.

MR BERGER: Even after the fact when you learnt that it was to her, you still didn't know what activities she had been undertaking which had made her too effective and too successful?

MR RAVEN: I would say no.

MR BERGER: And the same for Jeanette Schoon?

MR RAVEN: Yes.

MR BERGER: Is there any more that you say is specific to the people I have named?

MR RAVEN: Disinformation, point 1, the picture that was sketched to the general public. That was a Stratcom.

Point 2, point 3, point 4 and point 5.

MR BERGER: All applicable to the people I have named?

MR RAVEN: Yes.

MR BERGER: I am sure we can cut it short from here because the purpose of interrogation, couldn't possibly have related to Ruth First, Jeanette and Katryn Schoon?

MR RAVEN: Correct.

MR BERGER: Nor the obtaining of information, page 40?

MR RAVEN: That is correct.

MR BERGER: So none of page 40 is applicable to Jeanette and Katryn Schoon and Ruth First?

MR RAVEN: Except I would say the last paragraph, the motive of my deeds were to fight communism and other strong freedom organisations, which led a revolutionary onslaught against the apartheid government, and to intimidate these fighters and their followers and to disrupt their freedom fight and plans.

A further motive was to fight terrorism and to promote safety and security in the country.

MR BERGER: Even after the fact, you didn't know the activities of Ruth First, Jeanette and Katryn Schoon, but you say this applies to them?

MR RAVEN: Well, they were members of the Party, of a freedom organisation.

MR BERGER: And on that ground it is applicable?

MR RAVEN: After the fact, yes.

MR BERGER: The rest is context? Now at page 46 you are asked again to state your political objectives sought to be achieved and I assume you say that all of this is directly applicable to Ruth First as well as Jeanette and Katryn Schoon?

MR RAVEN: Yes, I will.

MR BERGER: And (b), your justification for regarding such acts as an act associated with a political objective is also correct?

MR RAVEN: Correct as well.

MR BERGER: And directly applicable?

MR RAVEN: Correct.

MR BERGER: I must just point out to you that what you say at page 46 and 47 and 48 bears a remarkable similarity with what Gen Coetzee says in his application at page 91.

MR VISSER: Mr Chairman, I think my learned friend must now tell us what point he is making. If it bears a resemblance, what is he suggesting?

MR DU PLESSIS: And what are the similarities Mr Chairman, the quotations?

MR VISSER: If my learned friend wants to suggest that there is something underhanded going on Mr Chairman, or having gone on, let him say so. Let him not cast aspersions and leave innuendo's hanging in the air. Let him say so and we will take it up. Perhaps what my learned friend is missing Mr Chairman, is these were the facts of what was going on. It doesn't matter who talks about them and who refers to them, those were the facts about what was going on.

MR BERGER: Okay. If you will keep it open at 46 and also turn to page 91 of bundle 3. Before we get to Gen Coetzee, you make reference there to the MDM, last paragraph on page 46. Do you see that?

MR RAVEN: 46 of?

MR BERGER: Bundle 1.

MR RAVEN: Yes.

MR BERGER: The MDM was not in existence in 1982 or 1984, do you know that Mr Raven?

MR RAVEN: The Mass Democratic Movement?

MR BERGER: Correct.

MR RAVEN: I am not aware of that.

MR BERGER: When do you say the MDM came into existence?

MR RAVEN: I don't know, was it 1984?

MR DU PLESSIS: I think Mr Chairman, in all fairness, my learned friend stated that the MDM was not in existence at the time. Now the Jeanette Schoon incident was in 1984 and as far as I know, the MDM came into existence round about that time.

MR BERGER: My learned friend is referring to the United Democratic Front.

MR DU PLESSIS: All right, I may be wrong there.

MR BERGER: The MDM only came into popular (indistinct) in the late 1980's, after the banning of the United Democratic Front.

So your reference there to the MDM is just political rhetoric isn't it Mr Raven?

CHAIRPERSON: This was drafted by his Attorneys, they put this sort of thing in. What is the point of wasting time with this with him?

MR BERGER: Chairperson, he has confirmed that this is directly applicable to Jeanette and Katryn Schoon and Ruth First, he said it to me and he said it to the Committee as well Chairperson.

Chairperson, I am then going to leave it and it will have to be argued because, let me just say this Mr Raven, in case I am accused of casting aspersions without backing it up. If you look at page 91 at the bottom, Gen Coetzee talks about a People's War against South Africa and its population.

This so-called People's War was defined as being and if you have a look at what you say, at the bottom to achieve these aims and objectives, the ANC/SACP alliance, this is page 46, was actively involved in starting a People's War which they defined as follows, and there is the definition at page 47. There is the definition in Gen Coetzee at page 91.

Over the page, you say according to the ANC the revolutionary war rested on a few pillars namely, and you set it out, but Gen Coetzee ...

MR DU PLESSIS: But Mr Chairman, with respect, is my learned friend saying that each applicant must give a different definition of a People's War? Clearly this definition comes from the same book or the same fons et origo. The four pillars of the ANC's revolutionary war was well known to everybody.

What does my learned friend want to say, does he want to say that each applicant has to give a different view of the ANC's four pillars of revolutionary war? With respect Mr Chairman.

MR BERGER: I am saying that the structure of the document at page 47 follows a pattern. Gen Coetzee's document at pages 91, 91 follows the same pattern.

The paragraphs come in similar sequence. I can go on and point it out. One of the main objectives of the revolutionary onslaught one will see at page 47 ...

MR VISSER: Mr Chairman, may I interrupt, my learned friend does not have to go on. We will concede that they are the same. If that will help him, we will concede. We have conceded it before, not conceded, we have drawn your attention right at the beginning Mr Chairman.

We have explained it all. There were a number of considerations at the time Mr Chairman, so we will concede it for purposes of my learned friend's argument that they are similar or even the same.

MR BERGER: And that they were drafted by different Attorneys?

CHAIRPERSON: Who may well have collaborated with one another, it has been known, although we don't see much of it here.

MR BERGER: And similarly Chairperson, the clients may also have collaborated?

CHAIRPERSON: They may. They all came from the same organisation. They may have had the same beliefs.

ADV DE JAGER: I don't think really we should argue about this. I think the point has been made Mr Berger. I appreciate the point you are making, and I think we could proceed or you could proceed on this point if you think it is necessary.

MR BERGER: No, I won't take this point any further.

Mr Raven, is it correct that at the time of the London bomb, you were a Warrant Officer?

MR RAVEN: That is correct.

MR BERGER: What was your rank at the time of the bomb that killed Ruth First?

MR RAVEN: I can't remember. It could have still been Warrant Officer.

MR BERGER: And what was your rank at the time of the bomb that killed Jeanette and Katryn Schoon?

MR RAVEN: I might have been a Lieutenant.

MR BERGER: Isn't it correct that you were promoted to Lieutenant after these three bombs?

MR RAVEN: No, it is not correct.

MR BERGER: When were you promoted to the rank of Lieutenant?

MR RAVEN: Can I just consult here?

MR BERGER: Yes.

ADV DE JAGER: Mr Du Plessis, you haven't got a background of career paragraph here?

MR DU PLESSIS: No Mr Chairman, unfortunately in this one, not.

MR RAVEN: I attended the Officers' Course as a Lieutenant in 1986.

MR BERGER: So then I was correct, wasn't I? You were only promoted to the rank of Lieutenant after the three bombs?

MR RAVEN: Correct.

MR BERGER: Were you promoted as a result of your success in the three bombs?

MR RAVEN: No, I was not.

MR BERGER: Was anyone upset that you had been promoted to Lieutenant and they had, or he had not been promoted to Lieutenant?

MR RAVEN: Not to my knowledge.

MR BERGER: Did you write Officer's exams?

MR RAVEN: No, I did not.

MR BERGER: So how did it come about that you were promoted without having written an exam?

MR RAVEN: They do promotions of merit.

MR BERGER: And who was responsible for your promotion?

MR RAVEN: I would - somebody would have to have made up a memorandum which then would have to be approved by the Commissioner.

MR BERGER: So either you get promoted if you go on a course or if you don't go on a course, you have to be recommended and here the recommendation was approved by the Commissioner?

MR RAVEN: Yes, and then you still have to go on a course as well, which if you fail, you don't get promoted.

MR BERGER: But you were promoted before you went on the course?

MR RAVEN: No, I was not.

CHAIRPERSON: At that time were you under the command of Captain Botha?

MR RAVEN: That is correct.

CHAIRPERSON: Of the Counter-espionage Unit?

MR RAVEN: That is correct.

MR BERGER: But you never wrote and passed any exams?

MR RAVEN: That is correct.

MR BERGER: And the Commissioner who approved your promotion to the rank of Lieutenant was Gen Coetzee?

MR RAVEN: Well, if he was Commissioner in 1986, yes.

MR BERGER: Your senior at the time of the bomb that killed Ruth First, was Frans van Eeden? Would that be correct?

MR RAVEN: No, I think by that time I had already been seconded to Intelligence and I was under Major Craig Williamson.

MR BERGER: Who was the Head of the Explosives Unit at the time of the bomb that killed Ruth First?

MR RAVEN: That was Colonel Frans van Eeden.

MR BERGER: And did he assist you with the manufacture of that bomb?

MR RAVEN: No, as I stated both cases the bomb, the IED, I made on my own.

MR BERGER: The Head of the Explosives Unit at the time of the bomb that killed Jeanette Schoon, was Paul Hattingh, is that right?

MR RAVEN: No, I think Colonel Frans van Eeden was still there.

MR BERGER: Neither Paul Hattingh, nor Frans van Eeden assisted you in any way in the manufacture of either of the bombs?

MR RAVEN: Neither of them.

MR BERGER: Hattingh was succeeded by Van Eeden, am I correct?

MR RAVEN: Other way around.

MR BERGER: Other way around, sorry. Hattingh succeeded Van Eeden?

MR RAVEN: I believe so.

MR BERGER: Did you have any access to mail bags at what was then known as Jan Smuts airport?

MR RAVEN: No, not at all.

MR BERGER: Did you pick the locks of any mail bags?

MR RAVEN: No, I did not.

MR BERGER: Do you know of any royal seals that were stolen by the Security Police?

MR RAVEN: Royal seals?

MR BERGER: Yes, from the United Kingdom. Royal seals that were stolen so that letters could be opened or not letters, that mail bags could be opened?

MR RAVEN: No, I know nothing of that.

MR BERGER: Checked and then sealed again with the Royal seal?

MR RAVEN: Not at all.

MR BERGER: Would you agree with the proposition that Brigadier Goosen would not have touched Ruth First without Gen Coetzee's blessing?

MR RAVEN: I can't answer on that question.

MR BERGER: Particularly after what happened to Mr Biko? You can't comment?

MR RAVEN: I can't comment, no.

MR BERGER: You did know of the allegations surrounding Brigadier Goosen in relation to the death of Mr Biko?

MR RAVEN: No, I don't.

MR BERGER: You never knew about them?

MR RAVEN: No. Oh, sorry. I am mixing up Biko, when you said Biko, I thought you said Bizo. Sorry, no what I read in the newspapers about the Biko case ...

MR BERGER: You thought I was talking about the death of Bizo?

MR RAVEN: No, I thought you were saying, you were pertaining something to Bizo, but it was Biko. I am sorry, I have apologised.

MR BERGER: Because Brigadier Goosen was known as Biko Goosen, wasn't he?

MR RAVEN: I have read it somewhere, I think in the transcript of the conversation between Mr Williamson and Ms Slovo.

MR BERGER: You didn't know that at the time?

MR RAVEN: No, I didn't know it at the time.

MR BERGER: Mr Raven, as I understand your evidence, you made a bomb in an envelope which you sealed very carefully and very tightly and you put it inside another envelope, which was ultimately sealed.

MR RAVEN: That is correct.

MR BERGER: So in order for Ruth First to trigger the bomb, she would have had to have opened two envelopes?

MR RAVEN: That is correct.

MR BERGER: And she would have had to have removed the contents of the inner envelope?

MR RAVEN: As I said earlier, removed ...

MR BERGER: Well, begun to remove?

MR RAVEN: Yes.

MR BERGER: And she had to move it a distance out of the envelope?

MR RAVEN: That is correct.

MR BERGER: And you don't think, or you didn't think at the time when you made the bomb, that the recipient of the bomb would become very suspicious, here is a letter, I open the letter and inside there is another letter which I have to open.

You didn't think that that would alert the person to the bomb?

MR RAVEN: I didn't think so at the time and it would appear that they weren't suspicious.

MR BERGER: Perhaps you are not telling the truth and perhaps there was no inner envelope?

MR RAVEN: That is incorrect.

MR BERGER: You see because your version about the blank envelope is necessary to sustain your ignorance of the identity of the addressee, you would agree?

MR RAVEN: That is the need to know, correct.

MR BERGER: Because if you had placed the bomb into the intercepted envelope, then you inevitably would have had to have seen the name?

MR RAVEN: If it wasn't pasted closed, I would have seen the name.

MR BERGER: On that Mr Raven, your evidence yesterday was that there was something covering the address on both envelopes.

MR RAVEN: That is correct.

MR BERGER: I would like you please to be exact and specific about what it was that was covering the address, the name and the address on both those envelopes?

MR RAVEN: If I remember correctly, it appeared to be - I don't know if you call it a 3M sticker, which you usually find on envelopes which the address is typed on and it is a self-adhesive which is then put onto the envelope.

I recollect it was something along that line.

MR BERGER: Like they called post-it's?

MR RAVEN: Well, I think at the time I mentioned it was something like this material that is used for flagging.

MR BERGER: Yes. Something like this?

MR RAVEN: That is correct.

MR BERGER: And it was bigger than this, yes one gets them in a slightly, in fact something like this

MR RAVEN: It could have been bigger than that as well.

MR BERGER: And it was just put over the name and the address, you could have lifted it up and had a look, but you didn't?

MR RAVEN: No. That is not the case at all. You are saying if I could, if it was open, the names would have been covered. As I testified, I didn't remove the envelope out of the large envelope.

MR BERGER: Yes, I know you have testified about that. I am just saying you could have just lifted that post-it and seen what was underneath?

MR RAVEN: Should that have been the case, I could have done that.

MR BERGER: Do you know if those 3M stickers were available in 1982?

MR RAVEN: I don't know. I was giving you an example of what it looked like. I am equating now to something that is available now. I don't know if it was available in 1982 or if there is an equivalent in 1982.

MR BERGER: You said it was a self-adhesive sticker?

MR RAVEN: Yes. I remember when I was at school, we used to have self-adhesive, well you would lick it but for nametags on your school books.

MR BERGER: Well, this wasn't something that would be licked, otherwise it would take the name and address off as it was ripped off?

MR RAVEN: No, it wouldn't.

MR BERGER: Why didn't you seal the intercepted envelope after you had put the bomb inside?

MR RAVEN: I didn't know whether the person or people, the recipients after my handing it over, wanted to either examine it or insert something else in it, or what. I don't know, but I didn't seal it.

MR BERGER: You see Mr Raven, I went through my notes of the evidence of Mr Williamson last night, he said when I got the envelope back, this is the large official envelope, I looked in the big envelope, I saw there was another envelope in the big envelope. There was the intercepted mail item and another envelope. You say that that is not correct?

MR RAVEN: No, that other envelope was inside the intercepted envelope, which in turn was in the large envelope.

MR BERGER: That is why you say you never sealed the envelope, am I right Mr Raven?

MR RAVEN: No, I just told you I never sealed the envelope.

MR BERGER: You never sealed the envelope so that you could leave room for Mr Williamson's evidence that there was another envelope, that he could see another envelope inside the official brown envelope?

MR RAVEN: Not true.

MR DU PLESSIS: Mr Chairman, is my learned friend now insinuating that the witness has made up his evidence after having heard Mr Williamson's evidence? Is that the insinuation?

Mr Chairman, we will deal with that insinuation in the right way.

MR BERGER: Mr Williamson also said in chief, that you took the first envelope, the one that was sent to Ruth First, to Brigadier Goosen. Then later on you said it is possible that he gave the envelope to Brigadier Goosen and then he said that one of the envelopes definitely, you took to Brigadier Goosen.

MR RAVEN: Not to my recollection. In both cases I handed them back to Mr Williamson.

MR BERGER: When Mr Williamson congratulated you on the Ruth First, the bomb that killed Ruth First, is it correct that he said to you, well done, your device worked?

MR RAVEN: Or words to that effect, I think.

MR BERGER: And when he congratulated you on the bomb that killed Jeanette and Katryn Schoon, he said have you seen the report, your device worked? Would that be correct?

MR RAVEN: I can't recollect that.

MR BERGER: Mr Raven, you say that you and Mr Williamson did not strike a deal in relation to the evidence you would be giving?

MR RAVEN: That is correct.

MR BERGER: You say that there was no deal to the effect that you would introduce a large brown envelope, a large official brown envelope?

MR RAVEN: That I would?

MR BERGER: You would introduce into your evidence a large official brown envelope, the one that was mentioned by Mr Williamson in his evidence?

MR RAVEN: That I, myself and Williamson had a deal on that?

MR RAVEN: No, not at all. Not true.

MR BERGER: And that ...

CHAIRPERSON: How many times do you propose to ask that? You are aware of the fact that the Act gives us power to cross-examination aren't you?

MR BERGER: I am Chairperson.

CHAIRPERSON: And you said you would be an hour this afternoon.

MR BERGER: I did and there was a lot of argument in between, but I am getting to the end.

CHAIRPERSON: Please do so without repeating questions that you have already put to this applicant.

MR BERGER: Mr Raven, I will then leave it. I put the deal to you and you have denied it.

The Church Street ... (tape ends) ...

MR RAVEN: That is correct, I think so.

MR BERGER: The videos that you were referred to and that you said accorded with your perception of what was happening in 1982 and 1984, were in fact videos taken from 1986. Are you aware of that?

MR RAVEN: No, I am not.

MR BERGER: The only information that you had on Mr Joe Slovo and or Ms Ruth First, was information that you got in 1979, am I correct? That was when you went on your course?

MR RAVEN: Security course.

MR BERGER: Am I correct?

MR RAVEN: And thereafter reports that were sent through.

MR BERGER: On that, you had no information in 1982 about exactly what Ms First was doing?

MR RAVEN: No.

MR BERGER: You had no information in 1984 about exactly what Ms Jeanette Schoon was doing?

MR RAVEN: No.

MR BERGER: Thank you Chairperson, I have no further questions.

NO FURTHER QUESTIONS BY MR BERGER

CROSS-EXAMINATION BY MS PATEL: Thank you Honourable Chairperson. Mr Raven, you have mentioned Captain Andre Beukes in your application for the London bombing. Who was he?

MR RAVEN: He was later, became succeeded Mr Williamson. He is the person at Pretoria Security Headquarters who had arranged passports in other names.

MS PATEL: Okay, was he aware of the purpose for which your passport was going to be used?

MR RAVEN: No, he wasn't.

MS PATEL: Then just one final aspect. Brigadier Goosen, to the best ...

MR RAVEN: Pardon?

MS PATEL: Brigadier Goosen, to the best of your knowledge did he have any explosives expertise?

MR RAVEN: Brigadier Goosen?

MS PATEL: Yes?

MR RAVEN: Not as far as I know.

MS PATEL: Yet, you confirm definitely Craig Williamson said to you the specifications for the bomb, the letter bomb came from him?

MR RAVEN: That is my recollection, yes.

MS PATEL: Don't you find that strange that somebody without any explosives expertise could make that decision?

MR RAVEN: It could have been that Brigadier Goosen had that either information or whatever you want to call it, from a third party, or a fourth party.

MS PATEL: Who would that third of fourth party have been?

MR RAVEN: I wouldn't know.

MS PATEL: Were you the only person available in your Department at that stage with that kind of knowledge, or who else would he have referred to?

MR RAVEN: Well, he could have referred maybe to anyone of a lot of people. People who had border experience, where they knew what a handgrenade could do, who knew what 100 g was. I presume he had seen the letter, he knew what kind of weight, it would be pointless putting in a 10 kg load into an envelope.

I can't say, I can't speculate as to why he specified that amount.

MS PATEL: All right, but he would have had to refer to somebody else with experience in this regard?

MR RAVEN: It is possible, yes.

NO FURTHER QUESTIONS BY MS PATEL

ADV DE JAGER: He clearly couldn't have in mind the size of the handgrenade for a letter bomb?

MR RAVEN: No, but I would think that he would think of the destruction caused by it.

RE-EXAMINATION BY MR DU PLESSIS: Thank you Mr Chairman. May I go ahead. Thank you Mr Chairman.

MR BERGER: Chairperson, before my learned friend does, might I just hand this physically in to you, because otherwise it is going to be left hanging around.

CHAIRPERSON: To my Secretary rather for safekeeping.

MR BERGER: This is video number 6.

MR DU PLESSIS: I want to object to that Mr Chairman. Just to make it clear Mr Chairman, I am objecting against giving it to your Secretary.

CHAIRPERSON: Do you want it to get lost?

MR DU PLESSIS: May I go ahead Mr Chairman? Mr Raven, when you made the bomb, when you were involved in the whole operation pertaining to the London bomb, Jeanette Schoon and Ruth First, did you think and were you of the view that your actions were at those times directed against the ANC which is a publicly known political organisation or liberation movement?

MR RAVEN: I was.

MR DU PLESSIS: And were you of the opinion that the ANC was waged in a political struggle against the South African government at that time?

MR RAVEN: I was.

MR DU PLESSIS: Right, now Mr Raven, can I just take you back to the moment you were in Mr Williamson's office, he gave you the order and that relates to Jeanette Schoon and Ruth First, you didn't know who the bomb was going to. Can you explain to the Committee just a little bit what went through your mind pertaining to what was the objective of this?

MR RAVEN: As I said when I received the order, I believed that the chain of command had been followed and that the targets were bona fide targets, pertaining to either the ANC or SACP alliance.

MR DU PLESSIS: Did you perceive it as part of the struggle?

MR RAVEN: I did.

MR DU PLESSIS: Can I refer you to volume 1, page 40, the last paragraph on page 40. Can you please just read out that again?

MR RAVEN: The motive of my deeds were to fight communism and other strong freedom organisations which led a revolutionary onslaught against the apartheid government and to intimidate those fighters and their followers and to disrupt their freedom fight and plan.

A further motive was to fight terrorism and to promote safety and security in the country.

MR DU PLESSIS: Right, now do you confirm that that was the motive with which you acted in the Ruth First, Jeanette Schoon and London bomb incident?

MR RAVEN: I do.

MR DU PLESSIS: And if the target was ex post facto if we look back at it now, not Ruth First, but if the person who was killed was Oliver Tambo, would that have made any difference to your motive?

MR RAVEN: No, it would not.

MR DU PLESSIS: Would that have made any difference to the views with which you did your duties at that time?

MR RAVEN: No.

MR DU PLESSIS: Would that have made any difference to your views pertaining to the struggle between the South African government and the liberation movements?

MR RAVEN: No.

MR DU PLESSIS: All right. Now Mr Raven, this piece that was written entitled "Further Political Objectives" from page 33 onwards, which you were questioned now extensively about, was or can you remember, does this accord with the general view of the Security Forces about the struggle?

MR RAVEN: That was the mindset at the time.

MR DU PLESSIS: And if the bomb was sent to somebody inside the country, would certain other parts of this excerpt have become applicable?

MR RAVEN: No.

MR DU PLESSIS: Let me ask the question this way, if ...

ADV DE JAGER: Mr Du Plessis, that leading question didn't work.

MR DU PLESSIS: Yes, Mr Chairman, the leading question didn't work Mr Chairman.

Mr Raven, in respect of this motivation, can you explain to the Committee how that fit in with your general view on the motivation of what you were doing at the time when you were in the Security Police?

MR RAVEN: I am afraid I don't understand.

MR DU PLESSIS: All right, Mr Raven, let me phrase it this way. Can you explain to the Committee in what way does page 33 and just have a look at the page, page 33 to page 38, does that accord with your views of the struggle at the time when you executed these three operations?

MR RAVEN: Correct.

MR DU PLESSIS: Now, Mr Raven, if and it wasn't put that such evidence would be led, if evidence is led that the bomb that went off, was definitely not in two envelopes but only in one envelope, would it have been your bomb?

MR RAVEN: No. Unless someone took my one out from the envelope and put it in another envelope.

MR DU PLESSIS: All right. Now when you received the orders in respect of the Schoon and First incidents, was your views about the struggle against the liberation movements, do you know if it was the same as Mr Williamson's?

MR RAVEN: I believe it would be.

MR DU PLESSIS: And ...

ADV DE JAGER: Mr Raven, just coming back to that. Would it have been possible to build the bomb directly into the intercepted envelope?

MR RAVEN: It would be possible yes.

ADV DE JAGER: Would it then be possible or - to put it in the post for instance?

MR RAVEN: Not advisable.

ADV DE JAGER: Why not?

MR RAVEN: Well, as I showed the difference between the size of a sheet of paper and the envelope itself, with that moving around in the post, there is a very good chance that it could go off while it is in the post and not reach its target.

ADV DE JAGER: But in building the bomb, you could have built it a little bit bigger than a folio?

MR RAVEN: It is possible.

ADV DE JAGER: Would there be any danger then of it going off?

MR RAVEN: If you could make it as I made mine that it had no movement inside the envelope, you had a good chance that it wouldn't go off.

CHAIRPERSON: As I understand it, correct me on this, one of the things you had to do was also to fix down the device which was inserted into the bomb which would ultimately set it off?

MR RAVEN: That is correct.

CHAIRPERSON: Would you be able to fix that down in an envelope that was already prepared, you didn't open the envelope?

MR RAVEN: If you are saying that that device I could have built into the intercepted postal?

CHAIRPERSON: Yes.

MR RAVEN: Yes, it could be done. The only problem I will sit there with slightly, I think would be steaming open the whole envelope.

CHAIRPERSON: So I mean you would have to open the whole of the intercepted envelope to fit the device in, you couldn't have slipped it into the envelope and just stuck it down?

MR RAVEN: No.

CHAIRPERSON: No.

MR DU PLESSIS: Right. Mr Raven, if you had known that a Stratcom operation was worked out before the Ruth First bomb, would you have given more serious consideration in using Eastern Block explosives then?

MR RAVEN: No.

MR DU PLESSIS: And Mr Raven, would you have considered at all at the time when you were given instructions in respect of the Ruth First and Jeanette Schoon bombs, did you give any consideration to the question if such a bomb could have gone to somebody totally not related to the struggle between the government and the liberation movements?

MR RAVEN: No, I believed at the time I was given the instruction, that it was going to a legitimate target.

MR DU PLESSIS: If you will just bear with me Mr Chairman, please. Mr Raven, do you know if there were informers in Botswana, in Gaberone of the Security Police or other of the Security establishments?

MR RAVEN: There must have been because of the amount of information coming in from Botswana and the other front-line States, there must have been sources there. Sources not agents.

MR DU PLESSIS: Now Mr Raven, in respect of the envelope, can you explain to us the way in which you dealt with the envelope in which the bomb was and the way you put the envelope into the intercepted mail item, with specific reference to your fingerprints?

MR RAVEN: Mr Chairman, last night at home I thought about this fact and as I explained at the time, when you said I in front of you held my hands on it there, I made a small envelope, approximately the same size which I glued with sellotape to show you that without having to hold the little points, to catch the corners in, it can be inserted quite easily.

May I show this to you. Bearing in mind that this envelope is inside a large envelope, it is a question of taking it there and it is in.

CHAIRPERSON: The applicant demonstrated using, holding the envelope between his knuckles.

MR BERGER: And Chairperson, also demonstrated it without the large official envelope, the "amptelike" envelope, it was not there.

MR RAVEN: Would you like me to do it again Mr Chairman.

MR DU PLESSIS: It is not necessary Mr Chairman, unless anybody else wants to see it.

Mr Raven, did you have any connection with any International Intelligence Services?

MR RAVEN: Yes, I did.

MR DU PLESSIS: As part of your duties?

MR RAVEN: That is correct.

MR DU PLESSIS: Can you explain a little bit?

MR RAVEN: In connection with the CIA, FBI and well it was the Mosad, of course they won't say so, the Israelis. In so far as they would pass onto us diagrams of IED's that they had come across in their struggle in their country to inform us of what is the tendency in their country as far as IED's go, because terrorists in their countries received training by the same people that received people amongst our terrorists.

It was a possibility that the tendency could run through.

MR DU PLESSIS: Thank you Mr Chairman, I have no further questions.

NO FURTHER QUESTIONS BY MR DU PLESSIS

MR SIBANYONI: Mr Raven, I am going to ask you a theoretical question. Taking your explanation that you didn't look at the envelope to see to whom it was addressed to, theoretically even if it was addressed to you, you would manufacture the bomb, put it in, without knowing that it was addressed to you?

MR RAVEN: That is correct.

MR SIBANYONI: Thank you Mr Chairperson.

CHAIRPERSON: That concludes as I understand it, the applicants in connection with these two incidents. I take it Mr Bizos, you don't want to start leading a witness at

this stage?

WITNESS EXCUSED

MR BIZOS: No, no thank you Mr Chairman.

CHAIRPERSON: I accordingly unless anybody has any, do you want to raise anything?

MR VISSER: Mr Chairman, yes, we mentioned before the question of Gen Coetzee's movements in June of 1985. My learned friend Mr Cornelius and ourselves have come to an agreement which we would like to place on record with your permission.

By agreement the following is then placed on record. One, that during June of 1985 Parliament was in session and Gen Coetzee as the Commissioner of Police at the time, attended Parliament during that month.

Secondly Mr Chairman, during the month of June of 1985 Gen Coetzee came to Pretoria on two occasions. The first being when he left Cape Town on the 6th of June 1985 and where he attended his office on Friday the 7th of June 1985 and that he left for Cape Town again from his office, at 12H15 on the 7th of June 1985.

Mr Chairman, on the second occasion ...

ADV DE JAGER: He went back to Cape Town?

MR VISSER: Mr Chairman, yes, I am just not certain whether he went straight to Cape Town or via Port Elizabeth, but I believe he went to Port Elizabeth and then travelled by motor vehicle to Cape Town on the first occasion.

On the second occasion Mr Chairman, he left Cape Town ...(intervention)

ADV DE JAGER: Mr Visser, he left his office at 12H15.

MR VISSER: Yes.

ADV DE JAGER: Wherever he went, when did he arrive in Cape Town?

MR VISSER: Mr Chairman, I believe that we have the information on paper. We have given copies to my learned friends. May we hand copies to you Mr Chairman, it will speak for itself.

Just by way of explanation Mr Chairman, the first document in that little bundle of three pages, refers to his travel arrangements on the 6th of June. The second page refers to exactly the same travel arrangements, but there was an amendment made for him first to go to Port Elizabeth, but he flew away at 12H15 on the 7th of June to answer Mr De Jager's question.

That you will find at the second page. Do you wish to mark these an Exhibit, Mr Chairman, it is OO, I think. We may as well.

That brings us to the last page of OO, page three of that and that refers to a visit from Cape Town by the General on the 12th of June. He left at 18H50 and he arrived at 20H45 at Jan Smuts and on the Thursday, the 13th of June, he returned at 11H40 and the flight number is given there, etc. That one was straight back to Cape Town Mr Chairman.

That is the second agreement. The third agreement which my learned friend has asked us to make is that after the session of Parliament had (indistinct) Mr Chairman, Gen Coetzee was back in his office from the 3rd of July of 1985.

CHAIRPERSON: Back in his office in Pretoria?

MR VISSER: In Pretoria, yes. Mr Chairman, my wife brought the map which we have and it is here for you to see.

CHAIRPERSON: Put it down and we will have a look at it afterwards.

MR VISSER: This is my third map Mr Chairman, this is my third map.

CHAIRPERSON: Is everybody happy with that?

MR CORNELIUS: Mr Chairman, Cornelius for the applicant McPherson. I just want to place on record that I had insight into this documentation. That is the agreement. I just want to draw your attention to the fact that there was an answer in cross-examination in his evidence in chief where he said, McPherson, he said the General came up especially.

This is to clear up the dates and to place it on record, so I think this is cleared up, thank you.

CHAIRPERSON: Nothing further for this afternoon? Mr Bizos, what time on Monday?

MR BIZOS: We are in the hands of the Committee Mr Chairman, and our colleagues. We can be here ...

CHAIRPERSON: (Microphone not on)

MR BIZOS: Can we compromise for 09H30 Mr Chairman.

CHAIRPERSON: Very well, 09H30 on Monday morning.

MR DU PLESSIS: Mr Chairman, may I just say I have had an arrangement with Mr Bizos and everybody else, I am not going to be here on Monday Mr Chairman. My learned Attorney Mr Chairman, is going to handle the cross-examination.

COMMITTEE ADJOURNS