CHAIRPERSON: Right, what are we beginning with today?

MR BIZOS: May it please you, Mr Chairman and Members of the Committee, we call Ms Gill Marcus.

MR DU PLESSIS: Mr Chairman, may I perhaps just deal with a preliminary point? I have come to realise this morning that a specific document, it doesn't seem to be a very long document, was provided to my learned friends, Mr Wagener and Mr Visser on Friday, explaining which witnesses would be called and giving a short explanation of their evidence. The witnesses referred to in that letter differ to the list that we received previously. I have not received such a letter, I have not seen it. I have only been told of it, I think 10 minutes ago. I haven't had a chance of studying that letter, Mr Chairman. I would have expected that - I think Mr Levine is in the same position, he also did not receive such a letter, that we would have been afforded the opportunity also of having such a letter. I have an e-mail address which is published as part of the Pretoria Bar under all the addresses of legal practitioners on the internet, it would have been easy to do it.

CHAIRPERSON: I received it 20 minutes ago. It will take you two minutes to read. If you want to you can borrow my copy.

MR DU PLESSIS: Thank you, Mr Chairman. If I could perhaps be provided with a copy.

MR BIZOS: Mr Chairman, I ...

MR BIZOS: ... on Friday. But as you say, Mr Chairman, we should try and avoid taking up too much time with preliminary points. The witness is here, it's two lines and two words. And what the witness has to say was put to witnesses given by, called by the applicant, so there can be no element of surprise.

MR DU PLESSIS: I'm not saying that I'm surprised, Mr Chairman, I'm not surprised with the document, that's what I'm saying, I'm not surprised with the document. Now I have looked at the document, it's not a problem, Mr Chairman, thank you very much.

May I just then deal with one other point, Mr Chairman, and that's the point that has been raised previously about the calling of witnesses in respect of an application which is not opposed, Mr Chairman. I see that on the list one of the witnesses who will be called will be Gill Marcus, and if she is going to be called in respect of the London bomb incident, I wish to refer you to the problem we raised previously in that regard, pertaining to the question, can somebody who doesn't oppose an amnesty application call a witness in a hearing such as this.

MR BIZOS: ...(no sound) Mr Chairman. We are calling the witness in order to show the conduct of Mr Williamson, which cannot be isolated to any particular incident. We are not calling her as evidence against the applicants who are applying only for amnesty for the London bombing. We have been through this before and the Committee has already made a ruling in that regard, Mr Chairman.

CHAIRPERSON: Carry on.

MR BIZOS: Thank you, Mr Chairman. We call Gill Marcus. Ms Marcus will affirm to tell the truth, Mr Chairman.

GILL MARCUS: (affirms and states)

EXAMINATION BY MR BIZOS: Ms Marcus, you are the Deputy-Minister of Finance?

MS MARCUS: Yes.

MR BIZOS: Did you leave South Africa to go into exile?

MS MARCUS: Yes, I left in 1969.

MR BIZOS: Did you become a member of the African National Congress whilst you were in exile?

MS MARCUS: Yes.

MR BIZOS: Did you for a number of years, work at 28 Penton Street, the headquarters of the African National Congress at the time that a bomb exploded there on the 14th of March 1982?

MS MARCUS: Yes, I was working at 28 Penton Street at the time.

MR BIZOS: Could you tell us whether you are the author of a plan which has already been handed in and marked Exhibit NN, which shows the layout of the ANC office in London and its environs?

MS MARCUS: Yes.

MR BIZOS: Do you confirm the correctness of that drawing?

MS MARCUS: To the best of my recollection, yes. Obviously that I redrew from memory, but yes, as far as I can recall.

MR BIZOS: Now we also have a photograph, Exhibit DD, of 28 Penton Street, is it a photograph of the ANC offices and adjoining buildings?

MS MARCUS: Yes, that's clearly the photograph of the offices prior to our moving into them.

MR BIZOS: Any material changes after you moved into them? - on this photograph.

MS MARCUS: I don't think they would be material to the external, there would be some adjustments internally and obviously some reconstruction internally, but the external remained very much as that picture indicates.

CHAIRPERSON: I assume you would have taken away the notice saying: "Take-away Service"?

MR BIZOS: Was that a residential area?

MS MARCUS: It was residential in terms of both the environment around it, as well as that particular street, including the building itself. In our initial renovations, as I recall the top floor as well as two rooms of the second floor were residential as well. We had I think both residential offices on the ground, on the first and on the second and the floor was residential for people who were working in the office.

MR BIZOS: Was there any school of any kind in the immediate vicinity of the ANC offices?

MS MARCUS: My recollection as best is certainly, I think there were two but I can definitely confirm the one. If you looked at Exhibit NN, I've indicated there as the White Lion free school, which was really just on the other side of the road on White Lion Street. I wouldn't be absolutely sure, but I seem to recall there was also a school behind at the empty yard. One of the buildings adjacent to that empty yard was also a school, but I wasn't absolutely sure and I didn't put it in, in terms of not being 100%, but my recollection was that there was a school there as well.

MR BIZOS: What sort of school was this free school?

MS MARCUS: It was a school that children who were perhaps having some difficulties in normal schooling, so it was in a sense a facility for children who would be there all the time to actually come along, who were ...(indistinct), to actually look at the kind of schooling that they could assist with. So it was an active place for children to attend.

MR BIZOS: Did they attend that free school during regular school hours or were they present more frequently?

MS MARCUS: My recollection of that school was that it was regular school hours, but that in the environment on a weekend there would often be activities involving children in that area.

MR BIZOS: Was there a market anywhere near there?

MS MARCUS: Yes, indeed. The Chapel Street Market, in actual fact from White Lion Street if you went one block to the left on the map to the west, that whole street is a market street and if you went down to sort of the block that our block is in, the street that would be parallel to that, I think it might have been Baron Street, but I wouldn't swear to that, it was also a market. So on a weekend it was a very, very busy area., you had fruit, vegetables, all kinds of things. It was a particular weekend market, known as the Chapel Street Market.

MR BIZOS: Did this market operate on Sundays?

MS MARCUS: Yes.

MR BIZOS: What time did the operations start?

MS MARCUS: They would normally start early on a Saturday or on a Sunday. It was something that by 9 o'clock everybody was, 9, 10 o'clock, 8 o'clock, it depended on what you were selling. But it was a very busy area for that market. It was a very popular market and the area around that would be where people parked their cars to go to the market.

MR BIZOS: Please tell us what the nature of your work was for the ANC at that time.

MS MARCUS: My responsibility was in information, I was the Deputy-Secretary of Information for the ANC, and my particular responsibility was the production of a weekly news briefing, plus any other information that the ANC required.

MR BIZOS: And what were your working hours?

MS MARCUS: Whatever the work required. So in essence, given the limited resources that we had and the amount of the workload, I would say if you wanted hours, probably starting at six in the morning and finishing whatever time, eight or nine in the evenings and weekends.

MR BIZOS: Did you work on Sundays?

MS MARCUS: Always.

MR BIZOS: Was that generally known?

MS MARCUS: I would think so, yes. I think everybody knew if you wanted to find me you went to the office, you didn't try my house.

MR BIZOS: Were there every Sunday morning?

MS MARCUS: I was there every Sunday morning except the day of the bomb.

MR BIZOS: From what time to what time?

MS MARCUS: On a Sunday I'd usually go in a little later, usually at about eight. I would be there at about eight until the work was finished for that day.

MR BIZOS: Did you know Mr Williamson?

MS MARCUS: I knew of him certainly, and I recall having met him once in our Penton Street office where he was in the reception to the Penton Street office.

MR BIZOS: You say you know of him, did you know whether he was an occasional or regular visitor at the ANC offices?

MS MARCUS: My understanding was that he certainly interacted with particular people in the ANC, he came to the ANC office. He was working at that time, to the best of my recollection, with the IUEF and was dealing with scholarships and therefore had interactions with people in the ANC. I certainly had no direct dealings with him but I know the IUEF was a recipient of the news briefings.

MR BIZOS: Have you any reason to believe whether or not he knew where your office was?

MS MARCUS: I would very surprised if he didn't. I mean, it was a small building, people knew what went on and we printed from that office so it made a noise. So I don't think anybody didn't know what was going on there because your printing machine was there.

MR BIZOS: Yes. And if anyone, as we are told was done, conducted a thorough surveillance before a bomb was put against the wall of your office, would they have known about your working habits?

MS MARCUS: I would think it would be very hard for them not to have known, they were very regular, the routine required in producing a weekly publication is very set and there were certain routine and practices that were, how you conducted your work. Certainly I think any surveillance would have shown when you worked, where you worked and where you were.

MR BIZOS: Would you have been there on Sunday the 7th March, the week before?

MS MARCUS: I'm sure I was.

MR BIZOS: And would you have been there the week before that, the 1st of March?

MS MARCUS: Well as I say I wouldn't know the dates. My understanding and ...(intervention)

MR BIZOS: I'm merely working back on Sundays from that day.

MS MARCUS: Sure, sure. As far as I know I worked every Sunday except that Sunday, so certainly each of the previous Sundays I would have been there.

MR BIZOS: Yes. What were you busy doing on Saturday the 13th of March?

MS MARCUS: On the 13th we'd actually gathered quite a number of people for two reasons, there was going to be a demonstration and a very big rally on the Sunday and we had put, a number of ANC members had come to the office to help prepare the placards and the banners that we would carry in that march. So that was the one component which we participated in. And secondly, we decided that those of us who were working on the news briefings having sort of got the banners and things done, to try to complete our work that day so that we would in fact be free on the Sunday. And I think - we certainly worked into the evening of the Saturday to complete the work. So we completed the banners and completed the news briefings work so that we wouldn't have to be there on the Sunday.

MR BIZOS: Casting your mind back, when would you say you might have left the office on the Saturday.

MS MARCUS: Probably about 9 or 10 o'clock at night. It would have been well into the evening.

MR BIZOS: What was the demonstration to be about?

MS MARCUS: My recollection is probably an anti, a pro-sanctions rally. It was a very big rally at Trafalgar Square, a lot of work had gone into it and it was a big mobilisation in support of anti-apartheid.

MR BIZOS: Would anyone keeping the office under surveillance the week before, including the Saturday of the claimed efficiency of Mr Williamson as an intelligence gatherer, would this be generally known or was it a secret operation?

MS MARCUS: No, it was very well-known. I mean if one looked at it - if I recall there were even big banners on Nelson's column, it was that was very widely publicised. In fact my recollection is that it was a very big rally, it wasn't a small rally. You know it wasn't a couple of hundred people coming along, there were thousands of people there, as my recollection. And it was a Trafalgar Square rally which was usually well-known. And obviously in relation to that, the ANC makes its own preparations for the ANC people who participate. That would be your banners and so on. So anyone watching that would know the activities leading up to that weekend.

MR BIZOS: Did you go to the office on the Sunday morning, the 14th?

MS MARCUS: I received a phone call at my house - we had actually had a number of people meeting at my house before the rally, I received a phone call there asking me to - first of all I think they were trying to find out whether I was there or whether I was in the office. I don't recall who the phone call was from, but it was saying can you come there, there's been an explosion at the office and I went straight up. That was shortly after 9 o'clock on the Sunday morning.

MR BIZOS: Where the banners that were to be used for the demonstration?

MS MARCUS: If you looked at Exhibit DD, those stairs leading up, that was a kind of foyer there and we had piled all the banners there in that front part so that when we came to fetch them we'd easily be able to load them. My recollection is that we had put all the work that we had done there in the front. That would be just inside the entrance. That foyer and the first office there where the window is would have been the reception and we would have put all the things we'd prepared there so that we could easily load them into the car. That's the only entrance or, into the building is through that door.

MR BIZOS: Who was going to pick up those banners?

MS MARCUS: I don't recall the specifics, but probably myself and others who had been part of preparing them. We would have a team who would be part of collecting the banners and distributing them at the march.

MR BIZOS: What did you find when you went to the ANC offices?

MS MARCUS: Well it was sealed off. The police were there, they wouldn't let us in. And in essence, they had cordoned off the area and we could just see, because then we went around the side, you could see the damage at the back, but they just said there'd been an explosion and that there was a lot of damage and they would not let us into the building. So we couldn't take our banners at the end of day anyway.

MR BIZOS: Could you please tell us what damage you saw that had been done, particularly in relation to the office that you would have been in had you gone in on that Sunday morning.

MS MARCUS: They first of all had to look at the soundness of the building to let us in, and I'm not sure if it was one or two days later when they let us in, it wasn't that day.

When I went back to my office - perhaps if one looked at Exhibit NN, which is marked mine there, there was a window, not the full length of my office, the part marked "exit" was a sort of kitchen which had a steel door at the back, there was a little yard at the back which was back space, it was just a few feet, and there was a sort of broken down fence there. At my office there was a window and in front of that window in the office would have been my desk and behind my desk would have been the printing machine, more-or-less in the middle of the office.

There was an enormous crater in the office, the printing machine had been thrown right into the other office, it had been pushed right the way through and my desk was sort of, it was a metal desk, it wasn't a wooden desk, and it was sort of quite twisted and there was just this big crater where I would have been, either at my desk or at the printing machine, but there was just a crater there.

MR BIZOS: Could you give us some indication of the dimensions of the crater?

MS MARCUS: Bit hard to describe. Probably if one took the - I would say, probably two or three times the size in diameter of the footrests here. So if you looked at it, about three times that size. Two or three times that size, of how the bottom of the camera is spread out.

MR BIZOS: Did you say twice or three times? Between two and three times?

MS MARCUS: Something like that, ja.

CHAIRPERSON: What footrest, Mr Bizos?

MR BIZOS: The footrests of the television camera.

CHAIRPERSON: The one in front here?

MR BIZOS: The one - between twice and ...

MS MARCUS: If you moved that out about three times, I would say that's roughly the size of the crater.

MR VISSER: I suggest that's about a metre, Mr Chairman.

CHAIRPERSON: And three times would be three metres.

MR VISSER: Three metres, yes.

MR BIZOS: I couldn't tell how deep ...(indistinct). It was certainly deep. The floor had been a concrete floor, so it was something where you actually just looked into this hole. It was deep, I wouldn't be able to tell you.

There was just a question perhaps, in thinking back at that time, something that, if you looked at that you just looked and said well, I don't think what, if I would have been there, I don't think there would have been much of me left to see. It was quite a sort of, it's quite an experience to actually stand and look at a hole that you would have been in.

MR BIZOS: What other damage had there been done to installations, windows, in the neighbourhood?

MS MARCUS: The damage again was quite extensive. In the empty yard the windows from those building were blown out, the Italian deli had another part attached there, that in fact had, the one wall had fallen down and that had to be demolished. We ourselves in our office had to do structural repairs because the whole walls of the entire building had shifted, and we had to do structural repairs from the basement up to actually make the building safe and available for habitation again. Our own office, or my own office I was never able to reoccupy.

MR BIZOS: In relation to the school, what damage was there, if any?

MS MARCUS: The main damage seemed to be blowing out of windows and a lot of glass.

MR BIZOS: Was there anyone in the building in which the ANC was housed at that time?

MS MARCUS: Yes. There was a young man by the name of Vernet Mbatha. Vernet Mbatha was an ANC member who lived in the top floor. As I said it had been residential. Previously two additional people had lived there, then one had moved out, then the third, the one person had remained. At that point in time, Vernet was the only person still living in the top of the building. My recollection is that the bomb in fact threw him out of his bed.

He knowing that I would normally be there, actually came down the stairs trying to find out whether I was downstairs. And I know that from when I arrived at the building he was just really totally shaken and saying "Gill, thank God, I came looking for you but thank goodness you weren't there. I was just worried that you were in the downstairs."

MR BIZOS: Shortly after this explosion, did you receive a postcard?

MS MARCUS: Yes. It was posted from Botswana.

MR BIZOS: And to whom was it addressed?

MS MARCUS: To me, at Penton Street.

MR BIZOS: What was written on it?

MS MARCUS: To the best of my recollection it was: "Oh, you are still around. Craig."

MR BIZOS: Did you have any friends called Craig, in Botswana?

MS MARCUS: No, I don't know any other Craig at all.

MR BIZOS: How did you interpret this biledo from Craig?

MS MARCUS: I was actually quite angry I must say, because I felt that, if I could give my expressions on the bomb, I don't think the bomb was ever intended for me personally, I think it was a bomb of the ANC. I think that if they had got me as well it would have been a nice to have, but that's about all.

I don't think it mattered one way or the other. But what this indicated was a callousness and a personal agenda that one was really a bit annoyed about, to put it mildly. It's quite callous and cynical, it's very cynical.

MR BIZOS: Had there been publicity about your habits and where you office was and where the main damage had been done, after this blast?

MS MARCUS: Yes, I think it wasn't particularly about my habits, but certainly there was in a photograph an indication of the damage done to the office and that it had occurred at the back of the office. And therefore, in terms of anti-apartheid circles they would have certainly known it was my office.

I don't recall if there was anything that indicated that that was where the news briefings were published from, in publicity terms or about my movements in particular.

Certainly people were well aware because the, we had to make alternate arrangements to produce the news briefings and our view was that we were going to be sure that we did not miss a week, we hadn't up to then and we were not going to, and therefore we needed a lot of assistance to produce it, which we got from different organisations in, different British organisations who gave us office space, allowed us or assisted us with access to printing equipment, their printing equipment and typesetting and other opportunities. And therefore we continued to produce the news briefings without any break.

MR BIZOS: Thank you, Mr Chairman, we have no further questions.

CHAIRPERSON: Who is to commence questioning?

CROSS-EXAMINATION BY MR LEVINE: It seems I've been nominated.

Ms Marcus, you don't have a copy of this postcard do you?

MS MARCUS: No.

MR LEVINE: And you don't have the original available?

MS MARCUS: No.

MR LEVINE: What did you do with it when you received it?

MS MARCUS: I think I probably threw it away, I don't recall.

MR LEVINE: And it merely had the very terse words: "see you're still here" or something of that nature?

MS MARCUS: You're still around is what I recall.

MR LEVINE: You're still around.

MS MARCUS: Craig.

MR LEVINE: And Craig?

MS MARCUS: Yes.

MR LEVINE: Was it in manuscript?

MS MARCUS: Sorry? Was it handwritten?

MR LEVINE: Yes.

MS MARCUS: Yes.

MR LEVINE: And was the Craig a signature or merely

C-r-a-i-g?

MS MARCUS: Just C-r-a-i-g.

MR LEVINE: Plus printed on the envelope, on the card?

MS MARCUS: On the card.

MR LEVINE: So ...(intervention)

CHAIRPERSON: Was it printed or written?

MS MARCUS: It was written, it was handwriting.

MR LEVINE: Perhaps, Mr Chairman, was it printed in manuscript?

MS MARCUS: It was handwritten.

MR LEVINE: In manuscript? Printed in manuscript?

MS MARCUS: Well I'm not sure what you mean by "printed". To me a postcard, if you handwrite I can see, it's written by hand, it's not printed from some machine and it's done by hand in a person's handwriting. That's what I understand you're asking and that is how it was, it wasn't from a machine and it wasn't printed, it ...(indistinct)

CHAIRPERSON: Well was it the word Craig or was it

C-r-a-i-g?

MS MARCUS: If I was writing my name I'd write it

G-i-ll, right?

CHAIRPERSON: Yes.

MR LEVINE: And that's exactly what I had there, was

C-r-a-i-g.

CHAIRPERSON: ...(indistinct) small ...(intervention)

MS MARCUS: It was upper and lower case and it would the same way as you would write your personal name.

MR LEVINE: It wasn't in any form of signature or anything like that?

MS MARCUS: I wouldn't know how Craig Williamson signs his name, but it is handwritten C-r-a-i-g, as you would write your name. It was not a signature in terms of signing off as I might sign a letter, which would be different from if I wrote Jill.

MR LEVINE: Did you ever previously receive a note or a letter in manuscript from Mr Craig Williamson?

MS MARCUS: Not that I recall, no.

MR LEVINE: So you were not able to identify it as being something which emanated from him?

MS MARCUS: No, I would not be able to say it was Craig Williamson, but a question of getting a postcard from Botswana in 1982 with the name of Craig on, there's very little other conclusions that one could draw.

MR LEVINE: There could have been any number of Craigs who might have written it.

MS MARCUS: Well I would want to know how you would decide which Craigs would write to me from Botswana. I mean there is only one Craig who was involved in anti-apartheid, the bomb had just occurred and yes, any number of Craigs could have written, but I'm not quite sure what they would be doing sending postcards from Botswana to me.

MR LEVINE: Well I have the same difficulty as you, any number could have written. Thank you very much, Mr Chairman.

CHAIRPERSON: Any other questions?

CROSS-EXAMINATION MR VISSER: Thank you, Mr Chairman. Perhaps I should ask a few questions, with your leave.

I can't see you, Ms Marcus, and you can't see me so we'll just have to feel our way around toward each other, if you don't mind.

MS MARCUS: As long as that's not literal.

MR VISSER: Ms Marcus, you said you went into exile, did you say 1969?

MS MARCUS: Yes, during 1969.

MR VISSER: But at the time you were not a member of the ANC, as I understand it?

MS MARCUS: The ANC during the period if you recall was banned and its membership was clandestine and there was a restricted political activity in the country. Membership was not formal in that sense in the country at that time. Obviously there were people who were members and who regarded themselves as members. Certainly in terms of formal joining, I went to the UK and I joined the ANC shortly after I arrived, formally.

MR VISSER: Well please stop me if I'm wrong, must one understand then your evidence to mean that you went into exile because you were aligned with the ANC at the time, but you couldn't join the ANC because it was a banned organisation and you went to the UK where you joined the ANC, is that more-or-less what you're saying?

MS MARCUS: More-or-less correct. In 1969 I was a student at the, well, 1967 and '68 I was a student at the Wits University and I had felt that I wanted to see what was happening and look at the kind of roll I could play. I did not feel that I could do it within the country.

I left the country in '69. My entire family left in '69 and we, I became a member of the ANC, linking up with them shortly after my arrival in the UK.

MR VISSER: Ms Marcus, what did you study, what did you qualify yourself as?

MS MARCUS: I hope - the university qualified me as a BComm graduate. I did two years which I passed at Wits, I then completed my studies through correspondence at the University of South Africa because they gave me credits for my two years at Wits. So I completed a BComm with particular emphasis on Industrial Psychology and Economic History.

MR VISSER: Yes. I'll tell you why I ask you the question, it's because I wanted to know whether your qualifications was what qualified you to become the Deputy-Minister of Finance. I take it the answer would be yes.

Coming to the two schools, Ms Marcus, which you referred to, the one that you remember, the other one that you obliquely remember. Do I understand your evidence correctly, that on Sundays as schools normally would tend to be, there was no activities going on at these schools?

MS MARCUS: There would not have been school activities, but my recollection is that those schools had sort of extramural activities in which the children were involved, and there were often children, that they would gather for different purposes organised by the school in that area. They were often there on a Sunday, and you could see the kids and hear the kids.

MR VISSER: And it was a very busy area over weekends, with markets and people parking their cars and walking along the sidewalks, not so?

MS MARCUS: Certainly Chapel Street Market is a very famous, was, I'm not sure of its status now, but at that time was a very famous and popular market for the people to come shopping on a Sunday.

MR VISSER: And you yourself was a person who worked every Sunday as you can recollect, and as Mr Berger stated, for many years in that office?

MS MARCUS: Yes, unfortunately I have a reputation of being a bit of a workaholic.

MR VISSER: Yes. For many years?

MS MARCUS: Yes.

MR VISSER: On Sundays?

MS MARCUS: Yes.

MR VISSER: Except this one?

MS MARCUS: Yes.

MR VISSER: Yes. So ...(intervention)

CHAIRPERSON: Well you would have been working to some extent, elsewhere on this Sunday, wouldn't you?

MS MARCUS: Yes, indeed, I mean it wasn't a day off, it was just a different form of activity which was outside the office.

MR VISSER: So either the perpetrators of the bombing were extremely fortunate, very lucky or it was an extremely well planned operation, wouldn't you agree?

MS MARCUS: I would have thought it's me who was lucky and I would have thought that, I don't think it mattered, because the question is about their well planning, is that we were still coming to fetch those banners and we could have equally have been there earlier at that time.

The only reason why we were not was as I said, we had people meeting at my house and we were going to come later to do that. We could as easily have come at that time. And if anyone had been watching the building if it was carefully planned, on the Saturday, they would have seen that when we come and do this kind of work which was common for the ANC, we do not have child-care facilities, there would have been children in the building, the members who were coming to work on it would have come with their children. So to me it was something that it really didn't matter whether people were killed or not. And I think it was me who was lucky, not the perpetrators.

MR VISSER: Well there are people who would say, Ms Marcus, that it does really matter whether people were killed or not, and there weren't any people killed or seriously injured, isn't that correct?

MS MARCUS: That is correct.

MR VISSER: And isn't that really the end of the matter?

MS MARCUS: I would be quite shocked if the end of the matter was that you plant a bomb and because nobody's killed, that's the end of the matter. I think the risks to people and the question of the callousness of planting a bomb in a busy area, in itself speaks volumes.

And I think that the question of actually having no-one killed is a plus for those of us who could have been, but I don't think it absolves the perpetrators by any means.

I mean, what would have happened if somebody had been at the back there, I mean it would as likely as not, from what I would be able to tell. I don't think it's the end of the matter at all.

MR VISSER: Yes, I'm not suggesting at all that bombing the building wasn't a serious matter, Ms Marcus, what I'm suggesting to you is that quite clearly the people who did the bombing had taken great care to ascertain and make absolutely sure that nobody was seriously injured in the blast, and they succeeded.

MS MARCUS: Well I'm saying differently. Vernet Mbatha who lived in the building, I mean on what basis do you say that he was secure? I don't know if the blast had gone slightly differently you're that guaranteed that a person on the top floor wouldn't get killed in that building? How do you know the damage wasn't so structural that in coming down he wouldn't have been killed?

I think those are not issues that one can ignore and I think that it would be wrong to dismiss the question that Vernet Mbatha's life was worth less than anybody else's. The fact that he wasn't injured was fortuitous and we're very delighted at that, but I don't think that any bomber could have been able to guarantee that that would be the outcome.

MR VISSER: So please assist me, Ms Marcus, what is the point of your evidence here today? Is the point then to come ...(intervention)

MR BIZOS: Mr Chairman, is the witness being asked to argue the case for the applicants? We will do that, Mr Chairman, it isn't a matter for the witness.

MR VISSER: Mr Chairman, it's a perfectly permissable question to ask the witness.

CHAIRPERSON: You have been asking her these questions and getting the answers, Mr Visser. They are largely argumentative, aren't they? You will continue to argue that it shows great care in planning, that nobody in a busy street on a day when there were markets there, was injured.

CHAIRPERSON: ... you are not going to accept, are you?

MR VISSER: No, that is so, Mr Chairman, but the question that arises now is, may I ask the witness what she intended with her evidence for this Committee to believe?

CHAIRPERSON: To tell us what she thought the facts were, so we can then come to a decision.

MR VISSER: May it please you, Mr Chairman. I take it then my question is not allowed.

CHAIRPERSON: I think it is pointless, Mr Visser.

MR VISSER: The nature of the work that you were doing, you were talking about a news letter, did I hear you correctly? - a news briefing. What were you referring to?

MS MARCUS: It's a news briefing. Basically my task was to produce a weekly news briefing on events in South Africa. In essence, that if one wanted to understand the content of that one could go into details about it, but it was to inform the wider public in the world about what was happening in South Africa, taken directly from South African newspapers. It was produced on a weekly basis and went to, at that time I wouldn't know the exact circulation, but its circulation grew to about

5 000 organisations worldwide.

MR VISSER: And you were sitting in the same room where the printing press was you've told us?

MS MARCUS: Yes, with the printing press, my office, filing, everything else, all in one space.

MR VISSER: And as the printing press was churning out pamphlets, news letters or whatever, did you normally read what was printed in that room where you sat and worked every day of your life?

MS MARCUS: Of course, I mean I did the printing as well. We didn't have much sort of personnel power, so one learnt to print as well. So I read it and I printed it and quite often typed it and distributed it as well.

MR VISSER: Did you make any input in the contents of what was printed in the Setchabas, for example, printed in that same room where you were working?

MS MARCUS: No, Setchaba is a different publication, it was not printed there. Setchaba had its own printing facility, quite separate from this and I did not make inputs into Setchaba unless I wrote an article for them. It was a different publication altogether, it was not produced from that office, it had a different office.

MR VISSER: What was exactly printed in that office then?

MS MARCUS: That office was responsible for printing matters that were public for the ANC. It would print news letters to members, it would print the news briefing, it would print leaflets, it would print pamphlets, whatever was required for the ANC. It was it's UK printing office.

Obviously it wasn't the only printing done by the ANC, it's what we did, it was our in-house printer. Like most organisations, they have two types of publications, those they do in-house and those that they take out to agencies to do either printing or producing. This was the in-house publication then, or print facility of the ANC in London, it wasn't the only one.

MR VISSER: Was any matter printed in the room where you worked, regarding instructions to persons within South Africa as to what to do in the struggle?

MS MARCUS: As I said, we produced leaflets, we may well have produced leaflets that would have come to South Africa, yes.

MR VISSER: For example propagating the killing of policemen and Security Force members?

MS MARCUS: I'm not quite sure what that's got to do with the question of bombing the office, but in terms of whatever the ANC policy was on issues I wouldn't be able to tell you which leaflets, because as I said this wasn't the only one.

The internal publicity for the ANC was actually done from other offices in Africa, and mine was concentrating on the external publicity of the ANC and what was required for public consumptions. There may have been occasions when we did do leaflets in support of what needed to be done at home, but I wouldn't be able to tell you which ones. Primarily the task of that office was external, not internal.

MR VISSER: Thank you, Mr Chairman, I have no further questions.

CHAIRPERSON: I don't quite understand this external and internal. You say the task of that office was external?

MS MARCUS: Yes, Judge, the question is that as you know, I'm sure if you went back to the 1980's and before, the ANC also produced information that was part of its publicity inside the country, so therefore in terms of that, that publicity was a different unit, it had nothing to do with me in terms of my responsibilities. My responsibility in the department was the publicity of the ANC in terms of interacting with the world environment.

CHAIRPERSON: ....(indistinct)

MS MARCUS: External.

CHAIRPERSON: ...(indistinct) the country.

MS MARCUS: External to South Africa.

CHAIRPERSON: ...(indistinct) confusing me. You had just told us that your office was the in-house printing, and I couldn't see the similarity between in-house and external, but I now understand it, thank you.

Any other questions?

CROSS-EXAMINATION BY MR DU PLESSIS: Thank you, Mr Chairman.

Ms Marcus, we haven't met, I'm Rulof du Plessis. I act for Jerry Raven who planted the bomb. Ms Marcus, in respect of that specific area, would you say that that area at night was a busy area, was there lots of nightlife there?

MS MARCUS: Not particularly, no. It was a residential area, a lot of people lived around there, there were - you know London doesn't have this vast separation between who lived and what happened, so the houses on the next sides could be living, but it wasn't in a sense of nightclubs and cafes and busy in that sense, but it was a normal residential area of London that would have the normal activities in terms of a residential area, not sort of city centre. The market was a day market, it wasn't an evening market.

MR DU PLESSIS: Alright. One could have expected people to have returned late at night from a night out on a Saturday night in that area?

MS MARCUS: ...(indistinct)

MR DU PLESSIS: And Ms Marcus, the market area, can you just explain to me on Exhibit NN, exactly where the market was that we are talking about.

MS MARCUS: I'll try to. If you move westwards we've got White Lion Street, as you can see now, if you went one block parallel, that would have been Chapel Street and that's the market street. And if you took, say where we've got the, the first block that you would come to, just as we've identified one block here, if you took the next block, that street, as I said my recollection is, and I may be wrong, that is was Baron Street, but it might not be that, that street would also be part of the market.

So the market would come up to, and you would have some stalls, almost up to the point of White Lion in that street there, and that would link into, so the street parallel to White Lion Street is Chapel Street, that whole street is a market street.

And the market street in the UK is, you put out your stall and you've got your fruit and your vegetables and whatever else you're selling, a very, very busy market, both sides all the way down the street, including that street there.

MR DU PLESSIS: Alright. You indicate while you're testifying - if I can explain it in this way, you indicate that the market would have stretched up to the left-hand corner of the page that we've got, the top left-hand corner of the page, is that where the market would have ended, if I can put it that way?

MS MARCUS: No, the market street, the actual street of Chapel Street goes much further down. What I'm saying is that - and if you went down further you'd find the diagonal if you want, the block up from Penton street. So the diagonal that would be parallel to Penton Street on or quite a way down you'd also have markets in those diagonals. But Chapel Street itself began at the top of Penton Street because that's where, if you were on the west there, your Chapel Street, Penton Street, the corner of Chapel Street and Penton Street would be where the market started, it would have gone down very extensively, virtually the whole length of Chapel Street.

MR DU PLESSIS: Alright. I just wanted to ...(intervention)

MS MARCUS: It started in Penton Street.

MR DU PLESSIS: I just want to determine if I understand you correctly, there is a block between White Lion Street and Chapel Street ...(no sound) There would be a block of buildings between White Lion and Chapel Street, you would walk in Penton Street, cross White Lion Street, walk down the block and then reach Chapel Street, is that correct?

MS MARCUS: You would have two access, one down White Lion Street and then across, or in Penton Street at the top and into Chapel Market. But what I'm also raising is that the market wasn't restricted to Chapel Market, if you went to the Italian deli on the corner right next to our office on a Sunday, you would have found that a lot of people would have packet out the Italian deli, it was their busiest day of the week.

So you would look at it in a sense that that, it wasn't sort of that you went to Chapel Street and you didn't do something else. The Italian deli would have been extremely busy on a Sunday and on a Saturday, those were their main days, and as I said people would have been walking and parking and moving around here to get into Chapel Street.

No cars would go into Chapel Street on a market day, you go there on foot and you park somewhere else because you have barrows in the street, you've got your walkway between, and it would have been a very, very busy thoroughfare.

CHAIRPERSON: One other point if I could just for clarity, and I want to make it quite clear I'm not talking about Sunday morning now. From the Plan BB if appears, you were asked about whether it was busy at night, there was a pub in White Lion Street near the Penton Street corner, is that so?

MS MARCUS: Yes, but the question with Britain is that I think it would be quite hard to go past any block that didn't have a pub. So it's that - you know in a sense that when I'm saying residential area, it is the normal activity in a residential area, you'll have your pub, you'll have this, and people go and do those kinds of things in their residential areas, the pubs are always there.

CHAIRPERSON: And in the plan Exhibit BB it also shows the police in Penton Street.

MS MARCUS: I don't have plan BB in front of me, I've got - yes, the police were opposite our offices, more-or-less, but I, that one if I recall, I may not be absolute, but I recall that was mainly traffic fines and things like that, that was the office where you went and paid your fines. So it was a police station that dealt with traffic offences and things like that. I'm sure they had a police station there as well, but it was mainly related to paying traffic fines. That's my knowledge of it because I had to go there and do it a couple of times myself.

MR DU PLESSIS: Right. Ms Marcus, then you would agree with me that, and that is my experience, is that shops open in London round about 10 o'clock usually, in the week, isn't that so? I'm talking of shops specifically.

MS MARCUS: No, definitely not.

CHAIRPERSON: Week or weekend?

MR DU PLESSIS: Let me phrase it like this, Mr Chairman. Over the weekend round about 10 o'clock, and I think in the week 9/10 o'clock.

MS MARCUS: Not the London I know and certainly not on weekends. If you're a market, a market, about a market is that it starts early.

MR DU PLESSIS: I'm talking about shops.

MS MARCUS: Shops vary, but I would have thought that by 08H30 most things are open, certainly by nine, it's certainly not 10 o'clock. I'm not aware of shops starting in London at ten. I mean I know that they, that that may be sort - I mean I'm certainly not aware of shops opening at ten.

MR DU PLESSIS: Well Ms Marcus, we can look at that, I have plenty of books at home indicating the opening times of markets and shops, tourist books. So we can independently establish that.

CHAIRPERSON: Well I can say I lived in London for some years and I don't know of shops opening in London during the week at 10 o'clock.

MR DU PLESSIS: Well Mr Chairman, at least not earlier than 9 o'clock.

Do you agree with me, Ms Marcus?

MS MARCUS: I think it depends on the nature of the shops. I mean it depends what you're shopping for. Stores that would be like John Orrs or something like that would have opening hours of eight thirty or nine. Different shops that you would looking at, you want to go into a cafe or you want to go and get - I can give you my own example if you like, is that before I started working with the ANC I used to work in a cafe and we started at six and we would be busy from six onwards, so it was a shop, the shops around us were open, so I don't know where the 9 o'clock or 10 o'clock started. Certainly all the customers who were coming in, who were going into the offices and the shops, came in well before eight.

MR DU PLESSIS: And what time were you saying did shops open generally on Sundays, Ms Marcus? At the same time, 9 o'clock, 8 o'clock? Is that what your testimony is?

MS MARCUS: I would actually have great difficulty being the authority on when shops open in London. I think London has - it's very different from here because I mean, a lot of shops are open 24 hours and a lot of shops have late-night shopping, so really, I'm not an authority of when shops open. I was never a great shopper, I'm very poor at it. Perhaps if you ...(indistinct) with the money I had in London, I'd have a better idea of what I could buy, but I wasn't a great shopper.

In terms of Chapel Market, those kinds of markets would be early, I mean there by eight or certainly by 8 o'clock on a morning. Your markets are busy, they're fruit, vegetables, people come there for the morning, and 10 o'clock, I don't think they would be opening by ten, I think that's very late for that kind of activity.

CHAIRPERSON: But ordinary shops wouldn't open on a Sunday, would they? Not in 1982, because Sunday opening is a recent development, isn't it?

MS MARCUS: As I said I really would have difficulty being an authority because it wasn't a pastime of mine.

MR DU PLESSIS: Thank you, Mr Chairman, I was coming to that.

Ms Marcus, you will recall, or maybe you won't recall, that there was a big dispute in Britain, I think in the beginning of the 1990's, maybe the late 1980's, about shops opening on Sunday, can you recall that?

MS MARCUS: You know, I remember there being a dispute. When I was in the UK, and I left in 1990 when the ANC was unbanned, shortly after that I was asked to come home and I was in Lusaka for some time, so anything that occurred after the beginning of the 1990's I would not be able to answer.

Prior to that there was a dispute because obviously in a country, I think in any country there's discussions around religious sensitivities and Sunday openings.

It would not have been something that was very uppermost in my mind at all, it was very peripheral to the kind of life I was leading or the work I was doing. So yes, it may have been taking place, but it wouldn't have been something I would have been engaged in particularly.

MR DU PLESSIS: Ms Marcus, the only point that I want to make and that I want to know if you agree with me is that on Sundays at that time, shops did not open.

MS MARCUS: No, I cannot agree with you because I think that you'd be able to do this very scientifically, you could go to the management of London's council, I'm quite sure that, there is Lincoln Burrough(?) who would be able to tell you the opening hours of Chapel Market.

MR DU PLESSIS: I'm not talking of markets, I'm getting to the market, Ms Marcus, I'm talking of shops.

MS MARCUS: Equally I think that they would give you rulings on what can or can't open and what can and can't be sold on a Sunday. I would be able to tell you that in terms of where I was working the Italian deli opened early, beyond that I wouldn't be able to tell you much. I was not somebody who went shopping the mornings, I couldn't tell you what time they opened.

MR DU PLESSIS: And Ms Marcus, do you also agree with me that Oxford Street is not bustling, even today, at

8 o'clock on a Sunday morning or even 9 o'clock on a Sunday morning? Not Oxford Street, not Regent Street, not any of the main shopping streets in London. ...(indistinct). Ms Marcus, I'm putting it to you, Sunday morning is a quiet morning in London, especially in respect of shopping, and I'm talking shops, not markets.

MS MARCUS: As I said, I'm not an authority on how shops open or who does their shopping on a Sunday. I can't help you more than that. My particular area of knowledge would be what would happen around where I was working, and that is what I can answer on, but in terms of generally in London, I think you need a person who is a London expert.

MR DU PLESSIS: Yes, well we will see about that, Ms Marcus, maybe we will call somebody as a witness.

CHAIRPERSON: ...(indistinct) you would like us to go over for an inspection, Mr du Plessis.

MR DU PLESSIS: I was getting to that, Mr Chairman.

ADV DE JAGER: Well seeing that we've got the Deputy-Minister of Finance here, perhaps you could work out a budget.

MS MARCUS: No, no, it would never be allowed for tax reduction purposes I can assure you.

MR DU PLESSIS: Alright, Ms Marcus. And then in respect of the school, you would agree with me that any school activities over a weekend would be the normal extramural activities, isn't that so? - like sport and things.

MS MARCUS: I wouldn't - yes, I mean generally that would the case, and I wouldn't be able to comment on the specific of the type of activities that these schools conducted, I just know from my working there that there were often on a weekend and on Sundays, children gathering in that area for different activities. What they did or how their schools performed or related to that, I really did not have knowledge about. But certainly, given that I worked there regularly, there were certainly children in that area at that time, on a regular enough basis that one would be aware that there were children there.

MR DU PLESSIS: Yes, Ms Marcus, but you would also agree with me that in all probability there wouldn't be a, it would be more probable to have expected children there on for instance a Saturday morning or a Saturday afternoon and a Sunday morning 8 o'clock/9 o'clock. Do you agree with me?

MS MARCUS: Generally speaking probably, yes.

MR DU PLESSIS: Yes. And the same probability is applicable in respect of the shops, Ms Marcus.

MS MARCUS: No.

MR DU PLESSIS: It is more probable - just give me a chance, isn't it more probable that you would have had many more people on the street, 11 o'clock, 12 o'clock right through to 3 o'clock on a Sunday doing shopping, than people doing shopping between 8 o'clock and 9 o'clock on a Sunday morning?

MS MARCUS: It depends whether you view the people who work at those stalls and who work in those shops as dispensable and not counting when you look at the number of people around. I mean if you going to a shop or you're going to go to a market, people have to set that up, the goods have to be delivered, it's fresh on that day. So that happens very early on a day if you're setting up a market.

You know I would say yes, if you looked at it to say well there might be more people at eleven or twelve, that may be true but it certainly would not be empty. And to me the critical question about this is that you have a market that is busy, that is known to be busy, that people set up their stalls, they are in the vicinity, and I think that when one looks at this, I mean I don't go beyond the value of one person you know. I think if you're weighing these up, do you weigh it in one, do you weigh it up in ten, what's your acceptable limit of injury.

As far as I'm concerned the whole thing is a disgrace that it happened because you're in an area that innocent bystanders are there. So you know the question of how busy it is, I mean the implications of what you're saying for me is that there's an acceptable level of death. There's no acceptable level of death.

MR DU PLESSIS: No, Ms Marcus, I'll get to the argument. The point is, Ms Marcus, how many people at this very busy market at 8 o'clock on a Sunday morning doing their weekly shopping at 8 o'clock on a Sunday morning, - as we all know the practice in South Africa apparently and in London is as if you want to indicate to us, how many people were injured by this blast, who were at the market?

MS MARCUS: There was no-one injured in this blast at the market. There was no-one injured in the blast other than sort of shock issues for Vernet Mbatha. I don't think that's the issue. If you want to look at it, I have no doubt that there is Lincoln City Council, can give you statistic for White Lion Street in 1982, when it started, when it was busy, how many stall holders, because they would have that kind of information.

MR DU PLESSIS: No, you see ...(indistinct)

MS MARCUS: ...(indistinct) busy popular ...(indistinct)

MR DU PLESSIS: I'm sorry, Ms Marcus, your last words were: "It was a very busy popular market." Now Ms Marcus, you see the point is nobody was injured in Chapel Street at the market because it was planned. And that was the evidence of my client, Mr Raven, it was planned that the damage would not go as far as that. The second point to this, Ms Marcus, which I'm trying to establish and which I will argue, is that in respect of the shops around the ANC's offices, that the probabilities that those shops were open at 9 o'clock on a Sunday morning are really very small, and the probabilities of people walking around in White Lion Street and Penton Street on a Sunday morning are very small.

MS MARCUS: I can't agree with you, the Italian deli would certainly have been open in my view, and second of all the question is were there people in the office itself. So I think that what you're saying is that well, if there were people in the office, they were expendable.

And if you looked at it in terms of what happened in terms of what happened in terms of the Italian deli ...(indistinct), if you went there and you saw how busy they were you'd know what we're talking about. It was a very, very popular shop, it had won awards as one of the best importers of Italian food. It was a point of destination on a Sunday for shopping, and certainly my recollection. As I said in terms of if you wanted to verify it, I've no doubt you could go back to the records, but it was not a late opening event. Sunday markets were not late.

MR DU PLESSIS: Ms Marcus, and what did this Italian deli sell?

MS MARCUS: ...(indistinct) Italian foods, cheeses, salamis, pastas, all imported from Italy and it was a very popular deli.

MR DU PLESSIS: Well what I'm trying to establish, did it sell pasta which you buy and then take home and cook or did it sell food that you can buy there, like a restaurant?

MS MARCUS: No, it wasn't a restaurant it was a deli, but you could eat in the sense that you could have rolls and things like that. So people would go in and buy their rolls, put salami that they would choose and make their sandwich, they could do that. But there was no sitting down, it was a deli in which you bought and took away.

MR DU PLESSIS: Alright. And it seems to me, Ms Marcus, that you are saying to us that the probabilities are overwhelming that lots of people on a Sunday morning at 8 o'clock would go to the Italian deli to buy pasta, that's what you're saying to us.

MS MARCUS: That's my recollection. It was a very popular deli, yes.

MR DU PLESSIS: Yes.

MS MARCUS: It's food was very good, I can testify.

MR DU PLESSIS: Yes, it sound very probable to me, Ms Marcus, I will however argue the opposite. And I'm putting it to you that I will argue that from all the times that could have been chosen, pertaining to when a bomb should be placed here, a Sunday morning between

8 o'clock and 9 o'clock was the best time for anybody to decide to place a bomb there with the least possibility of people being hurt.

MS MARCUS: You know there's two things about that that offend me, first of all you're asking me to comment on when was a suitable time and when there would be least injury, really that's got nothing to do with me. As far as I'm concerned, the fact that people actually sit and calculate these things is part and parcel what they have to account for.

Second of all, you're also asking me as a person who would have been in that office right, and it was one time in my life that I was not there and you're asking me to say this was a suitable time. Well yes, it might have been very suitable to everybody else, I think I'm just lucky to be here and not there sitting in a grave in London somewhere. So quite frankly I think it's really obtrusive of you to actually ask me whether I think that's a suitable time. I don't think that that's an acceptable question to me.

MR DU PLESSIS: Well Ms Marcus, irrespective of the fact that you may have been in the office or that you could have been in the office, the point is you were there. You were called as a witness before this hearing to come and testify to this Committee about the circumstances, and you have tried to portray to this Committee how busy this area on a Sunday is, you have tried to explain to us how many people buy pasta at 8 o'clock on a Sunday morning, you have tried to explain to us how many children go to school on a Sunday morning. The point I'm trying to make to you in answer to your evidence, Ms Marcus, is I'm putting it to you that of all the possible times these people could have decided to put a bomb there between 8 o'clock and 9 o'clock on a Sunday morning, according to their evidence, was the best time with the least risk of people being hurt, injured or killed.

CHAIRPERSON: Was it better than ...(indistinct) seven?

MR DU PLESSIS: Now the question is - Mr Chairman, or early on a Sunday morning, if I can put it like that. ...(intervention)

CHAIRPERSON: You didn't, you put it specifically 8 to 9 a.m.

MR DU PLESSIS: Well let me make it early ...(intervention)

CHAIRPERSON: ...(indistinct) suggest to you that this is a matter for argument surely.

MR DU PLESSIS: But Mr Chairman, she was there, with respect.

CHAIRPERSON: Yes, and what she said is she disagrees with your 8 to 9, because she was normally sitting in her office between 8 and 9. And one can understand her feeling this was not a safe time.

MR DU PLESSIS: Well Mr Chairman, my next question was, what other times were there, Ms Marcus, when that area was much more quieter?

MS MARCUS: Perhaps Mr Williamson should have asked me for the times when we would evacuate and he can go and do a bomb with absolute surety. I don't think that that's the kind of question that I'm willing to answer. I think the question here is, if they were weighing up when it would be suitable, the question is, whose lives were you willing to risk and how far were you willing to go in a country that is not your own and to take innocent lives. I mean the question is, you may have a disagreement with me because I was a member of the ANC or the ANC because it was a liberation movement that you didn't like in South Africa, it had nothing to do with London and therefore the question that you are asking me, I'm saying that I don't think it is my responsibility to answer what would have been a suitable time. A suitable time would be never because you had no right to put a bomb there, at any time. And therefore the question for me here, what I've tried to do in terms of coming here today is to say this was an environment in which there was risk, this was an environment in which you planted a bomb which for my good fortune I must say I was not there at the time.

The question that arises for me is the callousness because as I said I don't think this bomb was intended for me at all, I think it was intended for this office. I'm saying I don't think it mattered whether we were there or not.

And the question of sending me a postcard from Botswana after that, indicated that there was a clear awareness about what the consequence was. So really I think your points that may be in the interest of your client, that he took the least risk possible and he has acceptable levels of risk and acceptable levels of death, that's up to you and your client. As far as I'm concerned there is no acceptable level of death, there was no right to place that bomb or to assassinate people.

MR DU PLESSIS: Yes, Ms Marcus, however you supported the ANC's armed struggle, isn't that so?

MS MARCUS: Absolutely, and we've got the democracy we have as a result.

MR DU PLESSIS: And do you suppose ...(intervention)

CHAIRPERSON: Are you going on to a new aspect, Mr du Plessis?

MR DU PLESSIS: Mr Chairman, maybe I should return to this point. I will get to that aspect just now.

CHAIRPERSON: Well we'll take the adjournment ...(indistinct)

GILLIAN MARCUS: (s.u.o.)

CROSS-EXAMINATION BY MR DU PLESSIS: (Cont)

Ms Marcus, in respect of this last point, I've decided not to debate with you the difference in callousness between a bomb on a Sunday morning, injuring nobody and a bomb on a Friday afternoon, injuring and killing hundreds of people. So I'm not going to debate that with you.

Now Ms Marcus, you testified that you were responsible for the intelligence section, if I can put it like that, of that office, is that correct? - the ANC.

MS MARCUS: Absolutely not, not ...(indistinct)

MR DU PLESSIS: Now can you tell me what your responsibilities were?

MS MARCUS: I think there's an enormous difference in an intelligence office and a publicity information office. My publicity information office dealt with information that was public, it primarily related to taking South African newspapers and putting them into some form that made them accessible to the world about what was happening in South African in its own words, and making available documentation or publications that were produced legally in South Africa, they were not illegal documents. Obviously once those documents had the ANC label on it they became illegal, but the content was all from legal sources.

Secondly, it was about publicity and information. Publicity and information is communicating to an anti-apartheid worldwide network, bodies such as the United Nations, the US Congress Senators, British Parliament, bodies like that throughout the world in most parts of the world, that were looking to know what was happening in South Africa, what role they could play in support of the anti-apartheid struggle, and that was communicating in that regard, that type of information. That is very different from my understanding of an intelligence office.

MR DU PLESSIS: Alright, alright. So you were not responsible for any publications advancing the ANC's cause, advancing the anti-apartheid cause, explaining the struggle, enhancing the struggle, explaining the reasons for the armed struggle? You were not responsible for those kind of publications?

MS MARCUS: No, I am saying that - I would not draw the distinction for that, I'm saying that there's a difference between information about what the ANC stood for, including its armed struggle which was part of publicity, for instance if one signed the UN Geneva Conventions about conduct of war, that would have been a statement made by the President of the ANC, Oliver Thambo, that statement would be reproduced and I would certainly be part and parcel of ensuring that that statement was available to people who wanted to know about it.

So ANC's policies absolutely, one was there as part and parcel of an information network to the world about what was happening in South Africa so that people could know what was going on and support the struggle against apartheid.

MR DU PLESSIS: Yes, Ms Marcus, so it goes a little bit wider than simply reprinting what was printed in the South African press legally? It goes wider than that.

MS MARCUS: It certainly goes wider than that, but what I'm saying is that, you asked me what my primary task was, my primary task was the production of an ANC news briefing which collated and conveyed that information.

MR DU PLESSIS: Ms Marcus, you were responsible for the propaganda programme of the ANC, isn't that so?

MS MARCUS: I was one of the people certainly, involved in information, conveying the positions, the policies, the views of the ANC. You might call it propaganda, I would not necessarily do that, propaganda for me has an element of distortion and opportunism in it. I don't think that that's what we conveyed, I think we conveyed information.

MR DU PLESSIS: Ms Marcus, and that was the ANC's main office in the world, isn't it? That was the office of the ANC.

MS MARCUS: No, not at all.

MR DU PLESSIS: The most important office.

MS MARCUS: Not at all.

MR DU PLESSIS: Where was the most important office?

MS MARCUS: The ANC's head office at that time was in Lusaka, prior to that, it had been in Lusaka for some time, it's head office was in Lusaka, it had offices around the world. London was perhaps its major one in Europe but not the only one in Europe, but certainly because of the historical reasons that that was the first office that was set up in Europe, an important office, certainly not the main office. The ANC's headquarters were originally in Tanzania and then in Lusaka.

MR DU PLESSIS: Yes. Now Ms Marcus, Setchaba was printed on that printing press, isn't it so?

MS MARCUS: No, it was not printed on the printing press at all.

MR DU PLESSIS: Well that is what Mr McPherson testified and that was the intelligence that the South African Security Forces had. Are you saying that that was wrong?

MS MARCUS: Well I would think that - absolutely wrong. If they read Setchaba, which I know they did because they used to actually subscribe to it as well, it would indicate where it was printed, it was a solidarity printing by the GDR, I've forgotten, was it Dresden I think that they printed on, and that was printed on the document, printed in the GDR on these presses as a solidarity gesture for the ANC.

MR DU PLESSIS: Alright.

MS MARCUS: So it was not printed there at all. Setchaba Editorial Board was in the UK, its content was produced by the editorial team of Setchaba, which I was not part of, but it was an ANC team of journalists who produced the content of Setchaba, but its printing was done in the GDR.

MR DU PLESSIS: Alright, Ms Marcus. And your, the work that you did in that office, that was totally directed towards the enhancement of the struggle of the liberation movements against the apartheid South Africa, is that correct?

MS MARCUS: Absolutely.

MR DU PLESSIS: Every little minute you spent on that, on your work?

MS MARCUS: Yes, indeed.

MR DU PLESSIS: Alright. And you were also a member of the ANC.

MS MARCUS: Yes, indeed.

MR DU PLESSIS: And a member of the South African Communist Party.

MS MARCUS: Yes.

MR DU PLESSIS: And you're still today a member of both.

MS MARCUS: No, I'm not a member of the Party, I am a member of the ANC.

MR DU PLESSIS: You're not a member of the South African Communist Party?

MS MARCUS: No.

MR DU PLESSIS: And when did you resign?

MS MARCUS: I didn't resign, it was a question that when one, when the Party and the ANC were legalised in South Africa, it was a question then of joining that Party, and I didn't do that. So I'm a member of the ANC and I did not join the Party when we came back to South Africa.

MR DU PLESSIS: Are you saying to us today that you are not a member of the South African Communist Party in South Africa? Is that what you're saying?

MS MARCUS: I'm not a member. I'm not quite sure what you're asking me. Am I saying that I'm a member of the part, of the ANC certainly, I'm a card-carrying member of the ANC and very proud of it, I have been for 30 years almost. A member of the Communist Party, I'm not a member, I fully support what they stand for and their right to exist and I would defend that absolutely.

MR DU PLESSIS: And therefore you're a communist, is that right?

MS MARCUS: Not at all, I'm a member of the ANC. Because I recognise the right multi-democracy, a multi-party democracy in the country does not make me a member of that. I would certainly respect the right of the Freedom Front to exist or the National Party to exist, but I'm not a member of either.

MR DU PLESSIS: Ms Marcus, I'm not going to debate with you how communism and multi-party democracy have reached each other in this whole strange fiction of things, I'm not going to debate that with you.

Now Ms Marcus, on that Sunday morning ...(intervention)

MR BIZOS: May I suggest with the greatest respect, that if he doesn't want to debate he shouldn't start it, when he gets the wrong answers, and these are questions more suitable by prosecutors during the apartheid regime.

MR DU PLESSIS: Mr Chairman, I don't know if Mr Bizos is angry now and if that is the reason why I'm making this statement. Can I carry on please?

CHAIRPERSON: Carry on.

MR DU PLESSIS: Thank you, Mr Chairman.

Now Ms Marcus, you testified that there were banners at the offices that had to be collected that morning.

MS MARCUS: Yes.

MR DU PLESSIS: Is that correct?

MS MARCUS: Correct.

MR DU PLESSIS: And where were these banners?

MS MARCUS: Basically when you have a march, what we would do is make placards so that people could walk along where you've your slogans or what you want to say or your posters, you put them on a stick and you can walk along carrying what the message you want to convey. We had made a whole lot of these. My recollection is having made them we had piled them up, if you looked at Exhibit DD, you went in these front stairs there, there's a little foyer there and the reception room to the left and we had piled them all up there for collection. That's the exit point of the office, and it would have been where we'd put them so that we could load into the cars or whatever was fetching them, to go the rally as easy as possible.

MR DU PLESSIS: Alright. And that morning, Ms Marcus, you say you had a meeting at your house, is that correct?

MS MARCUS: That's correct.

MR DU PLESSIS: With whom did you have that meeting?

MS MARCUS: Other ANC members.

MR DU PLESSIS: And what was the meeting about?

MS MARCUS: I don't actually recall.

MR DU PLESSIS: Alright. Can you recall ...(intervention)

MS MARCUS: I actually think it might been our unit of ANC members who'd met at my house.

MR DU PLESSIS: And when was the march scheduled for, can you remember?

MS MARCUS: It was either mid-day or, probably by mid-day or early afternoon, maybe 12 or 2, somewhere around there.

MR DU PLESSIS: And you would have gone to the office, collected the banners and then gone to the march, is that correct?

MS MARCUS: Yes.

MR DU PLESSIS: So that would have happened if it wasn't for the bomb and everything went smoothly, that would have happened late in the morning, isn't that correct?

MS MARCUS: Not necessarily because one could have - I mean the question was one's looking at a series of circumstances. The fact that the people had the meeting at my house meant that we would have gone perhaps slightly later, if we had not decided to have the meeting at my house we would have gone earlier. I'm not sure whether the people who planted the bomb knew we were having a meeting at a house and therefore wouldn't be there early. I don't know if they knew that. So normally it would not have been the case. You would have gone there whatever time was convenient to load it up and to make sure you were there at the assembly point on time with the banners, so people arriving would be able to get their placards.

CHAIRPERSON: Yes, but if the meetings, the demonstration was at 2 o'clock in the afternoon, you wouldn't be arriving at Trafalgar Square with banners and things at 10 o'clock in the morning would you?

MS MARCUS: Not necessarily, but people would gather fairly early and those who would be preparing where you would assemble would come with goods. It would also depend who was collecting and the number of vehicles you had, it's not you know, it would not have been first thing in the morning necessarily, but he banners may have been collected earlier and not necessarily taken straight to Trafalgar Square. You would collect them, you may be doing other things, you may have even gone shopping.

MR DU PLESSIS: Now Ms Marcus, but you had the meeting that morning.

MS MARCUS: Yes.

MR DU PLESSIS: So you knew that that meeting, that morning specifically - I'm just trying to determine your behaviour that morning, you knew that you would have had the meeting so you would only have gone for the placards after the meeting, is that right?

MS MARCUS: Yes, I would say so and I think that, at the best of my recollection we'd have probably gone about 11 or something around that time.

ADV DE JAGER: But would you have been responsible for the collection of the banners, or could somebody else collect them and take them? Was it your responsibility or maybe someone else who would have gone and collected it?

MS MARCUS: It could have been someone else as well, but the likelihood, given that it would have been me meeting people there, it would not have only been myself collecting them, but the likelihood would have been that I would have been there to see that the office was open and that they were able to be distributed.

MR DU PLESSIS: Yes. And Ms Marcus, you consulted with Mr Bizos about this?

MS MARCUS: How do you mean?

MR DU PLESSIS: About everything that you testified about today, you consulted with Mr Bizos, isn't that right? - beforehand.

MS MARCUS: In terms of ...(intervention)

MR DU PLESSIS: Before today.

MS MARCUS: Well not everything. I didn't anticipate some of these questions.

MR DU PLESSIS: Yes, no, no, no, I'm talking mainly of your evidence-in-chief.

MS MARCUS: Certainly I made it, I was asked questions around, or I raised the question that this is my experience of what occurred and had a discussion with Mr Bizos about that.

MR DU PLESSIS: And when was that, Ms Marcus?

MS MARCUS: Last year sometime. I don't remember exactly, it was last year sometime.

MR DU PLESSIS: It must have been before Mr Bizos cross-examined Mr Williamson.

MS MARCUS: I don't recall.

MR DU PLESSIS: Because Mr Bizos had to put your version, isn't that so?

MS MARCUS: I don't recall. I haven't been following the processes of when Mr Bizos cross-examined Mr Williamson.

MR DU PLESSIS: Well from reading the record, it's clear that he had instructions from you.

MS MARCUS: Well if it has been cross-examined and this placed on the record, then that would be correct that it was before.

MR DU PLESSIS: Yes, because you see at page 838 of the record, Mr Bizos asked the following question to Mr Williamson:

And he says:

And then Mr Bizos said:

That's what Mr Bizos put in cross-examination to Mr Williamson. It differs substantially from the evidence you've given us now.

MS MARCUS: In what way does it differ substantially?

MR DU PLESSIS: It says that the people were expected to fetch the placards and the posters for the rally at about 9 o'clock.

MS MARCUS: Well that could well have been the case. As I said, I mean the question of when you went depended on whether we were at the meeting. The fact that we were going in the morning to fetch those placards, as you're saying as I'm saying now, it was me, we would have had the meeting, we would have fetched it slightly later. I don't see a major contradiction in that at all. The question is that on the morning before the rally the placards would have been fetched.

MR DU PLESSIS: No, you see Ms Marcus, that nowhere in this evidence, ag, in Mr Williamson's evidence during cross-examination was it put that you were at a meeting and that only after the meeting the placards would have been collected. I'm trying to determine why does Mr Bizos' version and your version differ.

MS MARCUS: Well I can't answer for that in the sense, what I'm saying is that to the best of my recollection if I was involved in collecting those placards which I would have been part of, in all likelihood it would have been after the meeting, if other people were coming it may well have people coming earlier and fetching. If you recall Mr Vernet Mbatha lived in the place and if people came to fetch, they could have come earlier.

MR DU PLESSIS: But, Ms Marcus ...(intervention)

MS MARCUS: I don't recall if I was the only one fetching.

MR DU PLESSIS: Ms Marcus, so your evidence about 11 o'clock just now must then have been wrong.

MS MARCUS: No, I'm saying that if I was the one fetching, I would have fetched it after the meeting, which would have been around 11 or slightly later, slightly earlier. We had a meeting at my house which would have finished in time for us to get to the rally in order to ensure that all the preparations were done.

MR DU PLESSIS: Well where would Mr Bizos then get the 9 o'clock from?

MS MARCUS: Well perhaps in my discussion we said that was the time when we were going to go and fetch it. I'm not quite sure whether the 9 o'clock would have been an absolute. The question I'm raising and saying that if it was me who was fetching, it would have been slightly later. I'm not sure that I'm the only one who was fetching. I don't recall the detail about whether I was the only one fetching or not. If other people fetched, they could have fetched at anytime.

MR DU PLESSIS: Yes, you see ...(intervention)

MS MARCUS: There's somebody on the premises who was able to let people in to fetch the placards.

MR DU PLESSIS: Yes, Ms Marcus.

MS MARCUS: It wouldn't be one vehicle that those placards would fit in.

MR DU PLESSIS: Ms Marcus, the point is if the people were expected at about 9 o'clock, that's exactly the time the bomb would have gone off. So it seems that it was important to place the possibility of people collecting the placards at about 9 o'clock.

MS MARCUS: Well they certainly could have been collected then. I don't think that the question of saying it would have happened or not happened, the question of - as I'm saying also, the meeting is totally fortuitous. I'm not quite sure, and perhaps the people who planted the bomb can tell us whether they knew we were having a meeting, and therefore that was part of their consideration. I don't think that that would have been the case, because that would have been something that was very, determined a very, very short time before the meeting itself.

MR DU PLESSIS: Well Ms Marcus, do you concede the possibility that they may have had information about this meeting?

MS MARCUS: Depends what they were tapping and not tapping in those days. They would be the only ones who'd know.

MR DU PLESSIS: No, but do you concede the possibility, do you concede the possibility?

MS MARCUS: Whether they knew about that meeting?

MR DU PLESSIS: Yes.

MS MARCUS: Um ...(intervention)

ADV DE JAGER: Mr du Plessis, we had, as far as I recollect, no evidence about them knowing about it.

MR DU PLESSIS: I know, Mr Chairman, there was no evidence but one must remember, Mr Chairman, that we're talking of 15 years ago. So it is possible that it is something that nobody could remember. I'm just talking about possibilities, Mr Chairman, and I'm just asking the witness if she concedes that possibility.

MS MARCUS: I would say that there is a possibility, depending how widespread their networks were, about who they were surveilling and not surveilling and if they were there could have been a question of us having that meeting. But it may or may not be relevant because as I said, the question of who collects was not simply related to me, other people could collect those placards as well.

MR DU PLESSIS: Alright.

MS MARCUS: So the people in my meeting were not necessarily the people collecting the placards. I would have been, but not the only one.

MR DU PLESSIS: Yes, Ms Marcus, we will argue on what you testified and the fact that you are testifying now that other people could have collected the placards, whereas you didn't testify that previously. I'm not going to argue with you about that now.

MS MARCUS: No, no, but you are arguing with it and I am saying and I said right at the beginning, was that there were placards there and there's no way that they would just fit in one vehicle, certainly not in just in mine.

MR DU PLESSIS: No, no, Ms Marcus, if ...(intervention)

MR BIZOS: Mr Chairman with respect, a Member of the Committee asked the witness if she was the only one that was likely to pick them up and her answer was:

And that was before the counsel for the applicant read the portion that I had put.

MR DU PLESSIS: No, but Mr Chairman, I asked specifically at what time would the placards have been fetched, she said that would have been after the meeting and she said 11 o'clock. And now ...(intervention)

MS MARCUS: Yes, but I'm saying that related to me collecting them, but not necessarily if somebody else was also collecting them.

MR DU PLESSIS: Well Ms Marcus, you didn't testify to such an extent that you said that somebody else may have collected them. There was ample opportunity for you to testify that and to say that to us, and you didn't. Now that ...(intervention)

MS MARCUS: But I am answering your question.

MR DU PLESSIS: Now that the problem has arisen, now you are telling us about that.

MS MARCUS: No, I'm answering your questions, I don't, I'm trying to answer your questions as best as I can recall. You asked me about what I would do and I said there would certainly have been my involvement in collecting those placards, that I was at a meeting and it would be after that meeting that they would be collected. But I also indicated that there were a lot of placards and it would not necessarily have been only myself who would have been collecting.

MR DU PLESSIS: You see Ms Marcus, I'm going to argue that this is indicative, as well as your refusal to agree with me on the probabilities of the present, it is indicative of an attempt to try and portray this whole situation, and that is what I'm going to argue, the whole situation there at the ANC offices as a place where the planting of the bomb was a grave risk to human lives. For instance a 9 o'clock issue was an attempt to place people, the possibility of people at the office there at the time the bomb was designated to go off. I'm going to argue that. What is your comment on that?

MS MARCUS: Well you can argue. I don't agree. I mean the question is very simple. I would have thing you'd want to look at why thy chose 9 o'clock, I don't think it relates to necessarily who is present. I think the question should, that you need to ask and what is available as to why they chose 9 o'clock, where were they when the bomb went off, were they watching? Did they look to see whether there were people around, did they have a remote on that bomb which wasn't there, it was set for a timer.

So the question to me is if you're presuming certain things, perhaps there are other presumptions that should be where were those who planted the bomb, to see whether there would be damage, who was in the vicinity and to look at the results of their handiwork. Where were they at the time? Then we would know what the point about 9 o'clock is.

MR DU PLESSIS: Ms Marcus, there's been ample and complete evidence about what happened and what the involvement of these people were.

Can I put to you what Mr Raven testified about how he placed the bomb. He testified that he placed the bomb in such a way that, and he testified that they knew that Mr Mbatha, they didn't know who he was, but that there was a person living on the top floor, he testified that the bomb was placed in such a way that it would not result in injury to the person living on the top floor or to injury of people in the surrounding areas. Do you want to comment on that, can you dispute that?

MS MARCUS: I'm not an expert bomb placer.

MR DU PLESSIS: Yes, so you can't dispute ...(intervention)

MS MARCUS: So I can't comment on whether the bomb was placed in a manner that, to cause minimum injury. I think the results of the devastation that it caused is visible for everybody to see. If Mr Raven felt that he had chosen a time that he was guaranteeing safety and that one person in the building didn't really matter, and he could guarantee his safety, I think he must obviously be a very expert bomb placer. Because you know you've got wonderful guarantees that you build in. Obviously his guarantee didn't include whether I was there or not because that was not, that was pure chance and that was a decision taken at 10 o'clock the night before, it was not a decision taken earlier than that.

MR DU PLESSIS: When was the decision taken about the meeting?

MS MARCUS: About me not ... no, no, no, the meeting was held at my place, but the decision about me attending was whether I finished my work. The meeting held at my place has got nothing to do with whether I'm present or not. The decision ...(intervention)

MR DU PLESSIS: No, no, but what was decided at 10 o'clock?

MS MARCUS: Whether I - that I - that the decision of the day before I'm saying that his ability to know whether I would be in that building or not was not something they would have been able to pick up from anywhere or from any conversation or from any surveillance because while the meeting is held in my house there's absolutely no reason why I would necessarily be there.

The contingent factor of me being in that meeting was whether I finished my work on the Saturday. And that we had progressed as well as it was and I decided to stay on the Saturday night to finish, enabled me to attend the meeting. And that's the question around presence on the Sunday. It was pure chance. There was the question that we would have the meeting, I would certainly try to make the meeting, the ability to make the meeting depended on me completing the work on the Saturday.

MR DU PLESSIS: Is there anything you want to add still to this, Ms Marcus? You've added now a substantial part of evidence which you haven't given us before, is there anything else about this meeting that you want to add? ...(intervention)

MS MARCUS: I'm responding to your questions, your questions provoke or elicit a certain response.

MR DU PLESSIS: No, the question ...(intervention)

MS MARCUS: You're asking me, did they have surveillance as to whether that meeting was taking place. I can't answer that.

MR DU PLESSIS: No, but Ms Marcus, ...(intervention)

MS MARCUS: Was there a question of the meeting taking place, absolutely. We had taken the decision that we would have the meeting on that morning and they would be at my house.

MR DU PLESSIS: No, Ms Marcus, ...(intervention)

MS MARCUS: The question of my participation in the meeting would be to the best of my ability having completed my work on the Saturday. I'm relating it to your question about knowing who would be present. I'm saying that they would have had no way of knowing whether I was in that office on the Sunday or I would not be in the office on the Sunday, because the environment may have indicated that there would be other meetings taking place, the decision was dependant on me completing the work on the Saturday.

MR DU PLESSIS: No, Ms Marcus, the only point I'm trying to make is I find it strange that suddenly now after you've conceded the possibility that the Security Police may have had information about the meeting, that you are trying to discount the fact that they may have had information about you attending the meeting, that you are doing it now.

MS MARCUS: No, I am not.

MR DU PLESSIS: I'm finding that very strange.

MS MARCUS: I'm not quite sure that - I mean I can't help what you find strange or what your parameters of thinking are ...(intervention)

MR DU PLESSIS: No, but why didn't you tell us right from the start this whole thing about the 10 o'clock.

MS MARCUS: It wasn't an issue. I'm responding to your questions. Look I can go into a whole diary of my life if you want.

MR DU PLESSIS: No, no, no, but this is important, Ms Marcus. It's important because what you are now saying to us is that nobody, the Security Police or an informer in that office couldn't or wouldn't have known that you would have been there the Sunday morning or not. Now that's quite important.

MS MARCUS: No, I'm saying they wouldn't have known I would not have been there. There's a very big difference, that if they were conducting ...(intervention)

MR DU PLESSIS: Yes, but they ...(indistinct) have information about it. ...(intervention)

MS MARCUS: ... they would not have known by surveillance that I would not have been there. They might have assumed I would not be there because there was an alternate meeting taking place, but they would not have been able to know because it was a contingent of my completing work on the Saturday. I certainly had every intention of meeting that obligation of being in the other meeting on the Sunday morning.

MR DU PLESSIS: Well Ms Marcus, I still fail to understand why an important fact such as that was not tendered in evidence-in-chief, was not tendered when I cross-examined you and ...(intervention)

MS MARCUS: But you're busy cross-examining me now.

MR DU PLESSIS: No, no, no, when you ...(intervention)

MS MARCUS: As you're asking questions so you're ...(indistinct) further.

MR DU PLESSIS: Please give me a chance, please give me a chance. When I asked you about the possibility of people having information about the meeting and your presence there, and that it is suddenly tendered now out of the blue. And I will ...(intervention)

MS MARCUS: I hardly put this out of the blue.

MR DU PLESSIS: Ms Marcus, I will argue, and I put it to you, I'm not going to take this matter further, I put it to you that you are trying to change your evidence so as to indicate to this Committee that nobody could have had information about your whereabouts on the Sunday morning.

MS MARCUS: I'm not changing my evidence, I'm replying to your questions. And I object to you actually calling me a liar. I can't help the limits of your thinking.

MR DU PLESSIS: Well Ms Marcus, if we ...(intervention - laughter)

MR DU PLESSIS: Have you said something funny, Ms Marcus?

MS MARCUS: I'm not aware of that.

MR DU PLESSIS: ... very funny, I don't know if there is anything..

MS MARCUS: Well perhaps you need to cross-examine Mr ...(indistinct)

ADV DE JAGER: Could we kindly proceed?

MR DU PLESSIS: I will proceed. Now Ms Marcus, this postcard that was sent by Mr Williamson, how did you receive it, in the normal mail?

MS MARCUS: Yes, it was - as far as I can recall it was in the mail that would have come to Penton Street, the mail marked for me would be given to me on a daily basis and it was in the mail.

MR DU PLESSIS: And who did you speak to about this postcard, who did you tell?

MS MARCUS: I can't recall, I might have shown it to a number of people, I'm sure I did, but I wouldn't recall the specifics about of who I ...(indistinct) to.

MR DU PLESSIS: But don't you think this was quite an important postcard? This clearly indicated exactly who was responsible for this blast.

MS MARCUS: You know perhaps you need to look at it from a slightly different angle. It doesn't indicate necessarily who was responsible, it indicated a person's thinking about you as an individual because this is not about a bomb, this is about you. This about you surviving or otherwise an act which he may or may not have been responsible for. I didn't know he was responsible for the bomb and it's only in evidence now subsequently under the TRC, that we know who was responsible.

What that postcard indicated was that whoever sent the postcard, and as I said that postcard was signed in handwriting, Craig, and therefore in my mind it was from Craig Williamson, the only Craig I know, posted in Botswana, was that somebody had some of their own thinking about you. To me that question is, and it may be something that's personal in relation to those things, was not the first, in my time in the UK, it was not the only incident around security activities of the South African Police, either for myself or for the ANC. You either let it become part of your thinking and you keep this postcard around and you put it there and you let that person intrude in your thinking and in your life. I don't function that way. I would take that postcard, and I have no doubt I would have taken it, perhaps discussed it or shown it with one or two people, and thrown it away because I would not allow that kind of intimidation to effect me.

MR DU PLESSIS: Well Ms Marcus ...(intervention)

ADV DE JAGER: Well that could have been a piece of evidence that you could have handed to the police.

MS MARCUS: I think you might need to think about what was going on in South Africa in 1982, police about what?

CHAIRPERSON: The English police, about a bombing in London.

MS MARCUS: It was subsequent to that and I certainly didn't relate it to handing in in terms of evidence. I did not think about it in that way.

MR DU PLESSIS: But Ms Marcus, that postcard could clearly have been interpreted in two ways, either it could have been sent by Craig Williamson, as you say you made that deduction, because he knew you were working at that office, or it could have been sent by him because he was the mastermind behind this whole operation, and that's how I understood your evidence you thought about it. Now if that was the case then this postcard could have been of great assistance to the British Police, because they didn't know up to this hearing, who was responsible for that blast.

MS MARCUS: Well neither did I. I read that postcard as something intended for me by the person who may or may not have had anything to do with the bombing.

MR DU PLESSIS: Goodness gracious, Ms Marcus, but if the postcard related to somebody who had something to do with the bombing then clearly that must have been of utmost importance, it could have discredited the South African Government immensely.

MS MARCUS: I didn't the South African Government needed assistance, but I think that the whole question about this bombing which was covered in the press, certainly in my sense of it, it was a card that I'd received from Craig Williamson, it was post the bombing, I did not hand it to the British Police, it was not something that I had ...(indistinct).

MR DU PLESSIS: Well Ms Marcus ...(intervention)

MR SIBANYONI: Excuse me, Mr du Plessis.

Ms Marcus, did you read the message as relating to the London bombing of the ANC office or not?

MS MARCUS: I read it around, about myself in relation to the bombing, yes.

MR SIBANYONI: So to you it was not something which can assist the British Police in their investigation as to who was behind the bombing?

MS MARCUS: No, it didn't - I didn't relate it in that way, and I certainly did not hand it over to the British Police.

MR SIBANYONI: Thank you.

MR DU PLESSIS: So Ms Marcus, do I understand you correctly, are you saying that you didn't think that Craig Williamson was behind the bomb and that he sent the postcard as a result of that, you didn't think that?

MS MARCUS: I didn't think he was necessarily behind the bomb, I think he sent the postcard as a result of it yes, but I didn't think he was necessarily behind the bomb. I would not have known.

MR DU PLESSIS: Is that what you're saying now?

MS MARCUS: Yes.

MR DU PLESSIS: Alright. So the possibility of you thinking that he may have been behind the bomb or that he may have wanted to kill you, we can discount that possibility, from what you thought?

MS MARCUS: I'm saying that at the time I did not know who was behind the bomb, and I indicated very clearly that I did not think that the bomb was related to me individually. The fact of Craig Williamson sending a postcard of that nature was to me something about intimidation, something about an approach that said; we're keeping an eye on you. Whether it would relate to a particular assassination or not, I was not relating it in that way.

That was not - and I think that perhaps if one wanted to look at that, maybe the Security Police should look at all the activities in the '70's and the '80's in the UK, because that was the way I read it. It was intimidatory, it was certainly something that drew attention around myself in relation to a particular person who sent that, by the name of Craig.

I did not think it was something that would help the British Police particularly, I thought it was really something directed at me.

MR DU PLESSIS: And Ms Marcus, do you have any explanation why this postcard would have been sent from Botswana?

MS MARCUS: No.

MR DU PLESSIS: Why would it have been sent from Botswana if it came from Craig Williamson and he wanted you to know that it came from him?

MS MARCUS: You'd have to ask him that, I'm not sure where he sent his postcards to, or maybe he sent it to other people as well.

MR DU PLESSIS: I just find this whole version very strange that's why I'm asking you about it, because I'm trying to struggle to find ...(intervention)

MR BIZOS: Mr Chairman, Mr Levine who acts for Mr Williamson did not put to this witness, nor did Mr Williamson deny that he had sent such a card, he said he may well have done so.

MR VISSER: No, he said he couldn't remember.

MR BIZOS: He couldn't remember whether he did it or not. Well we'll put it ... And he also said, I'm reminded, it's one of the things that he would have done, could have done or would have done. Nevermind ...(indistinct)

MR VISSER: It's page 829.

MR BIZOS: ...(indistinct) talking about the same piece of evidence, but the point about this, Mr Chairman, is that a person who is not acting for Mr Williamson wants to take Mr Williamson's case further by challenging the credibility of this witness, than the attorney for Mr Williamson and Mr Williamson himself were prepared to take it. Is such cross-examination permissable by someone not appearing by Mr Williamson. He's not prepared to deny it, and here we have the credibility of a witness challenged, Mr Chairman.

CHAIRPERSON: I don't think Mr du Plessis, you can put it on the basis that no such postcard was sent. You have no instructions to that effect.

MR DU PLESSIS: No, I'm not doing that, Mr Chairman.

CHAIRPERSON: Mr Williamson in his evidence said:

MR DU PLESSIS: I accept that, Mr Chairman, and I know that was the evidence. I am just pointing out, and that's the only purpose of this cross-examination, Mr Chairman, even though Mr Williamson testified about that and he testified he can't remember if he did it, the improbability thereof, in the light of the fact that we do not have any concrete evidence about the fact that it was done ... but I'll leave it there, I'm not going to pursue this matter further, Mr Chairman.

MS MARCUS: No, you can't leave it there. With respect, ...(intervention)

MR BIZOS: Mr Chairman, how dare my learned friend say that there is no concrete evidence? There is evidence of this witness which the person that is said to have sent it is not capable, is not prepared to deny. What is my learned friend up to, Mr Chairman? On what basis is he conducting this cross-examination?

CHAIRPERSON: Well you have indicated he has no basis.

MR DU PLESSIS: No, Mr Chairman ...(intervention)

CHAIRPERSON: He's testing the witness' credibility, but that he has no information himself on that point.

MR DU PLESSIS: Yes.

CHAIRPERSON: That is so is not, Mr du Plessis?

MR DU PLESSIS: That is so, Mr Chairman.

CHAIRPERSON: You are testing what the witness has said.

MR DU PLESSIS: Yes, but surely I am entitled eventually, after this evidence, to argue that the improbabilities of this witness' evidence, not just in respect of on issue, but in respect of all the issues, should make you careful of ...(intervention)

CHAIRPERSON: Yes. But you have Mr Williamson's evidence again saying that:

MR DU PLESSIS: Yes, that may be so, Mr Chairman, and if ...(intervention)

CHAIRPERSON: It will appear to indicate that Mr Williamson thought such a postcard might well have been sent, and we have had the witness saying she received such a postcard. I don't see that you can take the matter any further, Mr du Plessis.

MR DU PLESSIS: Well I wasn't intending ...(intervention)

CHAIRPERSON: ...(indistinct) wasting time.

MR DU PLESSIS: I wasn't intending to go any further, Mr Chairman.

MR BIZOS: ...(indistinct)

CHAIRPERSON: Well let's continue now with any other questions you have.

MR DU PLESSIS: Well, Mr Chairman, will I be allowed to ask any further questions, with respect.

CHAIRPERSON: If they are relevant.

MR DU PLESSIS: If you will bear with me, Mr Chairman, please.

Right. Now Ms Marcus, Exhibit NN is an empty yard, that is indicated on NN, is that correct?

MS MARCUS: That's correct.

MR DU PLESSIS: Was that only an empty yard or what was that? Was there anything else there?

MS MARCUS: My recollection is that there were certainly buildings around it, but there was a yard here that had, that was an open space there. Where these walls are and so on there were other buildings, but that yard was behind us and that was empty, as far as I can recall.

MR DU PLESSIS: Was there a parking lot there anywhere?

MS MARCUS: It was used as a parking lot sometimes. It was sometimes used as a parking lot in itself in that empty yard.

MR DU PLESSIS: The empty yard itself?

MS MARCUS: Yes.

MR DU PLESSIS: Now you see what I find particularly strange is, on page 835 Mr Bizos put the following to Mr Williamson:

Do you know of what school Mr Bizos was talking here?

MS MARCUS: I'm not sure what you're referring to. As I said, if you looked at this document you would see White Lion free school is on the other side of the road.

MR DU PLESSIS: Yes, yes.

MS MARCUS: This yard was certainly used for children which was there. And as I said in the beginning, I can't remember absolutely but my recollection was that there was another school, that one of these perimeters to this yard was a different school. I did not include it in this because I said at the time I couldn't be absolutely certain about it. The yard was used as a parking lot sometimes, it was used for children to play in, it was that kind of facility.

MR DU PLESSIS: Well if was stated here, Mr Bizos stated that this was a play area of a school. Now that clearly is not correct.

MS MARCUS: Play area - no, that may, it depends how you determine play area of a school. There's a school there - as I said, this is White Lion, it was used by children from the school to play in. That was definitely the case.

It's a not a play area that is the play, that is the school are built in in a perimeter fence of that school, but if you looked at the structure, if you looked DD you'll see how building occur in Britain. There isn't much room and yards around and therefore a yard like that would be used as a facility in terms of a school for children to play.

MR DU PLESSIS: Now Ms Marcus, was the other school also a free school, called a free school?

MS MARCUS: No.

MR DU PLESSIS: It wouldn't have been.

MS MARCUS: As I said to you regarding the other school, I did not include it because I was not absolutely certain where it was. My recollection is that there was a school behind there and the nature of that school would have been an ordinary school. The free school itself is indicated on the other side of the road.

MR DU PLESSIS: Yes. So we can accept that if Mr Bizos spoke about a school he would have spoken about the White Lion free school?

MS MARCUS: I'm assuming so. I was not present and I don't have the ...(indistinct)

MR DU PLESSIS: Yes, I'm just trying to determine this. And if Mr Bizos put that the parking lot was in fact a play school, play area of a school which is called a free school, he was wrong?

MS MARCUS: No, the free school used that play area as well.

MR DU PLESSIS: Oh did they use that play area as well?

MS MARCUS: The kids there were used from the school. The kids from the free school or the other school - as I said I'm not determining the other school, that yard was used for playing in.

ADV DE JAGER: What is referred to here as an empty yard was in fact walled and fenced in.

MS MARCUS: It was walled, the fence itself was not necessarily a firm fence, it had a gate and people could walk in and out.

ADV DE JAGER: Ja. I think we had evidence that taxis used to park there.

MS MARCUS: I'm not sure about that. I know there was occasion that it was used as parking. It wasn't a parking lot in that it was packed, it was something that was occasionally, that people would park their cars there. I don't know, there may have been taxis there, there may not have been particularly.

ADV DE JAGER: Well I may be wrong about the word taxis, but cars parked there. I see that some people are in agreement that there was evidence that taxis were parked there.

MS MARCUS: They may have been, I'm not absolutely sure. I know that that was a yard that was used by children to play in. It was also used periodically as a parking lot, or places where people can park their car rather than a parking lot, if you want to draw the distinction.

MR DU PLESSIS: Thank you, Mr Chairman, I have no further questions.

MR JANSEN: Thank you, Mr Chairman, Jansen in respect of the London bombing incident on behalf of Mr John Adams, I have no questions.

MR CORNELIUS: Cornelius on behalf of Vic McPherson, I don't have any questions, thank you Mr Chairman.

MS PATEL: Thank you, Honourable Chairperson, I don't have any questions either.

MR BIZOS: Thank you, Mr Chairman, no questions.

MR SIBANYONI: Just one question, Mr Chairman.

Ms Marcus, I heard you say repeatedly that the bomb was not intended for you, and help to understand this, you are also saying this was the only Sunday when you were not there which means had you been there you could not have survived the bomb. Now what makes you believe that it was not intended for you, but for the ANC?

MS MARCUS: I think you're correct in that if I had been there I don't think that it would have been possible to survive. Whether it was directed at me and why I think so, because I think that the thinking was pretty much as you've just read out - I was not familiar with Mr Williamson's evidence particularly, but as you've read out, that I think the intention was to try and intimidate the ANC, to try to have a psychological warfare against it. And why I'm saying I don't think it was, the bomb was not there directed at me personally. I think that whether I was there or not didn't matter.

The question was that if you were there it would have been perhaps a cherry on the top for them, if you weren't well, it was part of the psychological warfare that was being waged. And the way I did read that bomb was that it was intended to see whether it could destabilise the activities of the ANC and I think that the approach that the ANC took at the time was to say that in no way are we going to allow ourselves to be intimidated or allow our work to ceased, and we proceeded to do precisely that.