11-01-28: Condonation: Proof of Service Evidentiary Emails by Andrea Muhrrteyn

ANNEXURE A: PROOF OF SERVICE TO RESPONDENTS # 001-088: RADICAL HONESTY CONCOURT APPLICATION FOR CONDONATION; RE: WRIT OF HABEUS MENTEM AND CERTIORARI/REVIEW: TABLE OF CONTENTS: 1-2

SANEF & M. MAKHANYA

63-64

GEORGE HERALD & MANDI BOTHA

OMBUDSMAN JOE THLOLOE

65-66

IND. ON SAT & TREVOR BRUCE

JUDGE RALPH ZULMAN

67-68

702 RADIO & P. GWANGWA

OMBUDSMAN JOHAN RETIEF

71-72

SAT. STAR & BRENDAN SEERY

6-7

SAPA & M. VAN DER VELDEN

73-74

SOWETAN & BONGANI KESWA

8-9

BUSINESS DAY & PETER BRUCE

75-76

THE HERALD & JEREMY MCCABE

10-11

BUSINESS REPORT & J SIKHAKHANE

ROD AMNER

12-13

CAPE ARGUS & CHRIS WITFIELD

ROBERT BRAND

14-15

CAPE TIMES & ALIDE DASNOIS

GUY BERGER

18-19

CITIZEN & MARTIN WILLIAMS

HARRY DUGMORE

DAILY DISPATCH

HAROLD GESS

22-23

DAILY MAVERICK & BRKIC BRANKO

JANE DUNCAN

24-25

DAILY NEWS & ALAN DUNN

ANTON HARBER

26-27

ECR & DIANE MACPHERSON

FRANZ KRUGER

28-29

EYEWITNESS NEWS & K. KATAPODIS

WILLIAM BIRD

30-31

IOL & ADRIAN EPHRAM

PROJOURN STEERING COMMITTEE

32-33

M&G & NIC DAWES

34-35

MERCURY & A. QUINTAL

38-39

PRETORIA NEWS & Z MKHUMA

40-41

SA STAR & M. WILLIAMS

36-37

NEWS 24 & JANNIE MOMBERG

42-43

SUN. IND. & MAKHUDU SEFARA

50-51

BEELD & TIM DU PLESSIS

44-45

SUNDAY TRIBUNE & P. MGWABA

52-53

DAILY SUN & T. KHUMALO

46-47

SUN TIMES & RAY HARTLEY

54-56

DIE BURGER, H. JEFFERY & B. BOOYSEN

61-62

FINWEEK & COLLEEN NAUDE

DEGREE & DEBORA PATTA

MEDIA 24 RESPONDENTS: 16-17 21

CITY PRESS & F. HAFFAJEE ANDREW TRENCH

48-49

57-58

E-NEWS & P. CONROY

69-70

RAPPORT & LISA ALBRECHT

59-60

FINANCIAL MAIL & B. MTHOMBOTHI

77-78

VOLKSBLAD & AINSLEY MOOS

001 & 002: SANEF & MONDLI MAKHANYA From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:50 AM To: 'SANEF Admin'; 'SANEF Executive Director: Ms Femida Mehtar:'; 'SANEF Chair: Mr. Mondli Makhanya'; 'Ms. Makhubele' Subject: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SA NATIONAL EDITORS FORUM (SANEF) MR. MONDLI MAKHANYA (First & Second Respondents) Mr. Mondli Makhanya, Chairman South African National Editors Forum (SANEF) 2nd Floor, 7 St David’s Office Park St David’s Place, Parktown Tel 011 484 3630 / 3617 | Fax 011 484 3593

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY – SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application to Proceed dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully,

LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: SANEF Administrator [mailto:admin@sanef.org.za] Sent: Monday, January 24, 2011 8:42 AM To: 'Lara Johnstone' Subject: Read: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail Importance: High Your message To: 'SANEF Admin'; 'SANEF Executive Director: Ms Femida Mehtar:'; 'SANEF Chair: Mr. Mondli Makhanya'; 'Ms. Makhubele' Subject: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail Sent: 1/22/2011 1:50 AM was read on 1/24/2011 8:42 AM.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 3:55 PM To: 'Mr. Makhanya Secretary: Ms. Makhubele' Subject: Mr. M. Makhanya, c/o Ms. Makhubele, RE: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail Importance: High Mr. Makhanya, c/o Ms. Makhubele Ms. Makhubele, SANEF have acknowledged receipt of the attached Constitutional Court documentation for the attention of SANEF and Mr. Mondli Makhanya, however please make sure that Mr. Makhanya is informed of the attached Constitutional Court documentation. If either SANEF or Mr. Makhanya have any objections to the orders requested, they must file their objections as per the documentation. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954

Email: jmcswan@mweb.co.za

Telephoned Ms. Makhubele on 27 January 2011 at 16:03 hrs, and she acknowledged receipt of email.

From: Mantombi Makhubele [mailto:MakhubeleM@avusa.co.za] Sent: Thursday, January 27, 2011 4:02 PM To: Lara Johnstone Subject: Read: Mr. M. Makhanya, c/o Ms. Makhubele, RE: CCT #06-11: Respondent: [01] & [02] SANEF & M. MAKHANYA; Concourt Service per Electronic Mail Importance: High Your message was read on Thursday, January 27, 2011 4:02:11 PM (GMT+02:00) Harare, Pretoria.

003: JOE THLOLOE, PRESS OMBUDSMAN From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:54 AM To: 'Press Ombudsman Thloloe'; 'Khanyi Mndaweni' Subject: CCT #06-11: Respondent: [03] Ombudsman Joe Thloloe; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: Ombudsman Joe Thloloe SA PRESS COUNCIL 2nd Floor, 7 St. Davids's Park St Davids Place, Parktown, 2193 Tel: (011) 484 3612/8 | Fx: (011) 484 3619 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of

Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application to Proceed dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Pressombudsman [mailto:pressombudsman@ombudsman.org.za] Sent: Monday, January 24, 2011 10:28 AM To: Lara Johnstone; Khanyi Mndaweni Cc: Raymond Louw; ralphzulman@hotmail.com; Johan Retief Subject: RE: CCT #06-11: Respondent: [03] Ombudsman Joe Thloloe; Concourt Service per Electronic Mail Dear Ms Johnstone, As communicated to you before the Press Council, the Ombudsman, the Deputy Ombudsman and the chairperson of the Press Appeals Panel, Judge Ralph Zulman, abide by the decision of the Honourable Court. Regards, Joe Thloloe

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Monday, January 24, 2011 12:00 PM To: 'Pressombudsman'; 'Khanyi Mndaweni' Cc: 'Raymond Louw'; 'ralphzulman@hotmail.com'; 'Johan Retief' Subject: RE: CCT #06-11: Respondent: [03] Ombudsman Joe Thloloe; Concourt Service per Electronic Mail

Thank you Mr. Thloloe, Thank you for acknowledging receipt of the Condonation documentation submitted to your offices. Shall I interpret this as your 'notice to abide'? If so, have you informed the court registrar of your notice to abide? Would it be correct for me to interpret that you are not appointing counsel, and that I should submit any further documentation in these proceedings directly to yourself, Mr. Retief and Judge Zulman, for your responses? I have no objections thereto.. I am simply wanting to make clear that I understand you correctly, and we are on the same page. Respectfully,

Lara Johnstone

004: JUDGE RALPH ZULMAN, PRESS APPEALS PANEL From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:54 AM To: 'Judge Ralph Zulman' Subject: CCT #06-11: Respondent: [04] Judge Ralph Zulman; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

SA PRESS APPEALS PANEL JUDGE RALPH ZULMAN Fourth Respondent Judge Ralph Zulman SA PRESS APPEALS PANNEL 2nd Floor, 7 St. Davids's Park St Davids Place, Parktown, 2193 Tel: (011) 484 3612/8 | Fx: (011) 484 3619

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Monday, January 24, 2011 12:00 PM To: 'Pressombudsman'; 'Khanyi Mndaweni' Cc: 'Raymond Louw'; 'ralphzulman@hotmail.com'; 'Johan Retief'

Subject: RE: CCT #06-11: Respondent: [03] Ombudsman Joe Thloloe; Concourt Service per Electronic Mail Thank you Mr. Thloloe, Thank you for acknowledging receipt of the Condonation documentation submitted to your offices. Shall I interpret this as your 'notice to abide'? If so, have you informed the court registrar of your notice to abide? Would it be correct for me to interpret that you are not appointing counsel, and that I should submit any further documentation in these proceedings directly to yourself, Mr. Retief and Judge Zulman, for your responses? I have no objections thereto.. I am simply wanting to make clear that I understand you correctly, and we are on the same page. Respectfully,

Lara Johnstone

005: JOHAN RETIEF, DEP. PRESS OMBUDSMAN From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:58 AM To: 'Deputy Ombudsman Johan Retief' Subject: CCT #06-11: Respondent: [05] Dep. Ombudsman Johan Retief; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

SA PRESS COUNCIL: DEPUTY OMBUDSMAN RETIEF Fifth Respondent Deputy Ombudsman Johan Retief SA PRESS COUNCIL 2nd Floor, 7 St. Davids's Park St Davids Place, Parktown, 2193 Tel: (011) 484 3612/8 | Fx: (011) 484 3619

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Monday, January 24, 2011 12:00 PM To: 'Pressombudsman'; 'Khanyi Mndaweni' Cc: 'Raymond Louw'; 'ralphzulman@hotmail.com'; 'Johan Retief'

006 & 007: SAPA & MARK VAN DER VELDEN From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:58 AM To: 'News room'; 'Editor Mark van der Velden:'; 'Sub Editor Hannes de Wet'; 'CapeNews'; 'Cape Editor Ben Maclennon'; 'Russell Norton' Subject: CCT #06-11: Respondent: [06] & [07] SAPA & MARK VAN DER VELDEN; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SA PRESS ASSOCIATION (SAPA) MARK VAN DER VELDEN Sixth and Seventh Respondents Mark van der Velden, Editor SA Press Association (SAPA) P O Box 7766, Johannesburg, 2000 South Africa Tel: (011) 782 1600 | Fx: (011) 782 1587

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Mail Delivery System [mailto:postmaster@sapa.org.za] Sent: Saturday, January 22, 2011 2:06 AM To: jmcswan@mweb.co.za Subject: Delivery Confirmation With reference to your message with the subject: "CCT #06-11: Respondent: [06] & [07] SAPA & MARK VAN DER VELDEN; Concourt Service per Electronic Mail" Your message was successfully delivered to the following addresses: <ben@sapa.org.za> <capenews@sapa.org.za> <hannesd@sapa.org.za> <mark@sapa.org.za> <news@sapa.org.za> <russell@sapa.org.za>

From: jenni@sapa.org.za [mailto:jenni@sapa.org.za] Sent: Tuesday, January 25, 2011 11:32 AM To: jmcswan@mweb.co.za Subject: Questions from Sapa

Hello Lara, I'm a reporter from Sapa and I've been asked to write on your filing of papers to the Constitutional Court regarding a complaint against 88 respondents in the media. I have a copy of your founding affidavit, which I have read. I was wondering if you could please just help me with something. What is your plea to the court, besides condonation? In other words, what is it that you want the court to order? And, what is the Constitutional principle that your argument is based on? In other words, which section/s of the Constitution will you be relying on if you are granted access. Thank you, Kind regards, Jenni O'Grady Journalist SA Press Association 011-782-1600

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Tuesday, January 25, 2011 11:48 AM To: 'jenni@sapa.org.za' Subject: RE: Questions from Sapa Hi Jenni, Perhaps it might be helpful if you have all the documentation first. It appears from your email, as if you only have the Condonation Application documentation. The Condonation application is an additional application, it is NOT the main application. The main application is the Notice of Motion for Direct Access, which asks the courts for its various orders. The Notice of Motion informs you of the writs/orders I am requesting from the court: 1. A writ for Habeus Mentem, based on cultural law and the right to psychological integrity (details in the writ) 2. A writ for Review (Certiorari), this is to review the Ombudsmanâ&#x20AC;&#x2122;s decisions regarding various complaints filed with the Press Ombudsman. A review asks the court to investigate whether the Ombudsman gave a fair and impartial hearing, in consideration of the merits of the case. I attach the original Application for Direct Access, as well as its founding affidavit, for you. Once you have had a browse through themâ&#x20AC;Ś if you have any questions, please feel free to let me know and I shall answer them as simply as I can, for you. Two articles I have written, explaining the matter in more simple language, you can find at:

Concourt to review SANEF censorship of TRC Fraud & Ecolaw Media Corruption http://why-we-are-white-refugees.blogspot.com/2011/01/cct-06-11-concourt-toreview-sanef.html Peak Oil & Ecological Overshoot raised in SA Constitutional Court Media Corruption case http://beforeitsnews.com/story/371/196/Peak_Oil_Ecological_Overshoot_raised_i n_SA_Constitutional_Court_Media_Corruption_case.html Hope that helps to get your started. Regards, Lara

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Tuesday, January 25, 2011 11:55 AM To: 'jenni@sapa.org.za' Subject: RE: Questions from Sapa: very brief overview Very brief overview:

CCT # 06-11: Concourt to review SANEF censorship of TRC Fraud & Ecolaw Media Corruption Constitutional Court, Johannesburg (21-Jan-2011): On 19 January 2011 the Concourt Registrar Mr. Delano Louw issued the Concourt Reference Number CCT 06-11, in the matter of Radical Honesty SA and others vs. SANEF and others. The Concourt had been submitted with Proof of Service documentation proving that Radical Honesty SA had provided all the respondents with their Notice of Motion and Founding Affidavit documentation. The Applicants in the matter are Lara Johnstone and Radical Honesty SA, who filed an Application with the Constitutional Court for direct access, as a Pauperis Propria Persona / Litigant in Person; for a [I] writ of Habeus Mentem and [II] writ of Certiorari/Review. The Application was filed against 88 respondents: (a) three administrators of the SA Press Council; (v) SANEF and its chairman: Mr. Makhanya, (c) 36 SANEF and related media publications and their respective editors, managerial officials; (d) eight Media Professors from Univ. of Rhodes and Wits Journalism faculty departments; (e) Media Monitoring Africa: Mr. William Bird; and finally (f) Projourn Steering Committee.

CCT 23-10 RADICAL HONESTY AMICUS CURIAE: Radical Honesty SA Population Policy Common Sense TRC Fraud Amicus Curiae The complainants were originally approved to file an Amicus Curiae in the Constitutional matter of The Citizen v. Robert McBride (CCT 23-10), where they argued in support of a Population Policy Common Sense Interpretation of the Promotion of National Unity and Reconciliation (TRC) Act. Essentially Radical Honesty SA argued that the Truth and Reconciliation Commission had committed fraud, because among others it failed to address the population growth factors which contributed both to the establishment of

Apartheid (whites fear of the 'swart gevaar'/black peril), as well as to much of its racial resource war violence (a consequence of the ANC's 'breeding war' policies, resulting in huge demographic youth bulges). Radical Honesty SA's Ecolaw TRC Fraud arguments were founded on what it refers to as its Population Policy Common Sense Ecolaw principle: "any legislation or jurisprudence such as the TRC Social Contract, which professes to advocate on behalf of human rights, peace and social justice, while ignoring their ecological basis – a stable human population at slightly less than the eco-systems carrying capacity – is endorsing and practicing legal dishonesty and hypocrisy; i.e. fraud. It is legislation and jurisprudence deliberately indifferent to the laws of sustainability, advocating misery." The Radical Honesty SA Amicus was supported by the expert witness statements of (i) Dr. T. Michael Maher, author of the study: How and Why Journalists Avoid Population – Environment connection; and (ii) Dr. Brad Blanton, founder of the Radical Honesty movement, former candidate for Congress in Virginia in 2004 and 2006 and author of the Radical Honesty series of books. The South African media totally censored the argument in the Radical Honesty SA Amicus Curiae, in all its news reports, about the Citizen/McBride case before the Constitutional Court. Radical Honesty SA filed complaints to the Press Council Ombudsman against all the publications, all the way up to the Press Appeals Panel; all of whom endorsed the media's censorship of the Radical Honesty SA Amicus, and its arguments from the South African people's right to know. Radical Honesty SA then filed an application for direct access to the Constitutional Court to review the rulings of the Press Council's decisions, which endorsed the media's censorship of the Amicus and its Population Policy Common Sense arguments. Radical Honesty SA allege the media's Cover-up and Censorship of Ecological Overshoot is and will Encourage Instability & Anarchy.

------------- quote --------------If the State of the System is ‘Brink of Ecological Overshoot into Anarchy and Collapse’; and the media’s ‘act’ is (a) censorship of root cause problem solving, while (b) encouraging the factors (population growth, resource consumption) towards Anarchy and Collapse; then the conclusion is that the Media’s Actions are deliberate and intentional on behalf of Anarchy and Instability. Where is Society in the Act of Understanding Exponential Population Growth colliding with Exponentially Declining Resources? What is the role of the Media in Society’s Ignorance? What is the role of the media in deliberately keeping Society Ignorant, by means of Environment Population Connection censorship? Where is Ecological Societal System, in terms of Exponential Population Growth colliding with Exponentially Declining Resources? Is the Media Aggravating Instability by encouraging Population Growth and Increased Resource Consumption? Is the Media Encouraging Stability in favour of Population Stabilisation & Reduced Resource Exploitation? --------- end quote ------------

From: jenni@sapa.org.za [mailto:jenni@sapa.org.za] Sent: Tuesday, January 25, 2011 1:23 PM

To: Lara Johnstone Subject: Re: Questions from Sapa: very brief overview Hi Lara, Thank you for the additional documentation. Could you please point me to the pages where the sections of the Constitution you base your argument on can be found as I can't seem to locate them myself. Thank you, Kind regards, Jenni O'Grady Journalist SA Press Association 011-782-1600

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Tuesday, January 25, 2011 2:27 PM To: 'jenni@sapa.org.za' Subject: RE: Questions from Sapa: very brief overview Hi Jenny, Hope this helps. I have separated between the two writs: WRIT/ORDER OF HABEUS MENTEM: CULTURAL LAW & PSYCHOLOGICAL INTEGRITY The Writ of Habeus Mentem is invoked in accordance with the constitutional right to invoking cultural law, in S. 15(3), 30, 31 and 185, and Psychological Integrity in Section 12.

15. Freedom of religion, belief and opinion (1) Everyone has the right to freedom of conscience, religion, thought, belief and opinion. (3) This section does not prevent legislation recognising (a) marriages concluded under any tradition, or a system of religious, personal or family law; or (b) systems of personal and family law under any tradition, or adhered to by persons professing a particular religion. 30. Language and culture Everyone has the right to use the language and to participate in the cultural life of their choice, but no one exercising these rights may do so in a manner inconsistent with any provision of the Bill of Rights. 31. Cultural, religious and linguistic communities (1) Persons belonging to a cultural, religious or linguistic community may not be denied the right, with other members of that community a. to enjoy their culture, practise their religion and use their language; and

b. to form, join and maintain cultural, religious and linguistic associations and other organs of civil society. Commission for the Promotion and Protection of the Rights of Cultural, Religious and Linguistic Communities 185. Functions of Commission 1. The primary objects of the Commission for the Promotion and Protection of the Rights of Cultural, Religious and Linguistic Communities are a. to promote respect for the rights of cultural, religious and linguistic communities; b. to promote and develop peace, friendship, humanity, tolerance and national unity among cultural, religious and linguistic communities, on the basis of equality, non-discrimination and free association; and c. to recommend the establishment or recognition, in accordance with national legislation, of a cultural or other council or councils for a community or communities in South Africa. 2. The Commission has the power, as regulated by national legislation, necessary to achieve its primary objects, including the power to monitor, investigate, research, educate, lobby, advise and report on issues concerning the rights of cultural, religious and linguistic communities. 3. The Commission may report any matter which falls within its powers and functions to the South African Human Rights Commission for investigation. 4. The Commission has the additional powers and functions prescribed by national legislation. 12. Freedom and security of the person 1. Everyone has the right to bodily and psychological integrity, which includes the right a. to make decisions concerning reproduction; b. to security in and control over their body; and c. not to be subjected to medical or scientific experiments without their informed consent. When any citizen invokes cultural law, then the court has to apply a principle known as ‘choice of law’ rules. This happens when there are ‘conflicts of laws’. You belong to one culture, and I to another, and our cultures have different laws or cultural values, so it is a ‘conflict of laws’. Remember the case in KZN, where the Zulu’s argued that killing the bull with their bare hands was their culture? They then brought in cultural experts who said it was their culture to do that, and the court considered the matter within their cultural laws.

Other Stare Decisis decisions and law reports on Cultural Law Issues [b] Ex parte Minister of Native Affairs: In re Yako v Beyi 1948 (1) SA 388 (A) at 397: Appellate Division held that neither common nor customary law was prima facie applicable. Courts had to consider all the circumstances of a case, and, without any preconceived view about the applicability of one or other legal system, select the appropriate law on the basis of its inquiry. [c] SALC, Sept 1999: Report on Conflicts of law: P.22: ‘1.58. The Constitution now provides an entitlement for invoking customary law in legal suits. Because ss 30 and 31 specifically guarantee an individual and a group's right to pursue a culture of choice, it could be argued that

application of customary law has become a constitutional right. Previously, the state had assumed complete discretion in deciding whether and to what extent customary law should be recognized, an attitude typical of colonial thinking, for Africans were subject to whatever policies the conquering state chose to impose on them. Now, however, the state has a duty to allow people to participate in the culture they choose, implicit in this duty is a responsibility to uphold the institutions on which that culture is based.’ [d] In Smit NO and Others v King Goodwill Zwelithini Kabhekuzulu and Others (10237/2009) [2009] ZAKZPHC 75 (4 December 2009) Judge Nic van Reyden of the Kwa-Zulu Natal High Court, ruled in favour of the revived Zulu cultural practice of barehanded killing of a bull at the Ukweshwama festival, satisfied with the evidence of cultural expert Professor Jabulani Mapalala[1], who said that the animal’s death was quick, unpainful and that no blood was shed. (Others disagreed[2]: Mapalala’s expert witness testimony contradicts Chief Mlaba (not submitted to the court), as quoted in an ANC newsletter of December 1995, that: “We must use our bare hands, It’s cruelty, we agree, but it’s our culture. We cannot change our culture.”[3]). 1. International Law on Cultural Rights: UN Human Rights Committee: [a] In Sandra Lovelace v. Canada, Communication No. R.6/24 (29 December 1977), U.N. Doc. Supp. No. 40 (A/36/40) at 166 (1981), Lovelace petitioned the United Nations Human Rights Committee pursuant to the Optional Protocol of the International Covenant on Civil and Political Rights on December 29, 1977. On July 30, 1981 the United Nations Human Rights Committee reached its decision on the communication which 'inter alia' found Canada to be in breach of Article 27, of the International Covenant on Civil and Political Rights, the right of minority members to practice their culture. 2. International Law on Interpretation and Harmonization of Cultural Rights: International Court of Justice: [a] The Opinion of Weeramantry J in Case Concerning the Gabcikovoclarifies his legal Nagymaros Project (Hungary v Slovakia)[4], perspectives towards multi-culti lawmaking, namely that multi-cultural law must (a) avoid Mono-cultural legal hegemony and (b) draw on legal cultural diversity: The need for International law to draw upon Worlds Diversity of Cultures in Harmonizing Development and Environmental Protection. In drawing into international law the benefits of the insights available from other cultures, and in looking to the past for inspiration, international environmental law would not be departing from traditional methods of international law, but would, in fact, be following in the path charted out by Grotius. Rather than laying down a set of principles a priori for the new discipline of international law, he sought them also a posteriori from the experience of the past, searching through a whole range of cultures

[1] Mkhize: Bull-killing ruling promotes cultural tolerance, Mail and Guardian, 04 December 2009; Court Clears Ritual, Bare Handed Killing of a Bull – Does the Judgement Threaten Wider Environmental Problems?, by Dave Harcourt, Eco-Localizer, 6 Dec 2009; S. African Judge Compares Zulu Bull-Killing to Holy Communion, by C Szabo, 2 Dec 2009, Digital Journal; [2] Culture no excuse for cruelty: How soon before we start burning witches again?; Justice Malala, Sunday Times, 6 Dec 2009: “The argument put forward was that this bull must suffer because my ancestors made animals suffer. The argument is, with all due respect, stupid: my ancestors had not read the work of JM Coetzee and were not on Facebook. I know that I know more than they did, and that my practices must of necessity differ with theirs.” [3] ANC Daily News Briefing, Monday 11 December 1995: Zulu King revives ceremonies to build support, Sapa-AP, 10 December 1995; Court Clears Ritual, Bare Handed Killing of a Bull – Does the Judgement Threaten Wider Environmental Problems?, by Dave Harcourt, Eco-Localizer, 6 December 2009 [4] Opinion of Weeramantry J in the Case Concerning the Gabcikovo-Nagymaros Project (Hungary v Slovakia) (1998) 37 International Legal Materials 162 206.

available to him for this purpose[5]. From them he drew the durable principles which had weathered the ages, on which to build the new international order of the future. Environmental law is now in a formative stage, not unlike international law in its early stages. A wealth of past experience from a variety of cultures is available to it. It would be pity indeed if it were left untapped merely because of attitudes of formalism which see such approaches as not being entirely de rigueur. 3. Lifestyle as Evidence for Enquiry into Choice of Cultural Law: [a] In Ex Parte Minister of Native Affairs in re: Yako v Beyi 1948 (1) SA 388 (A) Schreiner J.A. said lifestyle of is a choice of law factor. “Aside from an express choice of laws all connecting factors with conflict of personal laws are designed to determine, in an objective manner, the cultural orientation of the parties. Because the laws involved are conceived in terms of culture .... the connecting factors must be conceived in like terms. The most direct access to a person’s cultural leanings would clearly be his or her lifestyle.”

WRIT OF CERTIORARI/REVIEW: 34. Access to courts Everyone has the right to have any dispute that can be resolved by the application of law decided in a fair public hearing before a court or, where appropriate, another independent and impartial tribunal or forum. 33. Just administrative action 1. Everyone has the right to administrative action that is lawful, reasonable and procedurally fair. The right to review is one aspect of the right to a free and fair trial. Review is similar to ‘appeal’, except that it is more broader, the court is allowed to go ‘outside the four corners of the documents filed in the matter’ or if it was a trial, then ‘outside the four corners of the trial transcript’. The court can then take a big picture look at whether the court or administrative proceedings were conducted fairly, impartially, efficiently and competently. Section 34 of the constitution for example, guarantees the right ‘to have justiciable disputes settled by a court of law or, where appropriate, another independent and impartial forum’ (such as the Press Ombudsman). Where any administrative body, whether the Press Ombudsman, or a liquor board, or a court of law, do not provide a fair impartial hearing, the proceedings of the hearing, can be either appealed, or be taken on review to a higher court. [a] S 173 of the SA Constitution grants Supreme Courts the inherent power to protect & regulate their own process and to develop the common law, taking into account the Interests of Justice (within the context of the values of the Constitution). Review: Irregularities & Illegalities in the Proceedings: [a] S 24(1) of the Supreme Court Act provides the grounds upon which proceedings of any inferior court may be brought under review, of relevance here are:-- (a) Absence of Jurisdiction on the part of the [5] Julius Stone, Human Law and Human Justice, 1965, p.66: “It was for this reason that Grotius added to his theoretical deductions such a mass of concrete examples from history.”

court; (c) Gross Irregularity in the Proceedings, & (d) the Admission of Inadmissible or Incompetent Evidence or the Rejection of Admissible or Competent evidence. Irregularity of Proceedings: [a] Irregularity: Where a Mistake of Law is fundamental in the sense that a lower court has declined to exercise the function entrusted to it by statute and, as a result of such conduct, a party has been denied the right to a fair hearing, such error may constitute an irregularity. Grounds for Review: [a] In Johannesburg Consolidated Investment Co. v Johannesburg Town Council 1903 TS 111 114 – 117, the court held that there are three distinct categories of judicial review, of relevance here are: (A) Irregularities & Illegalities in the Proceedings before lower courts, as contemplated by S 24 of the Supreme Court Act; and (C) Reviews provided for by other legislation, explained as: ‘The legislature has from time to time conferred upon this court or a Judge a power of review which in my opinion was meant to be far wider than the powers which it possesses under either of the review procedures to which I have alluded’ [(A) and (B) above] (116). It was further held that the second form of review means to “examine” or “take into consideration” and that the powers of the court in considering a matter already dealt with by the inferior court are unlimited – in other words, the reviewing court is empowered to entertain the matter de novo (At 310j-311a). Thus where a court reviews a decision of an inferior court in which it is alleged that a constitutional right has been infringed or threatened, the review is of the second variety described above and the court is therefore not limited to the grounds set out in s 24(1) of the Supreme Court Act (At 312a-c). Test for Bias: [a] In The Test for Bias in the Administrative and Judicial Process, (1982-3), 3 Natal U L Rev. 24, Greenberg J concluded (at 106), that: “The test appears to be whether the person challenged has so associated himself with one of the two opposing views that there is a real likelihood of bias or that a reasonable person would believe that he would be biased.”

True and Correct Interpretation of Proceedings: [a] In S v Ndala 1996 (1) 218 (C) 224 d-g, the court held that if the right of an Accused to a true and correct interpretation of the proceedings has, prima facie, been irrevocably infringed and such an infringement is brought to the attention of the Supreme Court, the court must intervene.

Telephoned SAPA ((011) 782 1600) on 27 January 2011 at 1607 hrs, and spoke to Mr. van der Velden, to confirm that he had received the Constitutional Court documentation for his attention; he said he was busy and put down the phone.

008 & 009: BUSINESS DAY & PETER BRUCE

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:58 AM To: 'Editor: Peter Bruce'; 'News Desk'; 'Editor Sam Mkokelis' Subject: CCT #06-11: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

BUSINESS DAY PETER BRUCE Eighth and Ninth Respondents Mr. Peter Bruce, Editor Business Day P O Box 1746, Saxonwold, 2132 Tel: (011) 280 3091 | Fx: (011) 280 5501

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

[15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: sam mkokeli [mailto:mkokeli@gmail.com] Sent: Saturday, January 22, 2011 2:03 AM To: Lara Johnstone Subject: Delivered: CCT #06-11: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE;Concourt Service per Electronic Mail Your message was delivered to the recipient.

Mr. Bruce was contacted by telephone at (011) 280 3091 / 280 5501, on 26 January 2011 at 13:03 hrs. Mr. Bruce said he had not received the email correspondence.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 1:08 PM To: 'Editor: Peter Bruce' Subject: CCT #06-11: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE; Concourt Service per Electronic Mail Importance: High Mr. Bruce, As per telephone conversation a few minutes ago; here is the Concourt documentation email that was sent to your email address on 22 January. Please acknowledge receipt. Thanks. Lara Johnstone

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.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 11:46 AM To: 'Secretary: Priscilla Malinga' Subject: Att: Peter Bruce, c/o Priscilla Malinga, Business Day; RE: CCT #0611: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE; Concourt Service per Electronic Mail Importance: High Hi Priscilla, As per our conversation a few minutes ago; here is the documentation I sent to Mr. Bruce yesterday. Please can you acknowledge receipt and make sure he receives. Thanks LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Priscilla Malinga [mailto:MalingaP@bdfm.co.za] Sent: Thursday, January 27, 2011 11:51 AM To: Lara Johnstone Subject: Read: Peter Bruce, c/o Priscilla Malinga, Business Day; RE: CCT #0611: Respondent: [08] & [09] BUSINESS DAY & PETER BRUCE; Concourt Service per Electronic Mail Importance: High Your message was read on Thursday, January 27, 2011 11:51:04 AM (GMT+02:00) Harare, Pretoria.

010 & 011: BUSINESS REPORT & J. SIKHAKHANE From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 1:58 AM To: 'Editor: Jabulani Sikhakhane'; 'Business Report:' Subject: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Importance: High Per Electronic Mail:

TO: TO:

BUSINESS REPORT JABULANI SIKHAKHANE Tenth and Eleventh Respondent Mr. Jabulani Sikhakhane, Editor Business Report 47 Sauer Street, Johannesburg Tel: (011) 633 2484 | Fax: (011) 838 2693

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Londiwe Buthelezi [mailto:londiwe.buthelezi@inl.co.za] Sent: Monday, January 24, 2011 8:44 AM

To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 8:43:53 AM (GMT+02:00) Harare, Pretoria. B

From: Wiseman Khuzwayo [mailto:wiseman.khuzwayo@inl.co.za] Sent: Monday, January 24, 2011 3:13 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 3:12:49 PM (GMT+02:00) Harare, Pretoria. C

Business Report were contacted by telephone on 26 January 2011 at 13:15 hrs, where I spoke to Ms. Tracy Pillai, and the documents were then submitted to Editor: Ellis Mnyandu: (ellis.mnyandu@inl.co.za), Business Report Newsroom: (Business.report@inl.co.za), Tracy Pillai: (Tracey.pillai@inl.co.za).

D From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 1:27 PM To: 'Editor: Ellis Mnyandu:'; 'Business Report Newsroom:' Subject: Att: BUS. REPORT: Editor: Ellis Mnyandu; Concourt Service per Electronic Mail; RE: [Respondents 10 & 11] Importance: High Per Electronic Mail: TO: TO:

BUSINESS REPORT JABULANI SIKHAKHANE Tenth and Eleventh Respondent Mr. Ellis Mnyandu, Editor Business Report 47 Sauer Street, Johannesburg Tel: (011) 633 2484 | Fax: (011) 838 2693

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant Please note Email Notice sent below; not yet acknowledged as received. Please acknowledge receipt.

Thank you,

LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za [NOTICE AS PER ORIGINAL CONTENT] E From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 1:31 PM To: 'Tracy Pillai:' Subject: Att: Bus. Report Editor: Mr. Ellis Mnyandu; c/o Tracy Pillai: RE: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Importance: High Ms. Pillai, As per telephone conversation a few minutes ago; please could you forward the attached documentation to Business Day Editor Mr. Ellis Mnyandu's secretary; for Mr. Ellis / Business Day's response, including Business Day's response related to their former editor: Mr. Jabulani Sikhakhane.

Per Electronic Mail: TO: TO:

BUSINESS REPORT JABULANI SIKHAKHANE Tenth and Eleventh Respondent Mr. Ellis Mnyandu, Editor Business Report 47 Sauer Street, Johannesburg Tel: (011) 633 2484 | Fax: (011) 838 2693

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant As per electronic mail, sent on January 22, 2011 1:58 AM, below. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Tracey Pillai [mailto:tracey.pillai@inl.co.za] Sent: Wednesday, January 26, 2011 1:47 PM To: 'Lara Johnstone' Subject: RE: Bus. Report Editor: Mr. Ellis Mnyandu; c/o Tracy Pillai: RE: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Good Day Lara, If you are referring to a response for Business Day, please contact them directly, as we cannot comment on their behalf. Ellis Mnyandu is the current Editor of Business Report Newspaper. Regards, Tracey Pillai PA to the Editor Business Report Newspaper Tel: +27 (0)11 633 2343 Fax: +27 (0)11 838 2693 tracey.pillai@inl.co.za www.br.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 1:58 PM To: 'Tracey Pillai' Subject: RE: Bus. Report Editor: Mr. Ellis Mnyandu; c/o Tracy Pillai: RE: CCT #06-11: Respondent: [10] & [11] BUS. REPORT & J. SIKHAKHANE; Concourt Service per Electronic Mail Hi Tracy, No, I am not referring to Business Day; I have already delivered the documentation for Business Day to its Editor, Mr. Peter Bruce. This documentation is for the editor of BUSINESS REPORT: Mr. Ellis Mnyandu; in regards to the statements made by the former editor of BUSINESS REPORT, Mr. Sikhakhane, as detailed in the Founding Affidavit documentation. The documentation sent to you, is for the attention of Business Report: Editor: Mr. Ellis Mnyandu. Thanks! Lara

012 & 013: CAPE ARGUS & CHRIS WHITFIELD From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:07 AM To: 'Editor: Chris Witfield'; 'Lindiz Van Zilla'; 'Lyntina Aimes'; 'Gasant

Abarder'; 'Andisiwe Makinana'; 'Sue Visser' Subject: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

CAPE ARGUS CHRIS WITFIELD Twelfth and Thirteenth Respondents Mr. Chris Witfield, Editor Cape Argus P O Box 56, Capetown, 8000 Tel: (021) 488 4911 | Fx: (021) 488 4156

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Lindiz Van Zilla [mailto:lindiz.vanzilla@inl.co.za] Sent: Saturday, January 22, 2011 2:29 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High

From: Sue Visser [mailto:sue.visser@inl.co.za] Sent: Saturday, January 22, 2011 5:54 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 5:53:31 PM (GMT+02:00) Harare, Pretoria.

From: Gasant Abarder [mailto:gasant.abarder@inl.co.za] Sent: Monday, January 24, 2011 7:28 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 7:28:06 AM (GMT+02:00) Harare, Pretoria.

From: Lyntina Aimes [mailto:lyntina.aimes@inl.co.za] Sent: Monday, January 24, 2011 8:38 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 8:37:59 AM (GMT+02:00) Harare, Pretoria.

Telephoned Cape Argus on 14:21 hrs, and spoke to Mr. Chris Witfields personal secretary, Ms. Lesley Byram. She agreed to accept the documentation for Mr. Witfield and forward to him.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 2:25 PM To: 'Lesley.byram@inl.co.za' Subject: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Hi Lesley, As per telephone conversation a few minutes ago; please forward to Mr. Witfield, for his attention and response. Below was sent to him on 22 January 2011; I just need to confirm he has received and knows about it. Please acknowledge receipt. Thanks LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za [CONTENT AS ORIGINAL]

From: Lesley Byram [mailto:lesley.byram@inl.co.za] Sent: Wednesday, January 26, 2011 2:29 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [12] & [13] CAPE ARGUS & C. WITFIELD; Concourt Service per Electronic Mail Importance: High Your message was read on Wednesday, January 26, 2011 2:29:16 PM (GMT+02:00) Harare, Pretoria.

014 & 015: CAPE TIMES & ALIDE DASNOIS From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:07 AM To: 'Editor: Alide Dasnois'; 'Ella Smook'; 'Di Caelers'; 'Nina Talliard' Subject: CCT #06-11: Respondent: [14] & [15] CAPE TIMES & A. DASNOIS; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

CAPE TIMES

TO:

ALIDE DASNOIS Fourteenth and Fifteenth Respondents Ms. Alide Dasnois, Editor Cape Times Newspaper House, 4th Floor 122 St. Georges Mall, Capetown Tel: (021) 488 4911 | Fx: (021) 488 4717

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Nina Talliard [mailto:nina.talliard@inl.co.za] Sent: Sunday, January 23, 2011 10:49 AM To: Lara Johnstone

Subject: Read: CCT #06-11: Respondent: [14] & [15] CAPE TIMES & A. DASNOIS; Concourt Service per Electronic Mail Importance: High Your message was read on Sunday, January 23, 2011 10:49:13 AM (GMT+02:00) Harare, Pretoria.

From: Ella Smook [mailto:ella.smook@inl.co.za] Sent: Monday, January 24, 2011 9:27 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [14] & [15] CAPE TIMES & A. DASNOIS; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 9:26:57 AM (GMT+02:00) Harare, Pretoria.

Called the CAPE TIMES to speak to Editor, Ms. Alide Dasnois, on 26 January 2011 at 14:25 hrs; and was put through to Mr. Witfields secretary, Ms. Lesley Byram, who said that Ms. Dasnois is on holiday for a month, and that Mr. Witfield is editor in charge while she was away. Mr. Witfield has also been served, and is aware of the documentation.

016 & 017: CITY PRESS & FERIAL HAFFAJEE SEE MEDIA 24 RESPONDENTS

018 & 019: THE CITIZEN & MARTIN WILLIAMS From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:07 AM To: 'Editor: Martin Williams'; 'Secretary: Yvonne'; 'citizensub@gmail.com'; 'Puleng M'; 'Citizen News Bureau' Subject: CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

THE CITIZEN MARTIN WILLIAMS Eighteenth and Nineteenth Respondents

Mr. Martin Williams, Editor The Citizen P O Box 43069, Industria, Jhb, 2042 Tel: (011) 248 6000 | Fx: (011) 248 6213 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: martcw7@gmail.com [mailto:martcw7@gmail.com] Sent: Saturday, January 22, 2011 2:09 AM To: Lara Johnstone Subject: Delivered: CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Your message was delivered to the recipient.

From: citizensub@gmail.com [mailto:citizensub@gmail.com] Sent: Saturday, January 22, 2011 2:10 AM To: Lara Johnstone Subject: Delivered: CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Your message was delivered to the recipient.

From: pulengm [mailto:pulengm@mail.citizen.co.za] Sent: Sunday, January 23, 2011 10:07 AM To: Lara Johnstone Subject: Read - CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Your message To: "'Editor: Martin Williams'" <martinw@citizen.co.za>, "'Secretary: Yvonne'" <yvonnel@citizen.co.za>, <citizensub@gmail.com>, "'Puleng M'" <pulengm@citizen.co.za>, "'Citizen News Bureau'" <news@citizen.co.za> Subject: CCT #06-11: Respondent: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Delivered: 01/22/2011 02:07:02 was read on01/23/2011 10:06:33

Telephoned THE CITIZEN on 26 January 2011 to speak to Yvonne Le Roux, Mr. Williams secretary on (011) 248 6013, at 14:52 hrs. No answer. Called again at 16:05 hrs and spoke to Johanna; who said that Ms. Le Roux was checking whether she could open the attachments.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 4:06 PM To: 'Martin Williams'; 'Secretary: Yvonne Le Roux' Subject: CCT #06-11: Resp: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Importance: High Mr. Williams & Ms. Le Roux, Please find attached the documentation sent for your attention on 22 January 2011. Please acknowledge receipt. Thanks.

LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: martcw7@gmail.com [mailto:martcw7@gmail.com] Sent: Wednesday, January 26, 2011 4:09 PM To: Lara Johnstone Subject: Delivered: CCT #06-11: Resp: [18] & [19] THE CITIZEN & M. WILLIAMS; Concourt Service per Electronic Mail Your message was delivered to the recipient.

020: DAILY DISPATCH From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Ed. Coordinator - Samantha'; 'Investigations Editor Mr. Eddie Botha'; 'Robin Ross-Thompson'; 'Theodore Jephta'; 'Thanduxolo Jika:' Subject: CCT #06-11: Respondent: DAILY DISPATCH; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

DAILY DISPATCH Twentieth Respondent Editor The Daily Dispatch P O Box 131, East London, 5200 Tel: (043) 702 2000 | Fx: (043) 743 5155

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of

Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Robin Ross-Thompson [mailto:RobinR@dispatch.co.za] Sent: Saturday, January 22, 2011 3:29 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: DAILY DISPATCH; Concourt Service per Electronic Mail Importance: High Your message To: Thanduxolo Subject: Electronic Sent:

news; Eddie Botha; Robin Ross-Thompson; Theodore Jeptha; Jika CCT #06-11: Respondent: DAILY DISPATCH; Concourt Service per Mail Sat, 22 Jan 2011 02:17:05 +0200

was read on Sat, 22 Jan 2011 15:28:56 +0200

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.

022 & 023: DAILY MAVERICK & BRKIC BRANKO From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Editor: Brkic Branko'; 'Deputy Editor Philip de Wet'; 'Transparency Mandy de Waal'; 'Brendah Nyakudya'; 'Jacques Rosseau'; 'Ivo Veger'; 'Stephen Grootes'; 'Brooks Spector'; 'Newsroom:' Subject: CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

DAILY MAVERICK BRKIC BRANKO Twenty-Second and Twenty-Third Respondents Brkic Branko, Editor The Daily Maverick 1st Floor, Building 3, Albury Park Corner Jan Smuts & Albury Rd, Hyde Park Cell: (084) 444 8700 | (083) 414 2983

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully,

LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Phillip de Wet [mailto:phillip@thedailymaverick.co.za] Sent: Saturday, January 22, 2011 8:47 AM To: Lara Johnstone Cc: Editor: Brkic Branko Subject: Re: CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail Hi Lara Much as I loath having to waste my time in such an utterly senseless fashion as communicating with you, you have again forced me into doing so. These pointless e-mails you send us contain no readable attachments. The "winmail.dat" files attached can not be opened by any standards-based software package. In a funny coincidence, it is simply a large amount of uninterpretable noise . So no, whatever you may choose to assume, your notice has not been served. Phillip

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 12:28 PM To: 'Editor: Brkic Branko'; 'Deputy Editor Philip de Wet'; 'Transparency Mandy de Waal'; 'Brendah Nyakudya'; 'Jacques Rosseau'; 'Ivo Veger'; 'Stephen Grootes'; 'Brooks Spector'; 'Newsroom:' Subject: (2) CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail Per Electronic Mail: TO: TO:

DAILY MAVERICK BRKIC BRANKO

Twenty-Second and Twenty-Third Respondents The Daily Maverick 1st Floor, Building 3, Albury Park Corner Jan Smuts & Albury Rd, Hyde Park Cell: (084) 444 8700 | (083) 414 2983 Delivered to: * Brkic Branko (Branko@thedailymaverick.co.za) * Deputy Editor Philip de Wet (phillip@thedailymaverick.co.za)

* * * * * * *

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) Daily Maverick Newsroom: (news@thedailymaverick.co.za)

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY - SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find following notices for your attention: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B) Available for read or download at: http://issuu.com/js-ror/docs/110128_cct-0611_condonation?mode=a_p The aforementioned documents were emailed to you in PDF format (exactly the same PDF format as the original Notice of Motion, which Mr. de Wet acknowledged as received); but Mr. de Wet state's he is unable to open the new pdf's, which he says he received as "winmail.dat" files, which he cannot open. All other respondents have had no problems opening the pdf files originally sent. Nobody has ever informed me of any pdf file I have sent being unopenable and that it is a 'winmail.dat' file. Irrespective, if Mr de Wet is unable to open the PDF files, he can view or download the CONDONATION files online at: http://issuu.com/js-ror/docs/110128_cct-0611_condonation?mode=a_p

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants.

Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Phillip de Wet [mailto:phillip@thedailymaverick.co.za] Sent: Sunday, January 23, 2011 11:18 PM To: Lara Johnstone Cc: Branko Brkic Subject: Re: (2) CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail Hi Lara You have sent us what appears to be exactly the same winmail.dat file as an attachment to your last mail. It is not a PDF document, nor in any format I can access. You have now also sent us a link to self-publishing site issuu.com. As a method of delivering what you claim to be a legal document, that is most unsatisfactory. It does not constitute serving, but requires fetching. As the document supposedly residing there is under your constant control (as well as the control of the site administrators, or anyone granted access to the relevant account, or anyone who gains access to the relevant account), you (or another party) can alter it at any time â&#x20AC;&#x201C; and claim that the altered version is the one we accessed. I have not your apparent legal expertise, but I can see any number of problems there. If you would like to consider this document served, as you continue to insist, I suggest that you actually serve it by one of the generally accepted methods. Phillip

D From: jmc.pa.tf@gmail.com [mailto:jmc.pa.tf@gmail.com] On Behalf Of Lara Sent: Monday, January 24, 2011 2:16 AM To: Phillip de Wet Cc: Branko Brkic; jmcswan@mweb.co.za Subject: Re: (2) CCT #06-11: Respondent: [22] & [23] DAILY MAVERICK & BRKIC BRANKO; Concourt Service per Electronic Mail Hi Philip, My Microsoft Outlook email program is set to sending emails in Plain Text. It should be -- according to Microsoft -- impossible for any 'winmail.dat' file to be sent; when sending emails in Plain Text, from Microsoft Outlook. In the thousands of emails I have sent, nobody has ever informed me of any 'winmail.dat' email, except yourself.

I read up on it, and apparently it is simply a file with instructions to another Microsoft Outlook user, instructing the end-user on formatting in the email (bold and such stuff). The email program -- Microsoft Outlook -- sends it itself, but it should only do so, when the Email formatting is set to Rich Text; which I never ever use. So, it appears to be some strange quirk, my apologies. Info on Winmail.dat: http://support.microsoft.com/kb/138053 http://www.pchell.com/support/winmaildat.shtml Re: ISSUU. The file is available for you to download; and I only set it up at ISSUU, cause we had this problem with winmail.dat, that I had never heard of, before I read up on it. As I said, my outlook express is not set to Rich Text, but just in case, I am going to send you the PDF's from gmail, so you should not have any problems with anymore winmail.dat's. RE: Generally accepted method of serving documents. Email has become a generally accepted method of serving documents in the civilized world. Not only is it environmentally friendly, by not wasting the recipients fax paper, or printing dozens of documents, that may not require printing. It also saves postage and service funds for all parties, not to mention reduces carbon footprints for delivery. For example: United Kingdom Criminal Procedure Rules: Rule.4.6, provides for Service by .. email or other electronic means. http://www.justice.gov.uk/criminal/procrules_fin/part_04.htm The constitutional court registrar had no problems with me serving the documents by email, as long as I verified they had been received. The concern was not with the method of electronic delivery, but simply to confirm that someone had acknowledged receipt of the documents, at the respective place of business or work, for delivery to the appropriately responsible person. I include herewith all the documents, in this matter, served to Daily Maverick and others in PDF: * Notice of Motion: Direct Access (136 K) * Founding Affidavit: Direct Access (427 K) * Notice of Motion: Condonation (41 K) * Founding Affidavit: Condonation ((37 K) * Founding Affidavit: Condonation Annexures [A] & [B] (284 K) & (771 K) I hope that these come through correctly as pdf. My apologies about the 'winmail.dat', as I explained. Please let me know if you have any problems with these PDF's. Lara

024 & 025: DAILY NEWS & ALAN DUNN From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Editor Alan Dunn'; 'Editor Secretary Debbie Yunnie' Subject: CCT #06-11: Respondent: [24] & [25] DAILY NEWS & A. DUNN; Concourt

Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

DAILY NEWS ALAN DUNN Twenty-Fourth and Twenty-Fifth Respondents Alan Dunn, Editor The Daily News Independent Newspapers 18 Osborne Street, Greyville, Dbn Tel: (031) 308 2911 | Fx: (031) 308 2111

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Debbie Yunnie [mailto:debbie.yunnie@inl.co.za] Sent: Monday, January 24, 2011 7:49 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [24] & [25] DAILY NEWS & A. DUNN; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 7:48:55 AM (GMT+02:00) Harare, Pretoria.

026 & 027: EAST COAST RADIO & DIANE MACPHERSON From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 3:35 AM To: 'News Editor Diane Macpherson'; 'Online Editor Charis Apelgren' Subject: CCT #06-11: Respondent: [26] & [27] ECR & D. MACPHERSON; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

EAST COAST RADIO DIANE MACPHERSON Twenty-Sixth and Twenty-Seventh Respondents Diane Macpherson, Editor East Coast Radio 313-315 Umhlanga Rocks Drive, Umhlanga Rocks, Durban Tel: (031) 570 9495 | Fx: (086) 679 4951

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B) Documents available for download at: http://issuu.com/js-ror/docs/110128_cct-0611_condonation?mode=a_p

TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Diane Macpherson [mailto:diane@ecr.co.za] Sent: Saturday, January 22, 2011 3:35 AM To: Lara Johnstone Subject: Out of Office AutoReply: CCT #06-11: Respondent: [26] & [27] ECR & D. MACPHERSON; Concourt Service per Electronic Mail Hello, I am out of the office until MON, 24 January. For urgent queries or time-bound press releases, please email newswatch@ecr.co.za or contact my assistant Bongi on 031 570 9405 (bongs@ecr.co.za) and she will be able to point you in the right direction. Thanks, Diane

Telephoned EAST COAST RADIO, on (031) 570 9495, at 15:49 hrs on 26 January 2011, and spoke to Ms. Diane MacPherson; who confirmed receipt of Condonation documentation.

028 & 029: EYEWITNESS NEWS & KATY KATAPODIS

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Eyewitness News Editor Katy Katapodis'; 'editor@ewn.co.za'; 'Eyewitness News'; 'Webmaster' Subject: CCT #06-11: Respondent: [28] & [29] EYEWITNESS NEWS & K. KATAPODIS; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO

EYEWITNESS NEWS KATY KATAPODIS Twenty-Eighth and Twenty-Ninth Respondents Katy Katapodis, Editor Eyewitness News Primedia House, 2nd Floor 5 Gwen Lane (cnr Gwen Lane & Fredman Dr) Sandown Tel: (011) 506 3702 | Fx (086) 501 2014

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave

George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: 702 Eyewitness News [mailto:News@ewn.co.za] Sent: Saturday, January 22, 2011 2:29 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [28] & [29] EYEWITNESS NEWS & K. KATAPODIS; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 2:29:14 AM (GMT+02:00) Harare, Pretoria.

From: Katy Katopodis [mailto:Katy@ewn.co.za] Sent: Saturday, January 22, 2011 7:18 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [28] & [29] EYEWITNESS NEWS & K. KATAPODIS; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 7:17:47 AM (GMT+02:00) Harare, Pretoria.

030 & 031: INDEPENDENT ONLINE (IOL) & ADRIAN EPHRAM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Editor Adrian Ephraim' Subject: CCT #06-11: Respondent: [30] & 31] IOL & A. EPHRAIM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

INDEPENDENT ONLINE ADRIAN EPHRAIM Thirtieth and Thirty-First Respondents Adrian Ephraim, Editor Independent Online The Star Building 47 Sauer Street, Jhb, 2001 Tel: (011) 633 9111

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA

Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Adrian Ephraim [mailto:adrian.ephraim@inl.co.za] Sent: Saturday, January 22, 2011 2:22 AM To: Lara Johnstone Subject: Out of Office: CCT #06-11: Respondent: [30] & 31] IOL & A. EPHRAIM; Concourt Service per Electronic Mail I am out of the office until January 31. For work related queries please contact renee.moodie@inl.co.za Regards Adrian Ephraim

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 3:56 PM To: 'renee.moodie@inl.co.za' Subject: Att: Ms. Renee Moodie; RE: CCT #06-11: Respondent: [30] & 31] IOL & A. EPHRAIM; Concourt Service per Electronic Mail Importance: High Ms. Renee Moodie, Please can you make sure that Mr. Ephraim receives the documentation below upon his return on the 30th. It has been sent to his email address, which replied: -----------------From: Adrian Ephraim [mailto:adrian.ephraim@inl.co.za] Sent: Saturday, January 22, 2011 2:22 AM To: Lara Johnstone Subject: Out of Office: CCT #06-11: Respondent: [30] & 31] IOL & A. EPHRAIM; Concourt Service per Electronic Mail I am out of the office until January 31. For work related queries please contact renee.moodie@inl.co.za Regards Adrian Ephraim ----------------He shall need to decide how he wishes to respond to the issues, and if he has any objections to orders requested from the Constitutional Court; he needs to file such objections and notify me of such. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

032 & 033: MAIL & GUARDIAN & NIC DAWES From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:17 AM To: 'Editor Matthew Burbidge'; 'Editor Keith Nichols'; 'Editor Nic Dawes'; 'News Desk'; 'Stefaans Brummer'; 'Verashni Pillay'; 'Newsdesk: Drew Forrest'; 'Features: Tanya Pamplone'; 'Dep. Editor: Rapule Tabane'; 'Editor Pers. Asst. Wendy Mosetlhi' Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

MAIL AND GUARDIAN NIC DAWES Thirty-Second and Thirty-Third Respondents Nic Dawes, Editor

Mail and Guardian P O Box 91667, Auckland Park, Jhb 2006 Tel: (011) 250 7300 | Fx: (011) 250 7502 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Rapule Tabane [mailto:RapuleT@mg.co.za] Sent: Saturday, January 22, 2011 2:52 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Importance: High Your message

To: Matthew Burbidge; Keith Nicholls; Nicholas Dawes; Newsdesk; Stefaans Brummer; Verashni Pillay; Drew Forrest; Tanya Pampalone; Rapule Tabane; Wendy Mosetlhi Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Sent: Sat, 22 Jan 2011 02:17:05 +0200 was read on Sat, 22 Jan 2011 02:52:18 +0200

From: Verashni Pillay [mailto:VerashniP@mg.co.za] Sent: Sunday, January 23, 2011 8:52 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Importance: High Your message To: Matthew Burbidge; Keith Nicholls; Nicholas Dawes; Newsdesk; Stefaans Brummer; Verashni Pillay; Drew Forrest; Tanya Pampalone; Rapule Tabane; Wendy Mosetlhi Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Sent: Sat, 22 Jan 2011 02:17:05 +0200 was read on Sun, 23 Jan 2011 20:52:24 +0200

From: Drew Forrest [mailto:DrewF@mg.co.za] Sent: Monday, January 24, 2011 4:22 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Importance: High Your message To: Matthew Burbidge; Keith Nicholls; Nicholas Dawes; Newsdesk; Stefaans Brummer; Verashni Pillay; Drew Forrest; Tanya Pampalone; Rapule Tabane; Wendy Mosetlhi Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Sent: Sat, 22 Jan 2011 02:17:05 +0200 was read on Mon, 24 Jan 2011 16:21:34 +0200

From: Nicholas Dawes [mailto:NicholasD@mg.co.za] Sent: Wednesday, January 26, 2011 1:28 PM To: Lara Johnstone

Subject: Read: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Importance: High Your message To: Matthew Burbidge; Keith Nicholls; Nicholas Dawes; Newsdesk; Stefaans Brummer; Verashni Pillay; Drew Forrest; Tanya Pampalone; Rapule Tabane; Wendy Mosetlhi Subject: CCT #06-11: Respondent: [32] & [33] M&G & N. DAWES; Concourt Service per Electronic Mail Sent: Sat, 22 Jan 2011 02:17:05 +0200 was read on Wed, 26 Jan 2011 13:28:18 +0200

034 & 035: THE MERCURY & ANGELA QUINTAL From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Angela Quintal'; 'Mercury News' Subject: CCT #06-11: Respondent: [34] & [35] THE MERCURY & A. QUINTAL; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

THE MERCURY ANGELA QUINTAL Thirty-Fourth and Thirty-Fifth Respondents Angela Quintal, Editor The Mercury Independent Newspapers, 18 Osborne St., Greyville, Durban Tel: (031) 308 2911 | Fx: (031) 308 2333

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Angela Quintal [mailto:angela.quintal@inl.co.za] Sent: Saturday, January 22, 2011 6:33 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [34] & [35] THE MERCURY & A. QUINTAL; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 6:32:39 AM (GMT+02:00) Harare, Pretoria.

036 & 037: NEWS 24 & JANNIE MOMBERG SEE MEDIA 24 RESPONDENTS

038 & 039: PRETORIA NEWS & ZINGISA MKHUMA

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Zingisa Mkhuma'; 'Graeme Hosken' Subject: CCT #06-11: Respondent: [38] & [39] PRETORIA NEWS & Z. MKHUMAN; Concourt Service per Electronic Mail Importance: High Per Electronic Mail:

TO: TO:

PRETORIA NEWS ZINGISA MKHUMA Thirty-Eighth and Thirty-Ninth Respondents Zingisa Mkhuman, Editor Pretoria Newspapers Holdings Ltd 216 Vermeulen Street, Pretoria Tel: (012) 300 2000 | Fx: (012) 328 7166

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY – SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

Telephoned the PRETORIA NEWS on 26 January 2011 at 16:13 hrs, and spoke to Ms. Diane Louw, Editor Ms. Zingisa Mkhuma’s secretary, who requested I send the documents to her, and she would forward to Ms. Mkhuman.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 4:35 PM To: 'dianne.low@inl.co.za' Subject: Dianne Low, Pta News; RE:CCT #06-11: Respondent: [38] & [39] PRETORIA NEWS & Z. MKHUMAN; Concourt Service per Electronic Mail Importance: High Ms. Dianne Low Personal Assistant to MS. ZINGISA MKHUMA Hi Dianne As per our brief telephone conversation a few minutes ago; please could you forward the attached documentation to Editor: Ms. Zingisa Mkhuma, for her attention and response. Please acknowledge receipt. Thanks. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

040 & 041: SA STAR & MOEGSIEN WILLIAMS From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Moegsien Williams'; 'Deputy Editor Jovial Rantao'; 'Admin Vidette Aslett'; 'StarNews' Subject: CCT #06-11: Respondent: [40] & [50] SA STAR & M. WILLIAMS; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SA STAR MOEGSIEN WILLIAMS Fortieth and Forty-First Respondents Moegsien Williams, Editor SA Star 47 Sauer Street, Johannesburg Tel: (011) 633 2410 / 9111 | Fax: (011) 836 6186

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA

Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Mthunzi Mbatha [mailto:mthunzi.mbatha@inl.co.za] Sent: Saturday, January 22, 2011 3:24 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [40] & [50] SA STAR & M. WILLIAMS; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 3:23:55 PM (GMT+02:00) Harare, Pretoria.

From: Vidette Aslett [mailto:vidette.aslett@inl.co.za] Sent: Monday, January 24, 2011 8:18 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [40] & [50] SA STAR & M. WILLIAMS; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 8:18:26 AM (GMT+02:00) Harare, Pretoria.

042 & 043: SUNDAY INDEPENDENT & MAKHUDU SEFARA From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Makhudu Sefara'; 'Editor Makhudu Sefara Secretary Jennifer Johnson'; 'Deputy Editor Andrew Walker' Subject: CCT #06-11: Respondent: [42] & [43] SUN. IND. & M. SEFARA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SUNDAY INDEPENDENT MAKHUDU SEFARA Forty-Second and Forty-Third Respondents Makhudu Sefara, Editor Sunday Independent 47 Sauer Street, Johannesburg Tel: (011) 633 9111 | Fx: (011) 834 7520

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

[14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Makhudu Sefara [mailto:makhudu.sefara@inl.co.za] Sent: Saturday, January 22, 2011 8:28 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [42] & [43] SUN. IND. & M. SEFARA; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 8:28:10 AM (GMT+02:00) Harare, Pretoria.

From: Jennifer Johnson [mailto:Jennifer.Johnson@inl.co.za] Sent: Monday, January 24, 2011 8:39 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [42] & [43] SUN. IND. & M. SEFARA; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 8:39:05 AM (GMT+02:00) Harare, Pretoria.

044 & 045: SUNDAY TRIBUNE & PHILANI MGWABA From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Philani Mgwaba'; 'News Editor Liz Clarke'; 'Tribune News' Subject: CCT #06-11: Respondent: [44] & [45] SUNDAY TRIBUNE & P. MGWABA; Concourt Service per Electronic Mail Importance: High

Per Electronic Mail: TO: TO:

SUNDAY TRIBUNE PHILANI MGWABA Forty-Fourth and Forty-Fifth Respondents Philani Mgwaba, Editor Sunday Tribune P O Box 47549 Greyville, 4023 Tel: (031) 308 2771 | Fx: (031) 308 2357

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: S'nethemba Gumede [mailto:s'nethemba.gumede@inl.co.za] Sent: Saturday, January 22, 2011 7:49 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [44] & [45] SUNDAY TRIBUNE & P. MGWABA; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 7:49:08 AM (GMT+02:00) Harare, Pretoria.

From: Amanda Khoza [mailto:amanda.khoza@inl.co.za] Sent: Saturday, January 22, 2011 10:01 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [44] & [45] SUNDAY TRIBUNE & P. MGWABA; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 10:00:56 AM (GMT+02:00) Harare, Pretoria.

Telephoned SUNDAY TRIBUNE: (031) 308 2771, on 27 January 2011, at 11:50 AM, and spoke to Mr. Mgwabaâ&#x20AC;&#x2122;s secretary: Ms. Anita Weedon, who agreed to receive the documents and forward them to Mr. Mgwaba.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 11:58 AM To: 'Secretary: Anita Weedon' Subject: Att: Mr. Mgwaba, c/o Ms. Weedon, Sunday Tribune; RE: CCT #06-11: Respondent: [44] & [45] SUNDAY TRIBUNE & P. MGWABA; Concourt Service per Electronic Mail Importance: High Hi Ms. Weedon, As per our telephone conversation a few minutes ago; please find attached the Constitutional Court documentation that was sent to Mr. Mgwaba. Please can you acknowledge receipt and make sure that he is aware of documents, should he wish to oppose any arguments. Thanks LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954

Email: jmcswan@mweb.co.za

046 & 047: SUNDAY TIMES & RAY HARTLEY From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Editor: Ray Hartley'; 'News Editor Jessica Bezuidenhout'; 'News Editor Heather Robertson'; 'Sunday Times'; 'Justice Malala'; 'Kim Hawkeye' Subject: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

TIMES LIVE (SUNDAY TIMES) RAY HARTLEY Fourty-Sixth and Forty-Seventh Respondents Avusa House, 4 Bierman Avenue Rosebank, Johannesburg Tel: (011) 280 3000 | Fx: (011) 280 5150

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants.

Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Jessica Bezuidenhout [mailto:BezuidenhoutJ@sundaytimes.co.za] Sent: Saturday, January 22, 2011 8:44 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 8:43:45 AM (GMT+02:00) Harare, Pretoria.

From: Sunday Times [mailto:suntimes@sundaytimes.co.za] Sent: Saturday, January 22, 2011 9:28 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 9:28:03 AM (GMT+02:00) Harare, Pretoria.

Called SUNDAY TIMES (011) 280 3000, on 27 January 2011 at 11:59 AM, and spoke to Editor, Mr. Hartleyâ&#x20AC;&#x2122;s secretary Ms. Nonni Mokgethi, who agreed to accept the documentation for Mr. Hartley and to forward to him.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 12:11 PM To: 'Secretary: Nonni Mokgethi' Subject: Att: Mr. Hartley, c/o Ms. N. Mokgethi, Sunday Times; RE: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail Importance: High Hi Ms. Mokgethi,

As per our telephone conversation a few minutes ago; please find attached the Constitutional Court documentation for Mr. Hartley's attention and response. Please acknowledge receipt and make sure he is informed of documentation. Thanks, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Nnoni Mokgethi [mailto:MokgethiN@sundaytimes.co.za] Sent: Thursday, January 27, 2011 12:23 PM To: Lara Johnstone Subject: Read: Att: Mr. Hartley, c/o Ms. N. Mokgethi, Sunday Times; RE: CCT #06-11: Respondent: [46] & [47] SUNDAY TIMES & RAY HARTLEY; Concourt Service per Electronic Mail Importance: High Your message was read on Thursday, January 27, 2011 12:22:31 PM (GMT+02:00) Harare, Pretoria.

048 & 049: 3RD DEGREE & DEBORA PATTA From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'News Room'; 'Ms. Deborah Patta'; 'ETV'; '3rd Degree'; 'Kirsty Blackford'; 'info@etv.co.za'; 'etvnewsP@iafrica.com'; 'etvnewsJ@iafrica.com'; 'webmaster@etv.co.za' Subject: CCT #06-11: Respondent: [48] & [49] 3RD DEGREE & D. PATTA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

3RD DEGREE DEBORAH PATTA Forty-Eighth and Forty-Ninth Respondents Ms Debora Patta 3RD Degree: Executive Producer PO Box 12124, Mill Street Gardens, CAPE TOWN, 8010 Tel: (021) 481 4500 | Fax: (021) 481 4630

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

A Telephoned 3RD DEGREE, on 26 January 2011, at 16:44 hrs, to speak to Ms. Pattaâ&#x20AC;&#x2122;s secretary on (021) 481 6451, but the machine refused to take messages. Telephoned ETV CEO secretary Mr. Marcelle Goldingâ&#x20AC;&#x2122;s secretary, Ms. Jamela Chomela, and asked if I could forward documentation for the attention of Mr. Golding.

Per Electronic Mail: TO: Mr. Marcelle Golding, CEO c/o: Pers. Assist: Ms. Jamela Chomela TO: Ms. Bronwyn Keene-Young, Chief Operating Officer c/o Pers. Assist: Ms. Beverly Fasser ETV HEAD OFFICE: Johannesburg CC: ICASA: info@icasa.org.za, BCCSA: bccsa@nabsa.co.za, Africa Christian Action: info@christianaction.org.za Dear Mr. Golding and Ms. Keene-Young, Please find attached the Constitutional Court documentation for ETV respondents: TO: TO:

TO: E-NEWS TO: PATRICK CONROY Fifty-Seventh and Fifty-Eight Respondents Mr. Patrick Conroy ETV: Head of E-News PO Box 12124, Mill Street Gardens, CAPE TOWN, 8010 Tel: (021) 481 4500 Fax: (021) 481 4630 As per electronic mail service below, which both parties appear to lack the honour and integrity to acknowledge receipt for. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za [CONTENT AS PER ORIGINAL]

From: Jamela Chomela [mailto:JamelaM@etv.co.za]

Sent: Wednesday, January 26, 2011 6:08 PM To: Lara Johnstone Subject: Read: Att: ETV CEO & COO: M. Golding & B. Keene-Young; RE: CCT#0611: [48], [49], [57] & [58] 3RD DEGREE, D. PATTA; E-NEWS & P.CONROY;Concourt Service per Electronic Mail Importance: High Your message was read on Wednesday, January 26, 2011 6:07:33 PM (GMT+02:00) Harare, Pretoria. Jamela Chomela HR Department TEL: 011 537 9331 FAX: 011 537 9380 CELL: 082 884 6196 JamelaM@etv.co.za www.etv.co.za

050 & 051: BEELD & TIM DU PLESSIS SEE MEDIA 24 RESPONDENTS

052 & 053: DAILY SUN & THEMBA KHUMALO

SEE MEDIA 24 RESPONDENTS

054, 055 & 056: DIE BURGER, HENRY JEFFERY & BUN BOOYSEN SEE MEDIA 24 RESPONDENTS

057 & 058: E-NEWS & PATRIC CONROY

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'News room:'; 'Patrick Conroy'; 'Zanile Madikane'; 'Bongi Potelwa'; 'Gill Scholtz' Subject: CCT #06-11: Respondent: [57] & [58] E-NEWS & P. CONROY; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: E-NEWS TO: PATRICK CONROY

Fifty-Seventh and Fifty-Eight Respondents Mr. Patrick Conroy ETV: Head of E-News PO Box 12124, Mill Street Gardens, CAPE TOWN, 8010 Tel: (021) 481 4500 Fax: (021) 481 4630 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

Telephoned ETV CEO secretary Mr. Marcelle Goldingâ&#x20AC;&#x2122;s secretary, Ms. Jamela Chomela, and asked if I could forward documentation for the attention of Mr. Golding.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 5:31 PM To: 'jamelam@etv.co.za'; 'beverly.fasser@etv.co.za' Cc: 'info@icasa.org.za'; 'bccsa@nabsa.co.za'; 'info@christianaction.org.za' Subject: Att: ETV CEO & COO: M. Golding & B. Keene-Young; RE: CCT #06-11: [48], [49], [57] & [58] 3RD DEGREE, D. PATTA; E-NEWS & P.CONROY; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: Mr. Marcelle Golding, CEO c/o: Pers. Assist: Ms. Jamela Chomela TO: Ms. Bronwyn Keene-Young, Chief Operating Officer c/o Pers. Assist: Ms. Beverly Fasser ETV HEAD OFFICE: Johannesburg CC: ICASA: info@icasa.org.za, BCCSA: bccsa@nabsa.co.za, Africa Christian Action: info@christianaction.org.za Dear Mr. Golding and Ms. Keene-Young, Please find attached the Constitutional Court documentation for ETV respondents: TO: TO:

LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za [CONTENT AS PER ORIGINAL]

From: Jamela Chomela [mailto:JamelaM@etv.co.za] Sent: Wednesday, January 26, 2011 6:08 PM To: Lara Johnstone Subject: Read: Att: ETV CEO & COO: M. Golding & B. Keene-Young; RE: CCT#0611: [48], [49], [57] & [58] 3RD DEGREE, D. PATTA; E-NEWS & P.CONROY;Concourt Service per Electronic Mail Importance: High Your message was read on Wednesday, January 26, 2011 6:07:33 PM (GMT+02:00) Harare, Pretoria. Jamela Chomela HR Department TEL: 011 537 9331 FAX: 011 537 9380 CELL: 082 884 6196 JamelaM@etv.co.za www.etv.co.za

059 & 060: FINANCIAL MAIL & BARNEY MTHOMBOTHI

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Barney Mthombothi'; 'David Furlonger'; 'Financial Mail'; 'FM Mad Focus'; 'Rob Rose'; 'Onica Buthelezi'; 'Financial Mail' Subject: CCT #06-11: Respondent: [59] & [60] FIN. MAIL & B. MTHOMBOTHI; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: FINANCIAL MAIL TO: BARNEY MTHOMBOTHI Fifty-Ninth and Sixtieth Respondents Mr Barney Mthombothi Editor: Financial Mail P O Box 1744 Saxonwold, 2132 Tel: (011) 280 5808

Fax: (011) 280 5800 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Rob Rose [mailto:roser@sundaytimes.co.za] Sent: Saturday, January 22, 2011 2:49 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [59] & [60] FIN. MAIL & B. MTHOMBOTHI; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 2:49:26 AM (GMT+02:00) Harare, Pretoria.

From: Barney Mthombothi [mailto:MthombothiB@fm.co.za] Sent: Monday, January 24, 2011 10:14 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [59] & [60] FIN. MAIL & B. MTHOMBOTHI; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 10:14:16 AM (GMT+02:00) Harare, Pretoria.

061 & 062: FINWEEK & COLLEEN NAUDE SEE MEDIA 24 RESPONDENTS

063 & 064: GEORGE HERALD & MANDI BOTHA

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Mandi Botha'; 'George News'; 'Pauline Lourens'; 'Lindie Joubert'; 'Shirley Coetzee'; 'Lo-An Nel Breytenbach'; 'Suzette Herrer'; 'Lucinda Viljoen'; 'Melissa Hulls'; 'Lizette da Silva'; 'Michelle Pienaar'; 'Ilse Schoonraad'; 'Jannie Meyer'; 'Anica Kruger'; 'Yvonne Botha'; 'Mr. Steyn' Subject: CCT #06-11: Respondent: [63] & [64] GEORGE HERALD & M. BOTHA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

THE GEORGE HERALD MANDI BOTHA

Sixty-Third and Sixty-Fourth Respondents Ms. Mandi Botha Editor: George Herald PO Box 806, George, 6539 Tel: (044) 874 2424 Fax: (044) 874 1393 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached:

* Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 8:50 PM To: 'Mr. Steyn'; 'Mandi Botha'; 'George News'; 'Pauline Lourens' Subject: Att: George Herald Editor: Ms. Mandi Botha; RE: CCT #06-11: Respondent: [63] & [64] GEORGE HERALD & M. BOTHA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: Ms. Botha / Mr. Steyn, George Herald TO: TO:

THE GEORGE HERALD MANDI BOTHA

Sixty-Third and Sixty-Fourth Respondents Ms. Mandi Botha Editor: George Herald PO Box 806, George, 6539

Tel: (044) 874 2424 Fax: (044) 874 1393 Please acknowledge receipt of documentation sent 22 January 2011, herewith resent for the attention of Ms. Botha and George Herald. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za [CONTENT AS ORIGINAL]

Telephoned GEORGE HERALD (044) 874 2424) on 27 January 2011 at 12:34 hrs, and spoke to Ms. Mandi Botha who acknowledged receipt of documentation.

From: George Herald Editorial [mailto:grjnews@groupeditors.co.za] Sent: Thursday, January 27, 2011 12:30 PM To: Lara Johnstone Subject: Read: George Herald Editor: Ms. Mandi Botha; RE: CCT #06-11: Respondent: [63] & [64] GEORGE HERALD & M. BOTHA; Concourt Service per Electronic Mail This is a receipt for the mail you sent to "'Mr. Steyn'" <mielies@ctp-mail.co.za>; "'Mandi Botha'" <mandi@groupeditors.co.za>; "'George News'" <grjnews@ctp-mail.co.za>; "'Pauline Lourens'" <paulinel@groupeditors.co.za> at 26/01/2011 20:49 This receipt verifies that the message has been displayed on the recipient's computer at 27/01/2011 12:30

065 & 066: IND. ON SATURDAY & TREVOR BRUCE

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:30 AM To: 'Trevor Bruce'; 'Luvoyo Mjekula'; 'Quinton Mtyala'; 'Greg Arde' Subject: CCT #06-11: Respondent: [65] & [66] IND. ON SAT. & TREVOR BRUCE; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

INDEPENDENT ON SATURDAY

TO:

TREVOR BRUCE

Sixty-Fifth and Sixty-Sixth Respondents Mr. Trevor Bruce News Editor: Independent on Saturday PO Box 47549, Greyville, 4023 Tel: (031) 308 2934 / 2381 Fax: (031) 308 2111 / 2185 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Greg Arde [mailto:greg.arde@inl.co.za] Sent: Saturday, January 22, 2011 9:33 AM

To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [65] & [66] IND. ON SAT. & TREVOR BRUCE; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 9:33:05 AM (GMT+02:00) Harare, Pretoria.

From: Quinton Mtyala [mailto:quinton.mtyala@inl.co.za] Sent: Sunday, January 23, 2011 11:08 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [65] & [66] IND. ON SAT. & TREVOR BRUCE; Concourt Service per Electronic Mail Importance: High Your message was read on Sunday, January 23, 2011 11:08:06 AM (GMT+02:00) Harare, Pretoria.

From: Luvuyo Mjekula [mailto:luvuyo.mjekula@inl.co.za] Sent: Sunday, January 23, 2011 11:44 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [65] & [66] IND. ON SAT. & TREVOR BRUCE; Concourt Service per Electronic Mail Importance: High Your message was read on Sunday, January 23, 2011 11:44:03 AM (GMT+02:00) Harare, Pretoria.

Telephoned INDEPENDENT ON SATURDAY ((031) 308 2934 / 2381), on 27 January 2011, at 12:52 hrs, and spoke to Newsdesk who informed me that Debbie Yunnie was the secretary for both NewsDay and Independent on Saturday.

067 & 068: RADIO 702 & PHELADI GWANGWA

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Pheladi Gwangwa'; 'pheladi@primedia.co.za'; 'News'; '702 Eyewitness News'; 'Bruce Whitfield'; 'Kieno Kammies'; 'Robin Clark'; 'John Robbie'; 'Lynne O’Connor'; 'David O’Sullivan' Subject: CCT #06-11: Respondent: [67] & [68] RADIO 702 & P. GWANGWA; Concourt

Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

RADIO 702 PHELADI GWANGWA Sixty-Seventh and Sixty-Eighty Respondents Ms Pheladi Gwangwa Station Manager: 702 Radio PO Box 5572, Rivonia, 2128 Tel: (011) 506 3702 | Fax: (011) 506 3670

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: 702 Eyewitness News [mailto:News@ewn.co.za] Sent: Saturday, January 22, 2011 4:11 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [67] & [68] RADIO 702 & P. GWANGWA; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 4:10:40 AM (GMT+02:00) Harare, Pretoria.

From: Pheladi Gwangwa [mailto:Pheladi@primedia.co.za] Sent: Monday, January 24, 2011 10:25 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [67] & [68] RADIO 702 & P. GWANGWA; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 4:57:58 PM (GMT+02:00) Harare, Pretoria.

069 & 070: RAPPORT & LISA ALBRECHT

SEE MEDIA 24 RESPONDENTS

071 & 072: SATURDAY STAR & BRENDAN SEERY

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Star News'; 'Brendan Seery'; 'Thandi Mabuza'; 'Anel Lewis'; 'Mthunzi Mbatha' Subject: CCT #06-11: Respondent: [71] & [72] SAT. STAR & B. SEERY; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SATURDAY STAR BRENDAN SEERY

Seventy-First and Seventy-Second Respondents Mr. Brendan Seery Executive Editor: Saturday Star

PO Box 1014, Johannesburg, 2000 Tel: (011) 633 2792 |

Fax: (011) 633 2794 / 838 3019

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Mthunzi Mbatha [mailto:mthunzi.mbatha@inl.co.za] Sent: Saturday, January 22, 2011 3:23 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [71] & [72] SAT. STAR & B. SEERY; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 3:22:31 PM (GMT+02:00) Harare, Pretoria.

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.

073 & 074: SOWETAN & BONGANI KESWA

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Bongani Keswa'; 'Editor – Sowetan'; 'Lorraine Mofokeng'; 'Thuli Zungu'; 'Edward Tsumele' Subject: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

SOWETAN BONGANI KESWA

Seventy-Third and Seventy-Fourth Respondents Mr. Bongani Keswa Editor In Chief: Sowetan PO Box 6663, Johannesburg, 2000 Tel: (011) 471 4000 | Fax: (011) 474 8834 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY – SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Thuli Zungu [mailto:zungut@sowetan.co.za] Sent: Monday, January 24, 2011 7:43 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 7:42:56 AM (GMT+02:00) Harare, Pretoria.

From: Edward Tsumele [mailto:Tsumelee@sowetan.co.za] Sent: Monday, January 24, 2011 9:47 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High Your message was read on Monday, January 24, 2011 9:47:29 AM (GMT+02:00) Harare, Pretoria.

From: Lorraine Mofokeng [mailto:lorrainem@sowetan.co.za] Sent: Monday, January 24, 2011 10:56 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High

Your message was read on Monday, January 24, 2011 10:55:51 AM (GMT+02:00) Harare, Pretoria.

Telephoned the SOWETAN ((011) 280 3000) on 27 January 2011 at 14:40 hrs and spoke to a news employee who informed me Mr. Keswaâ&#x20AC;&#x2122;s secretary is Ms. Loretta Ndlovu (lorettan@sowetan.co.za), but her line just rang.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 2:51 PM To: 'Keswa Secretary: Loretta Ndlovu' Subject: Att: Mr. B. Keswa, c/o Ms. L. Ndlovu, Sowetan; RE: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High Mr. Bongani Keswa c/o Ms. Loretta Ndlovu Ms. Ndlovu, Please can you forward the attached documentation, sent to Mr. Keswa on 22 January 2011 (as below), and confirm receipt. It is Constitutional Court legal documentation for his attention as a respondent, if he wishes to object to any of the orders requested. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Loretta Ndlovu SWTN [mailto:LorettaN@sowetan.co.za] Sent: Thursday, January 27, 2011 3:37 PM To: Lara Johnstone Subject: Read: Mr. B. Keswa, c/o Ms. L. Ndlovu, Sowetan; RE: CCT #06-11: Respondent: [73] & [74] SOWETAN & B. KESWA; Concourt Service per Electronic Mail Importance: High Your message was read on Thursday, January 27, 2011 3:36:45 PM (GMT+02:00) Harare, Pretoria.

075 & 076: THE HERALD & JEREMY MCCABE

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Jeremy McCabe'; 'The Herald'; 'L Makungan'; 'Avusa'; 'Estelle Kerrane'; 'Shawn M'; 'Circulation Manager'; 'Avusa Group Secretary Joanne Matisonn' Subject: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO: TO:

THE HERALD JEREMY MCCABE

Seventy-Fifth and Seventy-Sixth Respondents Mr Jeremy McCabe Editor in Chief: The Herald Private Bag X 6071, Port Elizabeth, 6000 Tel: (041) 504 7911 Fax: (041) 585 4966 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address.

From: Joanne Matisonn [mailto:MatisonnJ@avusa.co.za] Sent: Saturday, January 22, 2011 3:22 AM To: Lara Johnstone Subject: Out of Office: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail I am out of the office from Monday 24 January to Friday 28 January 2011. In my absence, please contact Diane Wulff on 011 340-9561 or Nana Moloto on 011 340-9421.

From: Clifford Fram [mailto:framc@avusa.co.za] Sent: Saturday, January 22, 2011 8:16 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 8:16:18 AM (GMT+02:00) Harare, Pretoria.

C From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 9:20 PM To: 'robertsonh@avusa.co.za' Subject: Att: Ms. Heather Robertson, The Herald; RE: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail Importance: High

Per Electronic Mail: TO: TO:

THE HERALD JEREMY MCCABE

Seventy-Fifth and Seventy-Sixth Respondents Ms. Heather Robertson

Editor: The Herald Private Bag X 6071, Port Elizabeth, 6000 Tel: (041) 504 7911 Fax: (041) 585 4966 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Heather Robertson [mailto:robertsonh@avusa.co.za] Sent: Thursday, January 27, 2011 12:15 AM To: Lara Johnstone Subject: Read: Ms. Heather Robertson, The Herald; RE: CCT #06-11: Respondent: [75] & [76] THE HERALD & J. MCCABE; Concourt Service per Electronic Mail Importance: High

Your message was read on Thursday, January 27, 2011 12:15:13 AM (GMT+02:00) Harare, Pretoria.

077 & 078: VOLKSBLAD & AINSLEY MOOS

SEE MEDIA 24 RESPONDENTS

079: ROB AMNER, RHODES SCHOOL OF JOURNALISM From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Email: Rod Amner'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Prof. Anthea Garman'; 'Nicky Cocroft'; 'Simon Pamphilon'; 'Simwogerere Kyazze' Subject: CCT #06-11: Respondent: [79] PROF. ROD AMNER, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

ROD AMNER Seventy-Ninth Respondent Prof. Rod Amner Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: R.Amner@ru.ac.za [mailto:R.Amner@ru.ac.za] Sent: Saturday, January 22, 2011 2:36 PM To: Lara Johnstone Subject: Re: CCT #06-11: Respondent: [79] PROF. ROD AMNER, RHODES JOURNALISM; Concourt Service per Electronic Mail Hi Lara, I am not a professor. Correct title and name: Mr Rod Amner. It is a great pity that you don't use your time and energies making a more useful contribution to your country. Rod

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 3:11 PM To: 'R.Amner@ru.ac.za' Subject: RE: CCT #06-11: Respondent: [79] PROF. ROD AMNER, RHODES JOURNALISM; Concourt Service per Electronic Mail Mr. Amner, My apologies, I shall correct your title. I imagine your definition of 'useful' and mine are not the same. According to my definition I am doing so.

If you could provide more constructive clear feedback criticism, to your meaning of 'useful', I would be more than happy to make an impartial enquiry and if your evidence for your argument shows your suggestion to be more useful than my current meaning and definition, I have no problem changing it. Please feel free to let me know your definition of 'useful contribution to your country'. Respectfully, Lara Johnstone

080: ROBERT BRAND, RHODES SCHOOL OF JOURNALISM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Email: Robert Brand'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Prof. Herman Wasserman'; 'Prof. Jeanne Prinsloo'; 'Prof. Larry Strelitz' Subject: CCT #06-11: Respondent: [80] PROF. ROBET BRAND, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

ROBERT BRAND Eightieth Respondent Prof. Robert Brand Pearson Chair of Economics Journalism Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 9:39 PM To: 's.fourie@ru.ac.za' Subject: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation Dr. Stephen Fourie Registrar of Rhodes University Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27-046-603-8276 Fax: +27-046-603-8300 Email: registrar@ru.ac.za Dear Dr. Fourie, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and

acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 3:02 PM To: 'registrar@ru.ac.za' Subject: Att: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation Dr. Stephen Fourie Registrar of Rhodes University Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27-046-603-8276 Fax: +27-046-603-8300 Email: registrar@ru.ac.za Dear Dr. Fourie, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 3:04 PM To: 'a.stander@ru.ac.za' Subject: Att: Mr. Ashley Stander, Media Liaison Off. Rhodes Univ; RE: Rhodes School of Journalism & Media Legal Documentation Ashley Stander Media Liaison Officer: Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27 (0)46 603 8513 Fax: +27 (0)46 603 8744 Email: a.stander@ru.ac.za Dear Mr. Stander, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

a.stander@ru.ac.za

Subject: Att: Mr. Ashley Stander, Media Liaison Off. Rhodes Univ; RE: Rhodes School of Journalism & Media Legal Documentation Sent: 1/27/2011 3:04 PM was read on 1/27/2011 3:15 PM.

081: GUY BERGER: RHODES SCHOOL OF JOURNALISM From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Guy Berger'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Dr. Lynette Steenveld'; 'Reg Rumney' Subject: CCT #06-11: Respondent: [81] GUY BERGER, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

GUY BERGER Eighty-First Respondent Prof. Guy Berger Head of School Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

Ashley Stander Media Liaison Officer: Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27 (0)46 603 8513 Fax: +27 (0)46 603 8744 Email: a.stander@ru.ac.za Dear Mr. Stander, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

From: Ashley Stander [mailto:a.stander@ru.ac.za] Sent: Thursday, January 27, 2011 3:15 PM To: 'Lara Johnstone' Subject: Read: Mr. Ashley Stander, Media Liaison Off. Rhodes Univ; RE: Rhodes School of Journalism & Media Legal Documentation Your message To: a.stander@ru.ac.za Subject: Att: Mr. Ashley Stander, Media Liaison Off. Rhodes Univ; RE: Rhodes School of Journalism & Media Legal Documentation Sent: 1/27/2011 3:04 PM was read on 1/27/2011 3:15 PM.

082: HARRY DUGMORE: RHODES SCHOOL OF JOURNALISM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Harry Dugmore'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Jude Mathurine'; 'Khaya Thonjeni' Subject: CCT #06-11: Respondent: [82] PROF. HARRY DUGMORE, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

HARRY DUGMORE Eighty-Second Respondent Prof. Harry Dugmore MTN Chair of Media and Mobile Communication Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address.

Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27 (0)46 603 8513 Fax: +27 (0)46 603 8744 Email: a.stander@ru.ac.za Dear Mr. Stander, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

083: HAROLD GESS, RHODES SCHOOL OF JOURNALISM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Harold Gess'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Jenny Gordon'; 'Paul Greenway' Subject: CCT #06-11: Respondent: [83] HAROLD GESS, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

HAROLD GESS Eighty-Third Respondent Lecturer Harold Gess Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se

Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 3:02 PM

To: 'registrar@ru.ac.za' Subject: Att: Dr. Stephen Fourie, Rhodes Registrar; RE: Rhodes School of Journalism & Media Legal Documentation Dr. Stephen Fourie Registrar of Rhodes University Rhodes University Lucas Avenue Grahamstown, 6139 South Africa Telephone: +27-046-603-8276 Fax: +27-046-603-8300 Email: registrar@ru.ac.za Dear Dr. Fourie, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

Dear Mr. Stander, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

084: JANE DUNCAN, RHODES SCHOOL OF JOURNALISM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Jane Duncan'; 'Rhodes Journalism'; 'registrar@ru.ac.za'; 'Chris Kabwato'; 'Nqobile Buthelezi'; 'Sibusiso Mtshali' Subject: CCT #06-11: Respondent: [84] PROF. JANE DUNCAN, RHODES JOURNALISM; Concourt Service per Electronic Mail Importance: High

Per Electronic Mail: TO:

JANE DUNCAN Eighty-Fourth Respondent Professor Jane Duncan Highway Africa Chair of Media and Information Society Rhodes School of Journalism and Media Studies Africa Media Matrix building Upper Prince Alfred Street Grahamstown, 6139 Tel: 046 603 7100 Fax: 046 603 7101

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

Grahamstown, 6139 South Africa Telephone: +27-046-603-8276 Fax: +27-046-603-8300 Email: registrar@ru.ac.za Dear Dr. Fourie, My apologies to bother again. The attached documentation was sent to Rhodes School of Journalism and Media Studies Professors/Lecturers: * Rod Amner (acknowledged receipt) * Robert Brand * Guy Berger * Harry Dugmore * Harold Gess * Jane Duncan Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

* * * * *

Robert Brand Guy Berger Harry Dugmore Harold Gess Jane Duncan

Only Mr. Rod Amner acknowledged receipt. Please could you forward the documentation to Prof. Brand, Berger, Dugmore, Gess and Duncan, and acknowledge receipt of service, as served upon aforementioned Rhodes School of Journalism and Media Studies Professors/Lecturers. Respectfully, Lara Johnstone APPLICANT PROPRIA PERSONA / PRO SE Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Email: jmcswan@mweb.co.za

085: ANTON HARBER, WITS SCHOOL OF JOURNALISM

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Anton Harber'; 'Big Media Sally'; 'Wits Journalism'; 'journinfo@wits.ac.za' Subject: CCT #06-11: Respondent: [85] PROF. ANTON HARBER, WITS JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

ANTON HARBER Eighty-Fifth Respondent

Professor Anton Harber Professor - Journalism and Media Studies Wits Journalism University of the Witwatersrand 1 Jan Smuts Avenue Braamfontein 2000 Johannesburg Tel: (011) 717 4028 Fax: 011 717 4081 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access dates shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Anton [mailto:anton@harber.co.za] Sent: Saturday, January 22, 2011 8:27 AM

To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [85] PROF. ANTON HARBER, WITS JOURNALISM; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 6:26:45 AM UTC.

086: FRANZ KRUGER, WITS SCHOOL OF JOURNALISM From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Franz Kruger'; 'editor@journalism.co.za'; 'journinfo@wits.ac.za' Subject: CCT #06-11: Respondent: [86] PROF. FRANZ KRUGER, WITS JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

FRANZ KRUGER Eighty-Sixth Respondent Professor Franz Kruger Senior lecturer in Journalism Wits Journalism University of the Witwatersrand 1 Jan Smuts Avenue Braamfontein 2000 Johannesburg Tel: (011) 717 4028 Fax: 011 717 4081

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 9:43 PM To: 'Franz Kruger' Cc: 'Pholiswa.Maseko@wits.ac.za' Subject: Att: Franz Kruger, Wits Journalism; RE: CCT #06-11: Respondent: [86] PROF. FRANZ KRUGER, WITS JOURNALISM; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 Please acknowledge receipt. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

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.

087: WILLIAM BIRD, MEDIA MONITORING AFRICA

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'William Bird'; 'info@mma.org.za'; 'Sandra Roberts'; 'William Bird'; 'George Kalu'; 'Media Monitoring'; 'Laura Fletcher'; 'Prinola Govenden' Subject: CCT #06-11: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

WILLIAM BIRD Eighty-Seventh Respondent William Bird Director & Ashoka Fellow Media Monitoring Africa Suite no.2, 22 Art Centre 6th Street Parkhurst (Johannesburg) Tel: +27 (0) 11 788 1278 Fax: +27 (0) 11 788 1289

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Wednesday, January 26, 2011 9:48 PM To: 'William Bird'; 'info@mma.org.za'; 'Sandra Roberts'; 'William Bird'; 'George Kalu'; 'Media Monitoring'; 'Laura Fletcher'; 'Prinola Govenden' Subject: Att: William Bird, Media Monitoring Africa; RE: CCT #06-11: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

Telephoned Media Monitoring Africa (MMA) at (011-788 1278), on 27 January 2011 at 15:14 hrs, and spoke to Mr. Ayabulela Poro, who said that Mr. William Bird as well as his admin officer were out at the moment, but that I could send him the documentation and he would forward it to Mr. Bird.

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Thursday, January 27, 2011 3:17 PM To: 'ayabulelap@mma.org.za' Subject: Att: William Bird, c/o Mr. Poro, Media Monitoring Africa; RE: CCT #06-11: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail Importance: High Mr. Ayabulela Poro, As per our telephone conversation a few minutes ago, please find the attached Constitutional Court documentation sent to Mr. Bird (see below) for his attention, and response should he object to any of the orders requested therein. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539 Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za

From: ayabulela poro [mailto:ayabulelap@mma.org.za] Sent: Thursday, January 27, 2011 4:38 PM Subject: Read: [!! SPAM] Att: William Bird, c/o Mr. Poro, Media Monitoring Africa; RE: CCT #06-11: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail Importance: High Your message To: ayabulela poro Cc: Subject: [!! SPAM] Att: William Bird, c/o Mr. Poro, Media Monitoring Africa; RE: CCT #06-11: Respondent: [87] WILLIAM BIRD; Concourt Service per Electronic Mail Sent: Thu, 27 Jan 2011 15:17:10 +0200 was read on Thu, 27 Jan 2011 16:37:47 +0200

088: PROJOURN STEERING COMMITTEE

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:54 AM To: 'Steering Committee General Secretary: Samantha Perry'; 'Michael Schmidt: Steering Committee Admin Secretary'; 'info@iaj.org.za'; 'Beauregard Tromp'; 'Michael Coetzee'; 'Greg Gordon'; 'Ray Joseph'; 'Monica Laganparsad'; 'Ebrahim Moolla'; 'Sholain Govender-Bateman'; 'Antoinette Lazarus'; 'Mandy de Waal'; 'Jan Hennop'; 'Cobus Bester'; 'Subry Govender'; 'Justin Arenstein'; 'Jedi Ramalapa'; 'Anso Thom'; 'Billings Siwila'; 'Matuba Mahlatjie' Subject: CCT #06-11: Respondent: [88] PROJOURN STEERING COMM.; Concourt Service per Electronic Mail Importance: High Per Electronic Mail: TO:

PROJOURN STEERING COMMITTEE Eighty-Eighth

Respondent

PROJOURN Steering Committee c/o: Michael Schmidt Exec. Director: Institute for the Advancement of Journalism 9 Jubilee Road Parktown, Johannesburg, 2193 Tel: +27 11 484 1765/6/7 Fax: +27 11 484 2282 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B)

From: Monica Laganparsad [mailto:LaganparsadM@sundaytimes.co.za] Sent: Saturday, January 22, 2011 9:21 AM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [88] PROJOURN STEERING COMM.; Concourt Service per Electronic Mail Importance: High Your message was read on Saturday, January 22, 2011 9:20:36 AM (GMT+02:00) Harare, Pretoria.

From: Ebrahim Moolla [mailto:Ebrahim@fhm.co.za] Sent: Saturday, January 22, 2011 7:34 PM To: Lara Johnstone Subject: Read: CCT #06-11: Respondent: [88] PROJOURN STEERING COMM.; Concourt Service per Electronic Mail Importance: High Your message To: Ebrahim Moolla Subject: CCT #06-11: Respondent: [88] PROJOURN STEERING COMM.; Concourt Service per Electronic Mail Sent: 22 January 2011 02:54:09 (UTC+02:00) Harare, Pretoria was read on 22 January 2011 19:34:01 (UTC+02:00) Harare, Pretoria.

MEDIA 24 RESPONDENTS 16-17: CITY PRESS & FERIAL HAFFAJEE; 21: ANDREW TRENCH; 36-37: NEWS 24 & JANNIE MOMBERG; 50-51: BEELD & TIM DU PLESSIS; 52-53: DAILY SUN & T.

KHUMALO; 54,55,56: DIE BURGER, H. JEFFERY & B. BOOYSEN; 61-62: FINWEEK & COLLEEN NAUDE; 77-78: VOLKSBLAD & AINSLEY MOOS

From: Lara Johnstone [mailto:jmcswan@mweb.co.za] Sent: Saturday, January 22, 2011 2:07 AM To: 'wdeklerk@telkomsa.net' Subject: CCT #06-11: MEDIA 24 RESPONDENTS; Concourt Service per Electronic Mail: Condonation Importance: High Per Electronic Mail: TO:

WILLEM DE KLERK ATTORNEYS Media 24 Respondents Attorneys P O Box 84162, Greenside, 2034 Tel: (011) 486 4505 Fax: (011) 486 4506 Email: wdeklerk@telkomsa.net

IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA Case No. CCT #06-11 RADICAL HONESTY â&#x20AC;&#x201C; SA 1st Applicant LARA JOHNSTONE 2nd Applicant

Please find attached: * Notice of Motion: Condonation * Affidavit: Lara Johnstone * Affidavit Annexures: (A) and (B) KINDLY TAKE NOTICE FURTHER that due to the number of respondents, to serve, this Condonation Notice of Motion, and the original Application Notice of Motion shall be considered as being officially served on all respondents as of Friday 28 January 2011; whereupon the Notice of Motion Application for Direct Access shall effectively start from, for Respondents response. TAKE NOTICE FURTHER that should any of the Respondents desire to oppose the granting of the orders prayed for in the notice of motion (Application for Direct Access), they shall: [14] Within 15 (fifteen) days after receipt of the notice of motion or any amendment thereof, deliver notice to the applicants of their intention to oppose and shall in such notice appoint an individual at which such party will accept notice and service of all process in such proceedings, which shall include the name of an individual responsible for receiving of service documentation by email, including their email address. [15] Within 30 (thirty) days after the expiry of the time referred to in sub-rule 53(4) of the Uniform Rules of Court, deliver any affidavits which they may desire in answer to the allegations made by the Applicants. Respectfully, LARA JOHNSTONE Litigant in Person, Pro Se Per: 16 Taaibos Ave George, 6539

Tel: (044) 870 7239 Cel: (071) 170 1954 Email: jmcswan@mweb.co.za