IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA In the matter between: RADICAL HONESTY – SA LARA JOHNSTONE
Case No. CCT #06-11 1st Applicant 2nd Applicant
And SOUTH AFRICAN NATIONAL EDITORS FORUM (SANEF) MONDLI MAKHANYA SA PRESS OMBUDSMAN: JOE THLOLOE SA PRESS APPEALS PANEL: JUDGE RALPH ZULMAN SA DEP. PRESS OMBUDSMAN: JOHAN RETIEF SOUTH AFRICAN PRESS ASSOCIATION (SAPA) MARK VAN DER VELDEN BUSINESS DAY PETER BRUCE BUSINESS REPORT JABULANI SIKHAKHANE CAPE ARGUS CHRIS WITFIELD CAPE TIMES ALIDE DASNOIS CITY PRESS FERIAL HAFFAJEE THE CITIZEN MARTIN WILLIAMS DAILY DISPATCH ANDREW TRENCH DAILY MAVERICK BRKIC BRANKO DAILY NEWS ALAN DUNN EAST COAST RADIO DIANE MACPHERSON EYEWITNESS NEWS KATY KATAPODIS INDEPENDENT ONLINE ADRIAN EPHRAM MAIL AND GUARDIAN NIC DAWES THE MERCURY ANGELA QUINTAL NEWS 24 JANNIE MOMBERG PRETORIA NEWS ZINGISA MKHUMA SA STAR MOEGSIEN WILLIAMS SUNDAY INDEPENDENT
1st Respondent 2nd Respondent 3rd Respondent 4th Respondent 5th Respondent 6th Respondent 7th Respondent 8th Respondent 9th Respondent 10th Respondent 11th Respondent 12th Respondent 13th Respondent 14th Respondent 15th Respondent 16th Respondent 17th Respondent 18th Respondent 19th Respondent 20th Respondent 21st Respondent 22nd Respondent 23rd Respondent 24th Respondent 25th Respondent 26th Respondent 27th Respondent 28th Respondent 29th Respondent 30th Respondent 31st Respondent 32nd Respondent 33rd Respondent 34th Respondent 35th Respondent 36th Respondent 37th Respondent 38th Respondent 39th Respondent 40th Respondent 41st Respondent 42nd Respondent
MAKHUDU SEFARA SUNDAY TRIBUNE PHILANI MGWABA TIMES LIVE RAY HARTLEY 3rd DEGREE DEBORA PATTA BEELD TIM DU PLESSIS DAILY SUN THEMBA KHUMALO DIE BURGER HENRY JEFFERY BUN BOOYSEN E-NEWS PATRICK CONROY FINANCIAL MAIL BARNEY MTHOMBOTHI FINWEEK COLLEEN NAUDE THE GEORGE HERALD MANDI BOTHA INDEPENDENT ON SATURDAY TREVOR BRUCE 702 RADIO PHELADI GWANGWA RAPPORT LISA ALBRECHT THE SATURDAY STAR BRENDAN SEERY SOWETAN BONGANI KESWA THE HERALD JEREMY MCCABE VOLKSBLAD AINSLEY MOOS ROD AMNER ROBERT BRAND GUY BERGER HARRY DUGMORE HAROLD GESS JANE DUNCAN ANTON HARBER FRANZ KRUGER WILLIAM BIRD PROJOURN STEERING COMMITTEE
43rd Respondent 44th Respondent 45th Respondent 46th Respondent 47th Respondent 48th Respondent 49th Respondent 50th Respondent 51st Respondent 52nd Respondent 53rd Respondent 54th Respondent 55th Respondent 56th Respondent 57th Respondent 58th Respondent 59th Respondent 60th Respondent 61st Respondent 62nd Respondent 63rd Respondent 64th Respondent 65th Respondent 66th Respondent 67th Respondent 68th Respondent 69th Respondent 70th Respondent 71st Respondent 72nd Respondent 73rd Respondent 74th Respondent 75th Respondent 76th Respondent 77th Respondent 78th Respondent 79th Respondent 80th Respondent 81st Respondent 82nd Respondent 83rd Respondent 84th Respondent 85th Respondent 86th Respondent 87th Respondent 88th Respondent
PROOF OF SERVICE – CONDONATION - AFFIDAVIT
I, the undersigned, LARA JOHNSTONE do hereby make oath and say: I served the Condonation Notice of Motion and Founding Affidavit (Annex. [A] and [B]) to: FIRST and SECOND RESPONDENT (SA NATIONAL EDITORS FORUM & MONDLI MAKHANYA), by personal email delivery, to their principal place of business: SA NATIONAL EDITORS FORUM, at 01:50 AM, on January 22, 2011, by emailing it to: SANEF Admin (admin@sanef.org.za), SANEF Executive Director: Ms Femida Mehtar: (director@sanef.org.za), SANEF Chair: Mr. Mondli Makhanya (makhanyam@avusa.co.za), Mr. Makhanya’s Secretary: Ms. Makhubele (makhubelem@avusa.co.za); Subject: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the first and second respondents place of business. SANEF Administrator acknowledged receipt on January 24, 2011 8:42 AM. The documents again served upon Mr. Makhanya via his secretary Ms. Makhubele, on January 27, 2011 3:55 PM. She acknowledged receipt by telephone on 27 January 2011 at 16:02 hrs. THIRD RESPONDENT (SA PRESS COUNCIL: OMBUDSMAN THLOLOE), by personal email delivery, to their principal place of business: SA PRESS COUNCIL, on January 22, 2011 1:54 AM, by emailing it to: Press Ombudsman Thloloe (Pressombudsman@ombudsman.org.za); Admin Clerk Khanyi Mndaweni (khanyim@ombudsman.org.za); Subject: CCT #06-11: Respondent: [03] Ombudsman Joe Thloloe; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the THIRD place of business. Ombudsman Joe Thloloe acknowledged receipt on behalf of Press Council Officials on January 24, 2011 10:28 AM. FOURTH RESPONDENT (SA PRESS APPEALS PANEL JUDGE RALPH ZULMAN), by personal email delivery, to his principal place of business: SA PRESS COUNCIL, on January 22, 2011 1:54 AM, by emailing it to: Judge Ralph Zulman (ralphzulman@hotmail.com); Subject: CCT #06-11: Respondent: [04] Judge Ralph Zulman; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the FOURTH respondents place of business. Ombudsman Joe Thloloe acknowledged receipt on behalf of Press Council Officials on January 24, 2011 10:28 AM. FIFTH RESPONDENT (DEPUTY PRESS OMBUDSMAN: JOHAN RETIEF), by personal email delivery, to their principal place of business: SA PRESS COUNCIL, on January 22, 2011 1:58 AM, by emailing it to: Deputy Ombudsman Johan Retief (JohanR@ombudsman.org.za); Subject: CCT #06-11: Respondent: [05] Dep. Ombudsman Johan Retief; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the FIFTH respondents place of business. Ombudsman Joe Thloloe acknowledged receipt on behalf of Press Council Officials on January 24, 2011 10:28 AM.
SIXTH and SEVENTH RESPONDENTS (SA PRESS COUNCIL (SAPA) & MARK VAN DER VELDEN), by personal email delivery, to their principal place of business: SA PRESS ASSOCIATION, on January 22, 2011 1:58 AM, by emailing it to: News room (news@sapa.org.za), Editor Mark van der Velden: (mark@sapa.org.za), Sub Editor Hannes de Wet (hannesd@sapa.org.za), CapeNews (capenews@sapa.org.za), Cape Editor Ben Maclennon (ben@sapa.org.za), Russell Norton (russell@sapa.org.za); Subject: CCT #06-11: Respondent: [06] & [07] SAPA & MARK VAN DER VELDEN; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. The SAPA Postmaster acknowledged receipt on January 22, 2011 2:06 AM. Also spoke to Mr. van der Velden by telephone on 27 January 2011, at 16:07 hrs to confirm his receipt of the documentation. EIGHTH and NINTH RESPONDENT (BUSINESS DAY & PETER BRUCE), by personal email delivery, to their principal place of business: BUSINESS DAY, on January 22, 2011 1:58 AM, by emailing it to: Editor: Peter Bruce (brucep@bdfm.co.za), News Desk: (lathamd@avusa.co.za), Editor Sam Mkokelis (mkokelis@bdfm.co.za); Subject: CCT #06-11: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Mr. Bruce was contacted by telephone on 26 January 2011 at 13:03 hrs. Mr. Bruce said he had not received the email correspondence. I emailed it to him again on January 26, 2011 1:08 PM. Mr. Bruce was again contacted by telephone at (011) 280 3091 / 280 5501, on 27 January 2011 at 11:35 hrs. I spoke to his secretary Priscilla Malinga, who agreed to accept the documentation and forward it to Mr. Bruce. TENTH and ELEVENTH RESPONDENT (BUSINESS REPORT & JABULANI SIKHAKANE), by personal email delivery, to their principal place of business: BUSINESS REPORT, on January 22, 2011 1:58 AM, by emailing it to: Business Report: (business.report@inl.co.za); Subject: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Londiwe Buthelezi acknowledged receipt on 24 January 2011 8:44 AM, and Wiseman Khuzwayo on January 24, 2011 3:13 PM. Business Report were contacted on 26 January 2011 at 13:15 hrs, where I spoke to Ms. Tracy Pillai, and then submitted the documents to Editor: Ellis Mnyandu: (ellis.mnyandu@inl.co.za), Business Report Newsroom: (Business.report@inl.co.za), Tracy Pillai: (Tracey.pillai@inl.co.za). Tracey Pillai acknowledged receipt. TWELFTH and THIRTEENTH RESPONDENT (CAPE ARGUS & CHRIS WITFIELD), by personal email delivery, to their principal place of business: CAPE ARGUS, on January 22, 2011 2:07 AM, by emailing it to: Editor: Chris Witfield (chris.whitfield@inl.co.za), Personal Secretary: Lesley Byram: (Lesley.byram@inl.co.za), Lindiz Van Zilla (lindiz.vanzilla@inl.co.za), Lyntina Aimes (lyntina.aimes@inl.co.za) , Gasant Abarder (gasant.abarder@inl.co.za), Andisiwe Makinana (andisiwe.makinana@inl.co.za), Sue Visser (sue.visser@inl.co.za); Subject: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Mr. Chris Witfields personal secretary, Ms. Lesley Byram acknowledged receipt on January 26, 2011 2:29 PM.
FOURTEENTH and FIFTEENTH RESPONDENT (CAPE TIMES & ALIDE DASNOIS), by personal email delivery, to their principal place of business: CAPE TIMES, on January 22, 2011 2:07 AM, by emailing it to: Editor: Alide Dasnois (alide.dasnois@inl.co.za), Ella Smook (ella.smook@inl.co.za), Di Caelers (di.caelers@inl.co.za), Nina Talliard (nina.talliard@inl.co.za); Subject: CCT #06-11: Respondent: [14] & [15] CAPE TIMES & A. DASNOIS; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Acting Editor: Mr. Chris Witfields personal secretary, Ms. Lesley Byram acknowledged receipt on January 26, 2011 2:29 PM. SIXTEENTH and SEVENTEENTH RESPONDENT (CITY PRESS & FERIAL HAFFAJEE), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. EIGHTEENTH and NINETEENTH RESPONDENT (THE CITIZEN & MARTIN WILLIAMS), by personal email delivery, to their principal place of business: THE CITIZEN, on January 22, 2011 2:07 AM, by emailing it to: Editor: Martin Williams (martinw@citizen.co.za), Secretary: Yvonne Le Roux (yvonnel@citizen.co.za), (citizensub@gmail.com), Puleng M (pulengm@citizen.co.za), Citizen News Bureau (news@citizen.co.za), Citizen News: (citizen@citizen.co.za); Subject: CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned THE CITIZEN on 26 January 2011 to speak to Yvonne Le Roux, Mr. Williams secretary on (011) 248 6013, at 16:05 hrs and spoke to Johanna; who said that Ms. Le Roux was checking whether she could open the attachments. I said if she had any problems to contact me. TWENTIETH RESPONDENT (DAILY DISPATCH), by personal email delivery, to their principal place of business: DAILY DISPATCH, on January 22, 2011 2:17 AM, by emailing it to: Legal Coordinator: Rochelle Bradshaw (rochelleb@dispatch.co.za), Ed. Coordinator - Samantha (news@dispatch.co.za), Investigations Editor Mr. Eddie Botha (eddieb@dispatch.co.za), Robin Ross-Thompson (robinrt@dispatch.co.za), Theodore Jephta (theodorej@dispatch.co.za), Thanduxolo Jika: (thanduxoloj@dispatch.co.za); Subject: CCT #06-11: Respondent: DAILY DISPATCH; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Daily Dispatch Editorial Coordinator Samantha acknowledged receipt by telephone on 05 January 2011, at 12:05 PM hrs. Telephoned DAILY DISPATCH at 14:45 on 26 January 2011, and spoke to Legal Coordinator: Rochelle Bradshaw, who acknowledged that DAILY DISPATCH had received the Concourt documentation. TWENTY-FIRST RESPONDENT (ANDREW TRENCH) by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation.
The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. TWENTY-SECOND and TWENTY-THIRD RESPONDENT (DAILY MAVERICK & BRKIC BRANKO), by personal email delivery, to their principal place of business: DAILY MAVERICK, on January 22, 2011 2:17 AM, by emailing it to: Editor: Brkic Branko (Branko@thedailymaverick.co.za), Deputy Editor Philip de Wet (phillip@thedailymaverick.co.za); Transparency Mandy de Waal (mandy@dailymaverick.co.za); Brendah Nyakudya (brendah@dailymaverick.co.za); Jacques Rosseau (jacques@dailymaverick.co.za); Ivo Vegter (ivo@dailymaverick.co.za); Stephen Grootes (stephen@dailymaverick.co.za); Brooks Spector (brooks@dailymaverick.com), Newsroom: (news@thedailymaverick.co.za); and on Tue 1/4/2011 3:22 PM; by emailing it to Daily Maverick News Room (news@thedailymaverick.co.za); Subject: CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Deputy Editor: Mr. Philip de Wet confirmed receipt. TWENTY-FOURTH and TWENTY-FIFTH RESPONDENT (DAILY NEWS & ALAN DUNN), by personal email delivery, to their principal place of business: DAILY NEWS, on January 22, 2011 2:17 AM, by emailing it to: Editor Alan Dunn (alan.dunn@inl.co.za), Editor Secretary Debbie Yunnie (Debbie.yunnie@inl.co.za); Subject: CCT #06-11: Respondent: [24] & [25] DAILY NEWS & A. DUNN; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Debbie Yunnie acknowledged receipt on January 24, 2011 7:49 AM. TWENTY-SIXTH and TWENTY-SEVENTH RESPONDENT (EAST COAST RADIO & DIANE MACPHERSON), by personal email delivery, to their principal place of business: EAST COAST RADIO, on January 22, 2011 3:35 AM; by emailing it to: News Editor Diane Macpherson (diane@ecr.co.za), Online Editor Charis Apelgren (charis@ecr.co.za); Subject: CCT #06-11: Respondent: [26] & [27] ECR & D. MACPHERSON; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Diane McPherson acknowledged receipt at 15:49 hrs on 26 January 2011. TWENTY-EIGHTH and TWENTY-NINTH RESPONDENT (EYEWITNESS NEWS & KATY KATAPODIS), by personal email delivery, to their principal place of business: EYEWITNESS NEWS, on January 22, 2011 2:17 AM, by emailing it to: Eyewitness News Editor Katy Katapodis (katy@702.co.za), (editor@ewn.co.za), Eyewitness News (news@ewn.co.za), Webmaster (webmaster@ewn.co.za); Subject: CCT #06-11: Respondent: [28] & [29] EYEWITNESS NEWS & K. KATAPODIS; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Katy Katapodis acknowledged receipt on January 22, 2011 7:18 AM. THIRTIETH and THIRTY-FIRST RESPONDENT (INDEPENDENT ONLINE & ADRIAN EPHRAM), by personal email delivery, to their principal place of business: IOL, on January 22, 2011 2:17 AM, by emailing it to: Editor Adrian Ephraim (adrian.ephraim@inl.co.za); Subject: CCT #0611: Respondent: [30] & 31] IOL & A. EPHRAIM; Concourt Service per Electronic Mail. The
email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Adrian Ephraim acknowledged receipt on January 22, 2011 2:22 AM. THIRTY-SECOND and THIRTY-THIRD RESPONDENT (MAIL & GUARDIAN & NIC DAWES), by personal email delivery, to their principal place of business: MAIL & GUARDIAN, on January 22, 2011 2:17 AM, by emailing it to: Editor Mathew Burbidge (mathewb@mg.co.za), Editor Keith Nichols (keithn@mg.co.za), Editor Nic Dawes (nicd@mg.co.za), News Desk (newdesk@mg.co.za), Stefaans Brummer (stefaansb@mg.co.za), Verashni Pillay (verashnip@mg.co.za); Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Nic Dawes acknowledged receipt on January 26, 2011 1:28 PM. THIRTY-FOURTH and THIRTY-FIFTH RESPONDENT (THE MERCURY & ANGELA QUINTAL), by personal email delivery, to their principal place of business: THE MERCURY, on January 22, 2011 2:30 AM, by emailing it to: Editor: Angela Quintal (angela.quintal@inl.co.za), Mercury News (mercnews@inl.co.za); Subject: CCT #06-11: Respondent: [34] & [35] THE MERCURY & A. QUINTAL; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Angela Quintal acknowledged receipt on January 22, 2011 6:33 AM. THIRTY-SIXTH and THIRTY-SEVENTH RESPONDENT (NEWS 24 & JANNIE MOMBERG), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. THIRTY-EIGHTH and THIRTY-NINTH RESPONDENT (PRETORIA NEWS & ZINGISA MKHUMA), by personal email delivery, to their principal place of business: THE PRETORIA NEWS, on January 22, 2011 2:30 AM, by emailing it to: Editor: Zingisa Mkhuma (zingisa.mkhuma@inl.co.za), Editor’s Assistant: Dianne Louw (dianne.low@inl.co.za), Graeme Hosken (graeme.hosken@inl.co.za); Subject: CCT #06-11: Respondent: [38] & [39] PRETORIA NEWS & Z. MKHUMAN; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Ms. Dianne Low acknowledged receipt. FORTIETH and FORTY-FIRST RESPONDENT (SA STAR & MOEGSIEN WILLIAMS), by personal email delivery, to their principal place of business: SA STAR, on January 22, 2011 2:30 AM, by emailing it to: Editor: Moegsien Williams (moegsien.williams@inl.co.za), Deputy Editor Jovial Rantao (jovial.rantao@inl.co.za), Admin Vidette Aslett (vidette.aslett@inl.co.za) StarNews (starnews@inl.co.za); Subject: CCT #06-11: Respondent: [40] & [50] SA STAR & M. WILLIAMS; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Ms. Vidette Aslett acknowledged receipt on January 24, 2011 8:18 AM.
FORTY-SECOND and FORTY-THIRD RESPONDENT (SUNDAY INDEPENDENT & MAKHUDU SEFARA), by personal email delivery, to their principal place of business: SUNDAY INDEPENDENT, on January 22, 2011 2:30 AM, by emailing it to: Editor: Makhudu Sefara (makhudu.sefara@inl.co.za); Editor Makhudu Sefara Secretary Jennifer Johnson (jennifer.johnson@inl.co.za), Deputy Editor Andrew Walker (andrew.walker@inl.co.za); Subject: CCT #06-11: Respondent: [42] & [43] SUN. IND. & M. SEFARA; Concourt Service per Electronic Mail. Mr. Makhudu Sefara acknowledged receipt on January 22, 2011 8:28 AM. FORTY-FOURTH and FORTY-FIFTH RESPONDENT (SUNDAY TRIBUNE & PHILANI MGWABA), by personal email delivery, to their principal place of business: SUNDAY TRIBUNE, on January 22, 2011 2:30 AM, by emailing it to: Editor: Philani Mgwaba (philani.mgwaba@inl.co.za), News Editor Liz Clarke (liz.clarke@inl.co.za), Tribune News (tribunenews@inl.co.za); Subject: CCT #06-11: Respondent: [44] & [45] SUNDAY TRIBUNE & P. MGWABA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned SUNDAY TRIBUNE: (031) 308 2771, on 27 January 2011, at 11:50 AM, and spoke to Mr. Mgwaba’s secretary: Ms. Anita Weedon (anita.weedon@inl.co.za), who agreed to receive the documents and forward them to Mr. Mgwaba. Served the documentation to Ms Weedon on January 27, 2011 11:58 AM. FORTY-SIXTH and FORTY-SEVENTH RESPONDENT (SUNDAY TIMES/TIMES LIVE & RAY HARTLEY), by personal email delivery, to their principal place of business: SUNDAY TIMES, on January 22, 2011 2:30 AM, by emailing it to: Editor: Ray Hartley (hartleyr@sundatimes.co.za), News Editor Jessica Bezuidenhout (bezuidenhoutj@sundaytimes.co.za), News Editor Heather Robertson (robertsonh@sundaytimes.co.za), Sunday Times (suntimes@sundaytimes.co.za), Justice Malala (malalaj@sundatimes.co.za), Kim Hawkeye (hawkeyk@sundaytimes.co.za); Subject: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Called SUNDAY TIMES on 27 January 2011 at 11:59 AM, and spoke to Editor, Mr. Hartley’s secretary Ms. Nonni Mokgethi, who agreed to accept the documentation for Mr. Hartley and to forward to him. Ms. Mokgeti acknowledged receipt on January 27, 2011 12:23 PM. FORTY-EIGHT and FORTY-NINTH RESPONDENT (3RD DEGREE & DEBORA PATTA), by personal email delivery, to their principal place of business: ETV: 3RD DEGREE, on January 22, 2011 2:30 AM, by emailing it to: News Room (newsroom@etv.co.za), Ms. Deborah Patta (deborap@etv.co.za), ETV (info@etv.co.za); Subject: CCT #06-11: Respondent: [48] & [49] 3RD DEGREE & D. PATTA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned ETV, on 26 January 2011, at 16:44 hrs, and spoke to CEO secretary Mr. Marcel Golding’s secretary, Ms. Jamela Chomela, and asked if I could forward documentation for the attention of Mr. Golding. Ms. Chomela acknowledged receipt on January 26, 2011 6:08 PM, for respondents: [48], [49], [57] & [58] 3RD DEGREE, D. PATTA; E-NEWS & P.CONROY. FIFTIETH and FIFTY-FIRST RESPONDENT (BEELD & TIM DU PLESSIS), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service
per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. FIFTY-SECOND and FIFTY-THIRD RESPONDENT (DAILY SUN & THEMBA KHUMALO), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. FIFTY-FOURTH, FIFTY-FIFTH and FIFTY-SIXTH RESPONDENT (DIE BURGER, HENRY JEFFEREYS & BUN BOOYSEN), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. FIFTY-SEVENTH and FIFTY-EIGHTH RESPONDENT (E-NEWS & PATRICK CONROY), by personal email delivery, to their principal place of business: E-NEWS, on January 22, 2011 2:30 AM, by emailing it to: News room: (newsroom@etv.co.za), Patrick Conroy (Patrick.Conroy@etv.co.za), Zanile Madikane (Zanele.Madikane@etv.co.za), Bongi Potelwa (bongi.potelwa@etv.co.za), Gill Scholtz (Gill.Scholtz@etv.co.za); Subject: CCT #06-11: Respondent: [57] & [58] E-NEWS & P. CONROY; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned ETV, on 26 January 2011, at 16:44 hrs, and spoke to CEO secretary Mr. Marcel Golding’s secretary, Ms. Jamela Chomela, and asked if I could forward documentation for the attention of Mr. Golding. Ms. Chomela acknowledged receipt on January 26, 2011 6:08 PM, for respondents: [48], [49], [57] & [58] 3RD DEGREE, D. PATTA; E-NEWS & P.CONROY. FIFTY-NINTH and SIXTIETH RESPONDENT (FINANCIAL MAIL & BARNEY MTHOMBOTHI), by personal email delivery, to their principal place of business: FINANCIAL MAIL, on January 22, 2011 2:30 AM, by emailing it to: Barney Mthombothi (mthombothib@fm.co.za), David Furlonger (furlongerd@fm.co.za), Financial Mail (fmmail@fm.co.za), FM Mad Focus (fmadfocus@fm.co.za), Rob Rose (RoseR@fm.co.za), Onica Buthelezi (buthelezio@fm.co.za), Financial Mail (fmdidu@fm.co.za); Subject: CCT #06-11: Respondent: [59] & [60] FIN. MAIL & B. MTHOMBOTHI; Concourt Service per Electronic Mail. Mr. Mthombothi acknowledged receipt on January 24, 2011 10:14 AM. SIXTY-FIRST and SIXTY-SECOND RESPONDENT (FINWEEK & COLLEEN NAUDE), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel.
SIXTY-THIRD and SIXTY-FOURTH RESPONDENT (THE GEORGE HERALD & MANDI BOTHA), by personal email delivery, to their principal place of business: GROUP EDITORS, on January 22, 2011 2:30 AM, by emailing it to: Mandi Both (mandi@groupeditors.co.za), George News (grjnews@ctp-mail.co.za), Pauline Lourens (paulinel@groupeditors.co.za), Lindie Joubert (lindie@groupeditors.co.za), Shirley Coetzee (shirley@groupeditors.co.za), Lo-An Nel Breytenbach (loannel@groupeditors.co.za), Suzette Herrer (mba@groupeditors.co.za), Lucinda Viljoen (lucinda@ctp-mail.co.za), Melissa Hulls (melissa@groupeditors.co.za), Lizette da Silva (lizette@groupeditors.co.za), Michelle Pienaar (michelle@groupeditors.co.za), Ilse Schoonraad (ilse@groupeditors.co.za), Jannie Meyer (jannie@groupeditors.co.za), Anica Kruger (anica@groupeditors.co.za), Yvonne Botha (yvonne@groupeditors.co.za); Subject: CCT #06-11: Respondent: [63] & [64] GEORGE HERALD & M. BOTHA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. A follow up was sent on January 26, 2011 8:50 PM. Ms. Botha acknowledged receipt on January 27, 2011 12:30 PM. SIXTY-FIFTH and SIXTY-SIXTH RESPONDENT (INDEPENDENT ON SATURDAY & TREVOR BRUCE), by personal email delivery, to their principal place of business: INDEPENDENT ON SATURDAY, on January 22, 2011 2:30 AM, by emailing it to: Trevor Bruce (trevor.bruce@inl.co.za), Luvoyo Mjekula (luvuyo.mjekula@inl.co.za), Philani Mgwaba (philani.mgwaba@inl.co.za), Quinton Mtyala (quinton.mtyala@inl.co.za) , Greg Arde (greg.arde@inl.co.za); Subject: CCT #06-11: Respondent: [65] & [66] IND. ON SAT. & TREVOR BRUCE; Concourt Service per Electronic Mail. Telephoned Ind. On Saturday on 27 January 2011 at 12:52 hrs and was informed that Mr. Bruce’s secretary was Ms. Debbie Yunnie. Served the documentation on Ms. Yunnie for delivery to Mr. Bruce. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. SIXTY-SEVENTH and SIXTY-EIGHTH RESPONDENT (RADIO 702 & PHELADI GWANGWA), by personal email delivery, to their principal place of business: RADIO 702, on January 22, 2011 2:54 AM, by emailing it to: Pheladi Gwangwa (pheladi@702.co.za), (pheladi@primedia.co.za), News (news@702.co.za), 702 Eyewitness News (news@ewn.co.za), Bruce Whitfield (brucew@702.co.za), Kieno Kammies (kieno@702.co.za), Robin Clark (robin@capetalk.co.za), John Robbie (johnr@702.co.za), Lynne O’Connor (lynne@702.co.za), David O’Sullivan (david@702.co.za); Subject: CCT #06-11: Respondent: [67] & [68] RADIO 702 & P. GWANGWA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Pheladi Gwangwa acknowledged receipt on January 24, 2011 10:25 PM. SIXTY-NINTH and SEVENTIETH RESPONDENT (RAPPORT & LISA ALBRECHT), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. SEVENTY-FIRST and SEVENTY-SECOND RESPONDENT (SATURDAY STAR & BRENDAN SEERY), by personal email delivery, to their principal place of business: SATURDAY STAR, on January
22, 2011 2:54 AM, by emailing it to: Star News (starnews@inl.co.za), Brendan Seery (brendan.seery@inl.co.za), Thandi Mabuza (Thandi.Mabuza@inl.co.za), Anel Lewis (anel.lewis@inl.co.za), Quinton Mtyala (Quinton.mtyala@inl.co.za), Mthunzi Mbatha (mthunzi.mbatha@inl.co.za); Subject: CCT #06-11: Respondent: [71] & [72] SAT. STAR & B. SEERY; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned SA STAR (011-633 2792) on 27 June 2011 at 13:04 hrs and repeatedly the phone was picked up and immediately disconnected. I called again at 14:38 hours and spoke to Mr. Seery, to enquire whether he would confirm having received the documentation for his attention. His response was “I am not interested in talking to you,” whereupon he put down the phone. SEVENTY-THIRD and SEVENTY-FOURTH RESPONDENT (SOWETAN & BONGANI KESWA), by personal email delivery, to their principal place of business: SOWETAN, on January 22, 2011 2:54 AM, by emailing it to: Bongani Keswa (keswab@sowetan.co.za), Editor – Sowetan (editor@sowetan.co.za), Lorraine Mofokeng (lorrainem@sowetan.co.za), Thuli Zungu (zungut@sowetan.co.za), Edward Tsumele (Tsumelee@sowetan.co.za); Subject: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Subsequently served upon Mr. Keswa’s secretary, Ms. Loretta Ndlovu, who acknowledged receipt on January 27, 2011 3:37 PM. SEVENTY-FIFTH and SEVENTY-SIXTH RESPONDENT (THE HERALD & JEREMY MCCABE), by personal email delivery, to their principal place of business: THE HERALD, on January 22, 2011 2:54 AM, by emailing it to: Editor: Heather Robertson (robertsonh@avusa.co.za), Jeremy McCabe (McCabej@avusa.co.za), The Herald (theherald@avusa.co.za), L Makungan (makungan@avusa.co.za), Avusa (care@avusa.co.za), Estelle Kerrane (kerranee@avusa.co.za), Circulation Manager (circmanager@avusa.co.za), Avusa Group Secretary Joanne Matisonn (matisonnj@avusa.co.za); Subject: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail. Heather Robertson acknowledged receipt on January 27, 2011 12:15 AM. SEVENTY-SEVENTH and SEVENTY-EIGHTH RESPONDENT (VOLKSBLAD & AINSLEY MOOS), by personal email delivery, to the principal place of business of their legal representative: Willem de Klerk Attorneys, on January 22, 2011 2:07 AM, by emailing it to: Attorney Willem de Klerk (wdeklerk@telkomsa.net); Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation. The email addresses to which I delivered the documents are the correct email addresses for the respondents legal counsel. SEVENTY-NINTH RESPONDENT (ROD AMNER), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Email: Rod Amner (r.amner@ru.ac.za), Wits Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za), Prof. Anthea Garman (a.garman@ru.ac.za), Nicky Cocroft (n.cockcroft@ru.ac.za), Simon Pamphilon (s.pamphilon@ru.ac.za), Simwogerere Kyazze (s.kyazze@ru.ac.za); Subject: CCT #06-11: Respondent: [79] PROF. ROD AMNER, RHODES JOURNALISM; Concourt Service per Electronic Mail. Mr. Amner acknowledged receipted on January 22, 2011 2:36 PM.
EIGHTIETH RESPONDENT (ROBERT BRAND), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Robert Brand (r.brand@ru.ac.za), Rhodes Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za), Prof. Herman Wasserman (h.wasserman@ru.ac.za), Prof. Jeanne Prinsloo (j.prinsloo@ru.ac.za), Prof. Larry Strelitz (l.strelitz@ru.ac.za); Subject: CCT #06-11: Respondent: [80] PROF. ROBET BRAND, RHODES JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. A follow up request was sent to (i) Dr. Stephen Fourie, Registrar of Rhodes University (registrar@ru.ac.za): Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation, on January 26, 2011 9:39 PM; and to Mr. Ashley Stander, Media Liaison Officer, Rhodes Univ., who acknowledged receipt on January 27, 2011 3:15 PM. EIGHTY-FIRST RESPONDENT (GUY BERGER), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Email: Guy Berger (g.berger@ru.ac.za), Rhodes Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za), Dr. Lynette Steenveld (l.steenveld@ru.ac.za), Reg Rumney (r.rumney@ru.ac.za); Subject: CCT #06-11: Respondent: [81] GUY BERGER, RHODES JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. A follow up request was sent to (i) Dr. Stephen Fourie, Registrar of Rhodes University (registrar@ru.ac.za): Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation, on January 26, 2011 9:39 PM; and to Mr. Ashley Stander, Media Liaison Officer, Rhodes Univ., who acknowledged receipt on January 27, 2011 3:15 PM. EIGHTY-SECOND RESPONDENT (HARRY DUGMORE), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Harry Dugmore (h.dugmore@ru.ac.za), Rhodes Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za); Jude Mathurine (j.mathurine@ru.ac.za), Khaya Thonjeni (k.thonjeni@ru.ac.za); Subject: CCT #06-11: Respondent: [82] PROF. HARRY DUGMORE, RHODES JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. A follow up request was sent to (i) Dr. Stephen Fourie, Registrar of Rhodes University (registrar@ru.ac.za): Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation, on January 26, 2011 9:39 PM; and to Mr. Ashley Stander, Media Liaison Officer, Rhodes Univ., who acknowledged receipt on January 27, 2011 3:15 PM. EIGHTY-THIRD RESPONDENT (HAROLD GESS), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Harold Gess (h.gess@ru.ac.za) , Rhodes Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za), Jenny Gordon (j.gordon@ru.ac.za), Paul Greenway (p.greenway@ru.ac.za); Subject: CCT #06-11: Respondent: [83] HAROLD GESS, RHODES JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I
delivered the documents are the correct email addresses for the respondents place of business. A follow up request was sent to (i) Dr. Stephen Fourie, Registrar of Rhodes University (registrar@ru.ac.za): Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation, on January 26, 2011 9:39 PM; and to Mr. Ashley Stander, Media Liaison Officer, Rhodes Univ., who acknowledged receipt on January 27, 2011 3:15 PM. EIGHTY-FOURTH RESPONDENT (JANE DUNCAN), by personal email delivery, to their principal place of business: Rhodes School of Journalism and Media Studies, on January 22, 2011 2:54 AM, by emailing it to: Jane Duncan (jane.duncan@ru.ac.za), Wits Journalism (journqueries@ru.ac.za), (registrar@ru.ac.za), Chris Kabwato (c.kabwato@ru.ac.za), Nqobile Buthelezi (n.buthelezi@ru.ac.za), Sibusiso Mtshali (s.mtshali@ru.ac.za); Subject: CCT #0611: Respondent: [84] PROF. JANE DUNCAN, RHODES JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. A follow up request was sent to (i) Dr. Stephen Fourie, Registrar of Rhodes University (registrar@ru.ac.za): Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation, on January 26, 2011 9:39 PM; and to Mr. Ashley Stander, Media Liaison Officer, Rhodes Univ., who acknowledged receipt on January 27, 2011 3:15 PM. EIGHTY-FIFTH RESPONDENT (ANTON HARBER), by personal email delivery, to their principal place of business: Wits Journalism, on January 22, 2011 2:54 AM, by emailing it to: Anton Harber (anton@harber.co.za), Big Media Sally (sallyannn@bigmedia.co.za), Wits Journalism ((editor@journalism.co.za), (journinfo@wits.ac.za); Subject: CCT #06-11: Respondent: [85] PROF. ANTON HARBER, WITS JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Anton Harber acknowledged receipt on January 22, 2011 8:27 AM. EIGHT-SIXTH RESPONDENT (FRANZ KRUGER), by personal email delivery, to their principal place of business: Wits Journalism, at 01:18 AM hrs, on January 22, 2011 2:54 AM, by emailing it to: Franz Kruger (franz.kruger@wits.ac.za), (editor@journalism.co.za), (journinfo@wits.ac.za); Subject: CCT #06-11: Respondent: [86] PROF. FRANZ KRUGER, WITS JOURNALISM; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business. Telephoned Pholiswa Maseko, at the Wits Journalism Department (Tel: (011) 717 4028), on 27 January 2011 at 15:07 hrs, who confirmed receipt of documentation. EIGHTY-SEVENTH RESPONDENT (WILLIAM BIRD), by personal email delivery, to their principal place of business: MEDIA MONITORING AFRICA, on January 22, 2011 2:54 AM, by emailing it to: William Bird (williamb@mma.org.za), (info@mma.org.za); Subject: CCT #0611: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail. It was followed up with a reminder on January 26, 2011 9:48 PM; a telephone call on 27 January 2011 to Mr. Ayabulela Royo and another email reminder on January 27, 2011 3:17 PM, who acknowledged receipt on 27 January 2011. The email addresses to which I delivered the documents are the correct email addresses for the respondents place of business.
EIGHTY-EIGHTH RESPONDENT (PROJOURN STEERING COMMITTEE), by personal email delivery, to their principal place of business: PROJOURN STEERING COMMITTEE & INST. FOR ADVANCEMENT OF JOURNALISM, on January 22, 2011 2:54 AM, by emailing it to: Steering Committee General Secretary: Samantha Perry (samantha.perry@gmail.com); Michael Schmidt, Steering Committee Admin Secretary (mschmidt@frayintermedia.com), (info@iaj.org.za); Beauregard Tromp (tromp@inl.co.za); Michael Coetzee (cicero@wbs.co.za); Greg Gordon (gregg@is.co.za); Ray Joseph (rayjoe@iafrica.com); Monica Laganparsad (laganparsadm@sundaytimes.co.za); Ebrahim Moolla (ebrahim@fhm.co.za); Sholain Govender-Bateman (sholain@webmail.co.za); Antoinette Lazarus (lazarusal@sabc.co.za); Mandy de Waal (mandyd@mweb.co.za); Jan Hennop (JanH@dispatch.co.za); Cobus Bester (besterc@sabc.co.za); Subry Govender (ptsa@global.co.za); Justin Arenstein (editor@africanpress.com); Jedi Ramalapa (jedi.ramalapa@gmail.com); Anso Thom (anso@health-e.org.za); Billings Siwila (billingsmovies@gmail.com); Subject: CCT #06-11: Respondent: [88] PROJOURN STEERING COMM.; Concourt Service per Electronic Mail. The email addresses to which I delivered the documents are the correct email addresses for the relevant respondents, as detailed on the Projourn Steering Committee webpage. Monica Laganparsad acknowledged receipt on January 22, 2011 9:21 AM; and Ebrahim Moolla on January 22, 2011 7:34 PM.
_____________________________________________ SWORN UNDER OATH BY: LARA JOHNSTONE MEMBER: RADICAL HONESTY CULTURE & RELIGION 27 JANUARY 2011 AT 23:32 HRS