S v Mokhesi + 12 (Ace included)

IN THE HIGH COURT OF SOUTH AFRICA
FREE STATE PROVINCIAL DIVISION
CASE NO:
In the matter of:
THE STATE
Versus
NTHIMOTSE MOKHESI ACCUSED 1
A 61-year old male South African citizen residing at 5 Wild Olive Heights, Olive Hill,
Bloemfontein
MAHLOMOLA JOHN MATLAKALA ACCUSED 2
A 42-year old male South African citizen residing at
PHEAGANE EDWIN SODI ACCUSED 3
A 47-year old male South African citizen residing at 20 Mount Road, Bryanston
BLACKHEAD CONSULTING (Pty) Ltd ACCUSED 4
A private company with registration number 2011/011664/07
As represented by accused 2
DIAMOND HILL TRADING 71 (Pty) Ltd ACCUSED 5
As represented by Phikolomzi Ignatius Mpambani
605 CONSULTING SOLUTIONS (Pty) Ltd ACCUSED 6

As represented by
SELLO JOSEPH RADEBE ACCUSED 7
A 56 - year old male South African citizen residing at 36 Le Metriale, Hanptons Street,
Lonehill, Fourways, Johannesburg
MASTERTRADE 232 (Pty) Ltd ACCUSED 8
As represented by accused 7.
ABEL KGOTSO MANYEKI ACCUSED 9
A 38 -year old male South African citizen residing at 52 Savuti building, 200 Harvard
Avenue, Clubview, Pretoria
ORI GROUP (Pty) Ltd ACCUSED 10
As represented by accused 9.
THABANE WISEMAN ZULU ACCUSED 11
A 53-year old male South African citizen residing at 60 Nonnetjieseend Street,
Pretoriuspark, Pretoria
SARAH MATAWANA MLAMLELI ACCUSED 12
A 63-year old female South African citizen residing at 7 Lillyvale Estate, Bloemfontein
ELIAS MAGASHULE ACCUSED 13
A 61 – year old male South African citizen residing at 78 Van Wouw Street, Sasolburg
(Hereinafter referred to as “the accused”)

___________________
INDICTMENT
_______
PREAMBLE
WHEREAS:
Section 217(1) of the Constitution of the Republic of South Africa (“Constitution”)
require that, “When an organ of state in the national provincial or local sphere of
government or institution identified in national legislation, contracts for goods or services, it
must do so with a system which is fair, equitable, transparent, competitive and cost-
effective.”
The Public Finance Management Act 1 of 1999 (“PFMA”), applies to all National and
Provincial Government Departments and Public Entities listed in the schedules to the
PFMA. Therefore, the PFMA will be applicable to the Free State Provincial Department of
Human Settlements.
The National Treasury may make regulations or issue instructions (Practice Notes) in terms
of section 76(4) (c) of the PFMA, applicable to all institutions to which the PFMA applies.
In terms of Treasury Regulation 16A promulgated in Government Gazette number
27388, which came into effect on 15 March 2005 and read with Treasury Regulation
16A2.1 (a), this framework applies to all Departments. Treasury Regulation 16A6.1
require that the procurement of goods and services, either by way of quotations or through a

competitive bidding processes, must be within the threshold values as determined by the
National Treasury.
Practice Note number 8 of 2007/2008, was issued in terms of section 76 (4) (c), laying
down the thresholds. This Practice Note was issued and came into effect on 01 December
2007. The Practice Note stated that Accounting Officers (Heads of Departments) should
apply certain threshold values when procuring goods and services, hiring or letting anything,
acquiring or granting any right or disposing of movable state property.
In terms of Treasury Regulation 16A6.2, a supply chain management system must, in the
case of procurement through a bidding process, provide for-
 The adjudication of bids through a bid adjudication committee;
 The establishment, composition and function of bid specification, evaluation
and adjudication committees;
 The selection of bid adjudication committee members;
 Bidding procedures; and
 The approval of bid evaluation and/or adjudication committee
recommendations.
In terms of Treasury Regulation 16A6.3(c), the Accounting Officer (the Head of the
Department) must ensure that bids to supply services/goods are advertised in at least the
Government Tender Bulletin for a minimum period of 21 days before closure, except in
urgent cases when bids may be advertised for such shorter period as the accounting officer
may determine.
In terms of Treasury Regulation 16A6.3 (d), which also came into effect on 15 March
2005, the accounting officer must ensure that awards of contracts/tenders made subsequent
to advertising are published in the Government Tender Bulletin and in the media where the
bids were originally advertised.

In terms of Treasury Regulation 16A6.6, the accounting officer or accounting authority
may, on behalf of the department, constitutional institution or public entity, participate in
any contract arranged by means of a competitive bidding process by any other organ of
state, subject to the written approval of such organ of state and the relevant contractors.
Regulation 16A.8 sets out the ethical standards, which must be complied with by all
officials and other role players in the Supply Chain Management System. Inter alia, the
regulation requires that conflicts of interests be disclosed, that all suppliers be treated
equally and that official positions are not to be used for private gain or to improperly benefit
other persons.
Treasury Regulation 16A9.1(a), further provides that the accounting officer or accounting
authority must take all reasonable steps to prevent abuse of the supply chain management
System.
Section 38 of the PFMA places certain obligations on Accounting Officers:
 Section 38(1) (a) (iii) requires the Accounting Officer to implementation of
an appropriate procurement and provisioning system which is fair, equitable,
transparent, competitive and cost-effective.
 Section 38(1) (c) (ii) requires effective and appropriate steps to prevent
unauthorized, irregular and fruitless and wasteful expenditure and losses
resulting from criminal conduct.
 Section 38(n) stipulates that the Accounting Officer must comply, and
ensure compliance by the department, trading entity or constitutional
institution, with the provisions of this Act.
Section 44(2) (d) provides that a delegation or instruction to an official in terms of
subsection (1), does not divest the accounting officer of the responsibility concerning the
exercise of the delegated power or the performance of the assigned duty.

The Free State - Human Settlements Department falls within the Treasury framework
outlined above and the PFMA.
Practice Note SCM 4 of 2003 established a Code of Conduct for Supply Chain
Management officials, which requires all officials to comply with relevant legislation and
National Treasury Practice Notes and ensured that public resources are administered
responsibly. The Practice Note specifically requires that:
 Practitioners should not afford undue preference to any group or individual,
 Should declare conflicts of interest,
 Should not amend and tamper with any bid after its submission,
 Combative practices are prohibited and these include reference to non-
existing competition and lower fictitious quotes.
Accused 3 and 4 was appointed by the Gauteng – Human Settlements Department in
March 2014, for the asbestos eradication project. The first phase entailed an assessment to
be carried out from March 2014 to April 2014 at a rate of R 650-00 per house.
On or about 28 May 2014, accused 3 and 4 formed a joint venture with Diamond Hill
Trading 71 (Pty) Ltd and requested for an appointment on risk “Audit and assessment,
Handling of hazardous material (removal) and disposal of asbestos – contaminated rubble
in the Free State” The rates were outlined as “Door to door assessment = R1350-00 per
house, excluding vat”and “Removal and disposal to an approved designated site = R
32760-00, excluding vat”.
When a supplier submits proposals to an organ of state outside of normal procurement
processes, such proposals are considered unsolicited bids. National Treasury Practice
Note No 11 of 2008/2009, entitled unsolicited proposals, regulates and provides guidance
on how unsolicited bids should be handled by organs of state and defines an unsolicited bid

as “An unsolicited proposal/concept means any proposal/concept received by an institution
outside its normal procurement process … (a submission that must be innovative, unique
and provided by a sole supplier).”
Treasury Practice Note No 11 of 2008/2009, dictates that an organ of state “…are not
obliged to consider an unsolicited proposal but may consider such a proposal only if it meets
the following requirements:
(a) a comprehensive and relevant project feasibility study has established a clear business
case; and
(b) the product or service involves an innovative design; or
(c) the product or service involves an innovative approach to project development and
management; or
(d) the product or service presents a new and cost-effective method of service delivery.”
Treasury Practice Note No 11 of 2008/2009, further provides that “The accounting officer
or accounting authority must reject the unsolicited proposal if the proposal-
(a) relates to known institutional requirements that can, within reasonable and practicable
limits, be acquired by conventional competitive bidding methods;
(b) relates to products or services which are generally available;
(c) does not fall within the institution’s powers and functions;
(d) does not comply substantially with paragraph 2;
(e) has not been submitted by a duly authorised representative of the proponent; or
(f) contravenes the provisions of any law.”
Practice Note No 11 of 2008/2009, mandates that the Accounting Officer must reject an
unsolicited bid that relates to known institutional requirements that can be acquired through
conventional competitive bidding or that relates to services which are generally available
and must notify the proponent of such rejection by registered mail.
On 19 June 2014, accused 1, requested approval to participate on a contract of the National
Department of Human Settlement.

Treasury Regulation 16A6.6, provides that “The accounting officer or accounting
authority may, on behalf the department, constitutional institution or public entity,
participate in any contract arranged by means of a competitive bidding process by any other
organ of state, subject to the written approval of such organ of state and the relevant
contractors.”
Principles underpinning the implementation of regulation 16A6.6 are the following:
 The contract must have been secured by means of a competitive bidding
process applicable to that other organ of state.
 The other organ of state and the service provider must have consented to such
participation procurement in writing.
Salient requirements applicable to Regulation 16A6.6 are the following: Over and above
the requirements stated in Regulation 16A6.6, there are also other salient requirements
which must be considered by the participating organ of state as well as the organ of state
that is approving the procurement under its contract. These include the following:
 The contract must be valid: The participating organ of state becomes a participant
in an existing contract. The contract must therefore not have expired. The
participating organ of state should conclude an addendum to the agreement with the
service provider/s that stipulates the duration of the participation agreement, which
may not exceed the end date of the original contract.
 The duration or variation of the contract: The participating organ of state must
confirm the duration of the contract between the service provider/s and the other
organ of state and determine the remaining term of the contract. The contract cannot
be extended or varied by the participating organ of state. It can only be extended by
the original contracting parties in line with the contractual terms agreed to in the
original contract.

 The goods or services must be the same and the quantity may not be increased:
The participating organ of state must assess whether the goods or services being
provided to the other organ of state are similar to the goods or services required by
the participating organ of state. The goods or services required by the participating
organ of state must be the same as advertised, adjudicated and contracted by the
other organ of state and may not be increased.
On 15 July 2014, accused 1 requested participation on a contract between the Gauteng -
Human Settlements Department and Blackhead Consulting (Pty) Ltd, in terms of Treasury
Regulation 16A6.6. Accused 11 assisted with and participated in this process.
Approval for participation in terms of regulation 16A6.6 was granted by the Gauteng
Human Settlements Department on 04 August 2014.
The contract between the Gauteng - Human Settlement Department and Blackhead
Consulting (Pty) Ltd expired at the end of August 2014.
On 1 October 2014, accused 1 appointed accused 3/4/5 as a “professional resource team
for the eradication of asbestos in the free state province”. A service level agreement was
entered into between the Department of Human Settlements and accused 3/4/5. The contract
price amounted to R 255 000 000-00, due to accused 3/4/5. An “advance payment” was
made by the Department to accused 3/4/5 to the value of R 51 000 000-00.
Phikolomzi Ignatius Mpambani was the sole director of Diamond Hill Trading –
accused 5. Mpambani was murdered in 2017.
During August 2014 accused 3/4/5 subcontracted the work to accused 7/8 at a cost of R
44 208 856-79.
During October 2014, accused 7/8 further subcontracted the work to accused 9/10 at a cost
of R 21 391 489-30.

The State alleges that a legal duty existed on accused 1, 2, 11, 12 and 13 to comply with the
stipulations in the PFMA as well as the Treasury Regulations. The State further alleges
that a legal duty existed on accused 1, 2, 11, 12 and 13 to disclose the deviations from
and/or noncompliance with Departmental prescripts, stipulations in the PFMA and the
Treasury regulations and/or to disclose the personal and/or business relationship between
themselves and accused 3 and/or Ignatius Mpambani and/or companies which they were
involved in or owned.
The Executive Members’ Ethics Act 82 of 1998 as well as Proclamation number 41 of
28 July 2000 (Government Gazette no. 21399) is applicable to and binding on accused 12
and 13.
At all relevant times accused 12 was the Member of the Executive Council (MEC) of the
Department of Human Settlements in the Free State province and accused 13 the Premier
of the Free State province.
On 26 June 2014 accused 13 delivered the State of the Province (Free State) address in
Bloemfontein in his capacity as Premier of the province. In his speech he made mention of
the eradication of asbestos roofing project in the Free State which would take place from
2014 to 2019.
Sections 133 and 136 of the Constitution are applicable to and binding on accused 12 and
13:
Section 133 of the Constitution prescribes the accountability and responsibilities of
Members of the Executive Council;
Section 133(2) prescribes that the Members of the Executive Council are individually and
collectively accountable to the Legislature for the exercise of their powers and the
performance of their functions;
Section 133(3)(a) prescribes that a MEC must act in accordance with the Constitution;

Section 136 of the Constitution deals with the conduct of Members of the Executive
Council;
Section 136(1) prescribes that a MEC must act in accordance with a Code of Ethics
prescribed by national legislation.
Section 136 (2)(b) prohibits conduct which is in any way inconsistent with their office, or
conduct which could expose themselves to any situation involving the risk of a conflict
between their official responsibilities and private interests;
Section 136 (2)(c) prohibits the use of their position entrusted to them, to enrich themselves
or improperly benefit any other person.
Sections 125 to 132 of the Constitution are applicable and binding on accused 13.
Sections 125 and 132 are also applicable and binding on accused 12.
Section 125 refers to the “executive authority of provinces”.
Section 127 refers to the “powers and functions of Premiers”.
Section 132 refers to the “executive councils”.
Section 1 (b) of the PFMA defines “executive authority”, and means, in relation to a
provincial department, the Member of the Executive Council of the province who is
accountable to the Provincial Legislature. Therefore section 1 (b) is applicable and binding
on accused 12 and 13.
In March 2009, the Policy Guideline of Supply Chain Management for the Free State
Provincial Government was issued and reviewed in November 2014. The prescripts
therein were binding on accused 1 and 2 at all relevant times.
On 6 May 2015, accused 1 approved and signed the Financial Management Policy –
Management of Supply Chain for the Department of Human Settlements, Free State
Province. The prescripts therein were binding on accused 1 and 2 at all relevant times.

On 31 July 2015 the Auditor – General submitted a report to the Free State Legislature on
the Department of Human Settlements. In this report, the contract between accused 4/5
and the Department of Human Settlements was found to be irregularly procured.
During July 2015 the Democratic Alliance (DA) brought an application in the Free State
High Court wherein accused 1 and 12 were the respondents. The basis for the application
was inter alia that the contract between the Department of Human Settlements and
accused 3/4/5 was irregular and that no further payments by the Department should be
made.
After the report by the Auditor General and the application by the DA, further amounts
totaling R 139 000 000-00 was paid by the Department to accused 3/4/5. A summary of
these payments and further payments to other entities and individuals is as follows:
1. In December 2014 the Department processedpayment in favor of Blackhead to
the value of R 20 000 000.00. This amount reflected in the FNB account number
62498704933 of Diamond Hill Trading on 22 December 2014.
2. In December 2014, Blackhead processed payment in favor of 605 Consulting
Solutions to the value of R 3 500 000.00. This amount reflected in the FNB account
number 62509451100 on 23 December 2014.
3. In December 2014, Blackhead processed payment in favor of Blackhead Consulting
to the value of R 3 200 000.00. This amount reflected in the ABSA account number
9182714467 on 23 December 2014.
4. In December 2014, Blackhead processed payment in favor of Mastertrade 232 to the
value of R 13 283 427.16. This amount reflected in the FNB account number
62457177113 on 23 December 2014.

5. In January 2015 the Department processed payment in favor of Blackhead to
62498704933 on 15 January 2015.
6. In January 2015, Blackhead processed payment in favor of 605 Consulting Solutions
to the value of R 8 750 000.00. This amount reflected in the FNB account number
62509451100 on 16 January 2015.
7. In January 2015, Blackhead processed payment in favor of Blackhead Consulting to
the value of R 18 250 000.00. This amount reflected in the ABSA account number
9182714467 on 16 January 2015.
9182714467 on 16 January 2015.
9. In March 2015 the Department processed payment in favor of Blackhead to the
62498704933 on 26 March 2015.
10. In March 2015, Blackhead processed payment in favor of 605 Consulting Solutions
62509451100 on 27 March 2015.
11. In March 2015, Blackhead processed payment in favor of 605 Consulting Solutions
62509451100 on 27 March 2015.
12. In March 2015, Blackhead processed payment in favor of Diamond Hill Trading to
62303179544 on 27 March 2015.

13. In March 2015, Blackhead processed payment in favor of Blackhead Consulting to
9182714467 on 28 March 2015.
14. In March 2015, Blackhead processed payment in favor of Blackhead Consulting to
9182714467 on 28 March 2015.
15. In March 2015, Blackhead processed payment in favor of Mastertrade 232 to the
62457177113 on 27 March 2015.
16. In June 2015 the Department processed payment in favor of Blackhead to the
62498704933 on 4 June 2015.
17. In June 2015, Blackhead processed payment in favor of 605 Consulting Solutions to
62509451100 on 5 June 2015.
18. In June 2015, Blackhead processed payment in favor of Diamond Hill Trading to the
62303179544 on 5 June 2015.
19. In June 2015, Blackhead processed payment in favor of Blackhead Consulting to the
value of R 6 050 000.00. This amount reflected in the ABSA account number
9182714467 on 5 June 2015.
20. In June 2015, Blackhead processed payment in favor of Mastertrade 232 to the value
of R 3 500 000.00. This amount reflected in the FNB account number 62457177113
on 5 June 2015.

21. In August 2015 the Department processed payment in favor of Blackhead to the
62498704933 on 11 August 2015.
22. In August 2015, Blackhead processed payment in favor of 605 Consulting Solutions
62509451100 on 11 August 2015.
23. In August 2015, Blackhead processed payment in favor of Diamond Hill Trading to
62303179544 on 11 August 2015.
24. In August 2015, Blackhead processed payment in favor of Blackhead Consulting to
9182714467 on 11 August 2015.
25. In August 2015, Blackhead processed payment in favor of Mastertrade 232 to the
62457177113 on 11 August 2015.
26. In January 2016 the Department processed payment in favor of Blackhead to
62498704933 on 28 January 2016.
9182714467 on 29 January 2016.
28. In January 2016, Blackhead processed payment in favor of Mastertrade 232 to the
value of R 600 000.00. This amount reflected in the FNB account number
62457177113 on 29 January 2016.

29. In February 2016, Blackhead processed payment in favor of 605 Consulting
Solutions to the value of R 4 681 500.00. This amount reflected in the FNB account
number 62509451100 on 1 February 2016.
30. In April 2016 the Department processedpayment in favor of Blackhead to the
62498704933 on 28 April 2016.
31. In April 2016, Blackhead processed payment in favor of 605 Consulting Solutions to
62509451100 on 28 April 2016.
32. In April 2016, Blackhead processed payment in favor of Blackhead Consulting to the
value of R 7 500 000.00. This amount reflected in the ABSA account number
9182714467 on 28 April 2016.
33. In August 2016 the Department processed payment in favor of Blackhead to the
62498704933 on 4 August 2016.
34. In August 2016, Blackhead processed payment in favor of 605 Consulting Solutions
62509451100 on 4 August 2016.
35. In May 2015 Blackhead Consulting processed payment in favor of SMD to the value
of R 1 000 000.00. This was paid from the ABSA account number 4079288727 of
Blackhead Consulting on 26 May 2015.
36. In December 2015 accused 3 processed payment in favor of SMD to the value of R
600 000.00. This was paid from the FNB account number 62434818524 of accused 3
on 21 December 2015.

In correspondence with the Department of Human Settlements, the following different
names were used when referring to the service provider, namely Blackhead:
i. Blackhead Consulting;
ii. Blackhead Consulting, trading as Diamond;
iii. Blackhead Diamond Hill Trading 71 Consulting;
iv. Blackhead Consulting Diamond Hill Trading 71;
v. Blackhead Consulting (Pty) LTD;
vi. Blackhead Consulting (Pty) LTD JV;
vii. Blackhead Consulting, trading as Diamond Trading;
viii. Blackhead Consulting, trading as Diamond Hill;
ix. Blackhead Consulting and Diamond Hill Trading 71;
x. Blackhead JV;
xi. Diamond Hill Trading 71 / Blackhead JV;
xii. Diamond Hill Trading 71 Blackhead JV;
xiii. Blackhead Consulting (Pty) LTD Joint-Venture; and
ix. Blackhead Consulting (PTY) LTD and Diamond Hill Trading 71 (Pty) LTD Joint -
Venture.
All aspects relating to asbestos are governed by the Asbestos Regulations of 2001,
promulgated under section 43 of the Occupational Health and Safety Act 85 of 1993.
Regulation 7 of the Asbestos Regulations dictates that the person(s) conducting the
assessment of potential exposure to asbestos should be conversant with the work
environment, the processes relating to the asbestos work to be performed and the risks
associated with asbestos exposure. In addition, assessments must be conducted in
consultation with health and safety representatives or committee to ensure that their inputs
are taken into consideration and ensure transparency. The assessment of potential asbestos
exposure is a complex scientific process. Accused 3, 4, 5, 7, 8, 9, and 10 did not adhere to
any of the mentioned prescripts, nor did any of them consult the South African Institute for
Occupational Hygiene. Accused 1, 2, 11 and/or 12 did not ensure that the law pertaining to

asbestos was followed and adhered to and did not ensure that proper and competent persons
and/or companies were appointed.
Accused 3, 4, 5, 7, 8, 9, and 10 did not share information and conduct proper training to
employees as prescribed in Regulation 5.
Now the State, as represented by the Director of Public Prosecutions, will allege that
Accused 1 to 13 are guilty of the crimes of:
COUNT 1 TO 8: FRAUD:
FIRST ALTERNATIVE COUNT TO COUNT 1 TO 8: THEFT:
SECOND ALTERNATIVE COUNT TO COUNT 1 TO 8: ATTEMPTED THEFT
THIRD ALTERNATIVE COUNT TO COUNT 1 TO 8: FAILURE TO REPORT
CORRUPT TRANSACTIONS - CONTRAVENTION OF SECTION 34 OF ACT 12
OF 2004:
COUNT 9: CORRUPTION – CONTRAVENTION OF SECTION 3 OF ACT 12 OF
2004:
ALTERNATIVE COUNT TO COUNT 9: CORRUPTION – CONTRAVENTION OF
SECTION 4 OF ACT 12 OF 2004:
2004:
SECTION 4 OF ACT 12 OF 2004
2004:

2004:
2004:
2004:
2004:
FIRST ALTERNATIVE COUNT TO COUNT 15: CORRUPTION –
CONTRAVENTION OF SECTION 4 OF ACT 12 OF 2004:
SECOND ALTERNATIVE COUNT TO COUNT 15: CORRUPTION –
2004:

2004:
2004:
2004:
COUNT 20: CONTRAVENTION OF SECTION 86 OF THE PUBLIC FINANCE
MANAGEMENT ACT 1 OF 1999 (PFMA):
COUNT 21 TO 66: CONTRAVENTION OF SECTION 4 (a) AND/OR (b), READ
WITH SECTIONS 1 AND 8 OF THE PREVENTION OF ORGANISED CRIME ACT
121 OF 1998 – MONEY LAUNDERING;
Section 51 (2) of Act 105 of 1997 applies to counts 1 to 14.

COUNT 1 TO 8: FRAUD:
In that during the period 2014 to 2015 and at near Bloemfontein, in the district of
Bloemfontein, the accused individually or collectively, acting in the furtherance of a
common purpose with their co-accused and/or persons unknown to the State and/or
representatives acting on their behalf, unlawfully, falsely and with the intent to defraud,
explicitly or tacitly, through words or conduct and/or failed to act, pretended to the
Department of Human Settlements and/or the Treasury Department and/or the State that:
 The contract between the Department of Human Settlements, Free State, and
accused 3/4/5 and subcontracts between accused 3/4/5 and 7/8/9/10 were legitimate
contracts in terms of the policies, procedures, prescripts and legislation as outlined in
the preamble and/or
 All proper procurement processes as prescribed by legislation, guidelines and
policies (as outlined in the preamble) were followed in awarding the contract to
accused 3/4/5 and/or
 Accused 1, 2, 11, 12 and 13 had no personal or financial interest in the awarding of
the contract to accused 3/4/5 and/or 7/8/9/10 and/or
 All monies paid over and received by accused 3/4/5 and/or 7/8/9/10 were legally
due and not the subject or result of any unlawful practices and/or
 The work that formed the basis of the contracts was completed and/or done properly
and cost effective and/or the Department received value for money and/or
 Accused 3/4/5 was entitled to and could legally subcontract with accused 7/8,
without disclosing such fact to the Department and/or

 Accused 7/8 was entitled to and could legally subcontract to accused 9/10 without
disclosing such fact to the Department and/or
 Accused 3/4/5 and/or 7/8/9/10 were entitled and/or allowed by law to conduct the
work in respect of asbestos stipulated in the contracts and/or
 No prices and/or fees were inflated and/or no stipulations of the contract were altered
and/or
Whereas the accused, when they made such misrepresentations individually or collectively
and/or together with representatives and/or unknown individuals acting on their behalf,
knew that:
 The contract between the Department of Human Settlements and accused 3/4/5 and
subcontracts between accused 3/4/5 and 7/8/9/10 were illegal and irregular and/or
 Proper procurement processes as outlined in the preamble were not followed and
adhered to and/or
 Accused 1, 2, 11, 12 and 13 had personal or financial interest in the awarding of the
contracts and/or
 The payment of R 230 million to accused 3/4/5 and subsequent payments by
accused 3/4/5 to accused 7/8 and by accused 7/8 to accused 9/10 were not legally
due and/or were the result of unlawful practices and/or
 The work was not done properly and/or completed and was not cost effective and/or
 Accused 3/4/5 and/or 7/8/9/10 were not entitled and/or allowed by law to conduct
the work as stipulated in the contracts and/or

 Accused 1 and/or 2 and/or 11 were not entitled and/or allowed to appoint accused
3/4/5 and accused 3/4/5 not entitled and/or allowed to subcontract accused 7/8
and/or accused 7/8 to subcontract accused 9/10 and/or had to disclose such facts to
the Department and/or
 The contract price was inflated from R 650-00 per house to R 850-00 per house
and/or
 Discrepancies existed regarding the services to be rendered in terms of the contract;
The unsolicited proposal and the letter of appointment created the impression that
the appointment was for the assessment, removal of asbestos material and the
replacement of asbestos roofs; The Service Level Agreement only referred only to
assessment and removal; The Instruction to Perform Work was only issued for the
assessment; whereas the contract price remained the same.
AND through the aforementioned misrepresentations and/or omissions, the accused
individually and/or collectively persuaded the Department of Human Settlements and/or the
Treasury Department and/or the State, to its actual or potential prejudice, to award the
contract as outlined in the preamble and to pay an amount of R 230 million of a total
contract amount of R 255 million, to the accused as outlined in the preamble.
FIRST ALTERNATIVE COUNT TO COUNT 1 TO 8: THEFT:
In that at the time and place mentioned in the main count, the accused unlawfully and
intentionally stole R 230 million, the property of the State.
SECOND ALTERNATIVE COUNT TO COUNT 1 TO 8: ATTEMPTED THEFT:

In that at the time and place mentioned in the main count, the accused unlawfully and
intentionally attempted to steal R 25 million, the property of the State.
THIRD ALTERNATIVE COUNT TO COUNT 1 TO 8: FAILURE TO REPORT
CORRUPT TRANSACTIONS - CONTRAVENTION OF SECTION 34 OF ACT 12
OF 2004:
- Only against accused 1, 2, 11, 12 and 13.
That the accused are guilty of the crime of corruption in contravention of section 34 (1) (a)
and/or (b) and/or (iv), read with sections 1, 2, 20, 21, 24, 25, 26, 34 (2) and 34 (4) of the
Prevention and Combating of corrupt activities Act 12 of 2004:
In that at the time and place mentioned in the main count, the accused, who held positions of
authority as outlined in the preamble, and who knew or ought reasonably to have known or
suspected that any other person has committed –
(a) An offence under Part 1, 2, 3 or 4, or section 20 or 21 (in as far as it relates to the
aforementioned offences) of Chapter 2; or
(b) The offence of theft, fraud, extortion, forgery or uttering a forged document,
involving an amount of R 100 000-00 or more, directly or indirectly and individually
or collectively, wrongfully and corruptly failed to report such knowledge or
suspicion or cause such knowledge or suspicion to be reported to the police official
in the Directorate for Priority Crime Investigation referred to in section 17C of the

South African Police Service Act 68 of 1995, in that they knew or ought reasonably
had to have known or suspected that one or more of the crimes listed above were
committed by any other person(s), in the awarding of the contract and payments to
accused 3, 4, 5, 7, 8, 9 and/or 10, which involved more than the amount of R
100 000-00, namely R 255 million, and failed to report such knowledge or
suspicion.
2004: - Only against accused 1.
That the accused are guilty of the crime of corruption in contravention of section 3(a) (ii)
and/or (iii) and/or (iv), read with sections 1, 2, 20, 24, 25 and 26 of the Prevention and
Combating of Corrupt activities Act 12 of 2004:
In that on or about 2 April 2015, at Bloemfontein in the district of Bloemfontein, the
accused , directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or
offered to accept any gratification, namely payment of R 650 000-00 paid on his behalf to
Kramer, Weiman & Joubert attorneys, which was not legally due, from accused 3 and/or 4
in order to act and/or omit to act, personally and/or by influencing another person to act, in a
manner that amounts to:
 Abuse of a position of authority and/or
 A breach of trust, and/or
 The violation of a legal duty or a set of rules
And/or which was designed to achieve an unjustified result and/or that amounted to any
other unauthorized or improper inducement to do or not to do anything,

In that accused 1 unlawfully and intentionally manipulated the process of the appointment
of accused 3 and/or accused 4 and/or 5 to ensure that the contract is awarded to accused 4
and/or 5.
SECTION 4 OF ACT 12 OF 2004: – only against accused 1:
That the accused are guilty of the crime of corruption in contravention of section 4(1) (a) (i)
and/or (ii) and/or (iii), read with sections 1, 2, 4(2), 20, 24, 25 and 26 of the Prevention and
In that during the time and place mentioned in the main count, the accused, who was
employed as the Head of the Department of Human Settlements and as such a public officer,
directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or offered to
accept a gratification from accused 3, 4, or 5, whether for the benefit of himself or for the
benefit of another person, namely payment of R 650 000-00 on his behalf, in order to act,
personally or by influencing another person so to act, in a manner –
(i) That amounts to the –
(aa) Illegal, dishonest, unauthorized, incomplete, or biased; or
(bb) Misuse or selling of information or material acquired in the course of the
exercise, carrying out or performance of any powers, duties or functions arising out of a
constitutional, statutory, contractual or any other legal obligation;
(ii) That amounts to –
(aa) the abuse of a position of authority and/or
(bb) a breach of trust, and/or
(cc) the violation of a legal duty or a set of rules;
(iii) Designed to achieve an unjustified result; and/or
(iv) That amounts to any other unauthorized or improper inducement to do or not to do
anything.

2004: - Only against accused 3, 4 and 5.
That the accused are guilty of the crime of corruption in contravention of section 3(b) (i)
and/or (ii) and/or (iii) and/or (iv), read with sections 1, 2, 20, 24, 25 and 26 of the Prevention
and Combating of Corrupt activities Act 12 of 2004:
In that during the time and place mentioned in count 9, the accused , directly or indirectly
and wrongfully and corruptly gave or agreed to or offered to give to any other person any
gratification, whether for the benefit of that other person or for the benefit of another person,
namely the amount of R 650 000-00 paid from the account of accused 4 of whom accused 3
is the sole director, as part payment for the purchase of a house by accused 1,
in order to act and/or omit to act, personally and/or by influencing another person to act, in a
manner –
that amounts to the - :
(aa) illegal, dishonest, unauthorized, incomplete, or biased; or
(bb) misuse of or selling of information or material acquired in the course of the,
Exercise, carrying out or performance of any powers, duties or functions arising out of a
(cc) the violation of a legal duty or a set of rules

And/or (iii) which was designed to achieve an unjustified result
and/or (iv) that amounted to any other unauthorized or improper inducement to do or not to
do anything
In that accused 3/4/5 unlawfully and intentionally paid R 650 000-00 on behalf of accused
1 as part payment for a property purchased by accused 1 after accused 1 participated
and/or assisted in the appointment of accused 3/4/5 as service provider for the Department
of Human Settlements, of which accused 1 was the Head of the Department.
SECTION 4 OF ACT 12 OF 2004 – only against accused 3, 4 and 5:
That the accused are guilty of the crime of corruption in contravention of section 4(1) (b),
read with sections 1, 2, 4(2), 20, 24, 25 and 26 of the Prevention and Combating of Corrupt
activities Act 12 of 2004:
In that during the time and place mentioned in the main count, the accused, directly or
indirectly and wrongfully and corruptly gave or agreed or offered to give any gratification to
a public officer, namely accused 1, whether for the benefit of that public officer, namely
accused 1, or for the benefit of another person, namely payment of R 650 000-00 on his
behalf, in order to act, personally or by influencing another person so to act, in a manner –
(bb) Misuse or selling of information or material acquired in the course of
the exercise, carrying out or performance of any powers, duties or functions
arising out of a constitutional, statutory, contractual or any other legal
obligation;

anything.
In that during the period November 2013 to December 2015, at or near Pretoria in the
district of Pretoria and Bloemfontein in the district of Bloemfontein and Ballito in the
district of Ballito the accused , directly or indirectly and wrongfully and corruptly accepted
and/or agreed and/or offered to accept any gratification, namely payment of R 600 000-00,
which was not legally due, from accused 3 and/or 4 in order to act and/or omit to act,
personally and/or by influencing another person to act, in a manner that amounts to:
• Abuse of a position of authority and/or
• A breach of trust, and/or
• The violation of a legal duty or a set of rules
In that accused 11 unlawfully and intentionally assisted in the manipulation of the process
of the appointment of accused 3 and/or accused 4 and/or 5 to ensure that the contract is
awarded to accused 4 and/or 5.

employed as the Director – General of the Department of Human Settlements in Gauteng,
and as such a public officer, directly or indirectly and wrongfully and corruptly accepted
and/or agreed and/or offered to accept a gratification from accused 3, 4, or 5, whether for
the benefit of himself or for the benefit of another person, namely payment of R 600 000-00
on his behalf, in order to act, personally or by influencing another person so to act, in a
manner –
anything.

In that during the time and place mentioned in count 11, the accused , directly or indirectly
namely the amount of R 600 000-00 paid from the account of accused 4 of whom accused 3
is the sole director, as part payment for a vehicle bought by accused 11,
in order to act and/or omit to act, personally and/or by influencing another person –
in a manner –
Exercise, carrying out or performance of any powers, duties or functions arising out of a
do anything

In that accused 3/4/5 unlawfully and intentionally paid R 600 000-00 on behalf of accused
11 as part payment for a vehicle for accused 11, after accused 11 participated and/or
assisted in the appointment of accused 3/4/5 as service provider for the Department of
Human Settlements, of which accused 11 was a Director - General.
SECTION 4 OF ACT 12 OF 2004: – only against accused 3, 4 and 5:
a public officer, namely accused 11, whether for the benefit of that public officer or for the
benefit of another person, namely payment of R 600 000-00 on his behalf, in order to act,
(bb) Misuse or selling of information or material acquired in the course of the exercise,
carrying out or performance of any powers, duties or functions arising out of a

(v) That amounts to any other unauthorized or improper inducement to do or not to do
anything.
combating of corrupt activities Act 12 of 2004:
In that on or about 26 May 2015, at or near Pretoria in the district of Pretoria and
Bloemfontein in the district of Pretoria and Ballito in the district of Ballito the accused ,
directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or offered to
accept any gratification, namely payment of R 1 000 000-00, which was not legally due,
from accused 3 and/or 4 in order to act and/or omit to act, personally and/or by influencing
another person to act, in a manner that amounts to:
In that accused 11 unlawfully and intentionally assisted in the manipulation of the process
of the appointment of accused 3 and/or accused 4 and/or 5 to ensure that the contract is
awarded to accused 4 and/or 5.

employed as the Director – General of the Department of Human Settlements in Gauteng,
and as such a public officer, directly or indirectly and wrongfully and corruptly accepted
and/or agreed and/or offered to accept a gratification from accused 3, 4, or 5, whether for
the benefit of himself or for the benefit of another person, namely payment of R 1 000 000-
00 on his behalf, in order to act, personally or by influencing another person so to act, in a
manner –
anything.

In that during the time and place mentioned in count 13, the accused, directly or indirectly
namely the amount of R1 000 000-00 paid from the account of accused 4 of whom accused
3 is the sole director, on behalf of accused 11,
in order to act and/or omit to act, personally and/or by influencing another person - to act, in
a manner –
do anything
In that accused 3/4/5 unlawfully and intentionally paid R 1 000 000-00 on behalf of
accused 11, after accused 11 participated and/or assisted in the appointment of accused

3/4/5 as service provider for the Department of Human Settlements, of which accused 11
was a Director - General.
SECTION 4 OF ACT 12 OF 2004: – only against accused 3, 4 and 5:
a public officer, namely accused 11, whether for the benefit of that public officer or for the
benefit of another person, namely payment of R 1 000 000-00 on his behalf, in order to act,
(bb) Misuse or selling of information or material acquired in the course of the exercise,
carrying out or performance of any powers, duties or functions arising out of a
anything.

In that on or during August 2015, at Bloemfontein in the district of Bloemfontein, the
accused , directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or
offered to accept any gratification, namely payment of R 53 550-00, paid on his request
towards the tuition fees of the daughter of Refiloe Mokoena, which was not legally due,
from Ignatius Mpambani and/or accused 5 in order to act and/or omit to act, personally
and/or by influencing another person to act, in a manner that amounts to:
In that accused 13 had knowledge of the irregular and/or illegal nature of the agreement
between accused 3/4/5 and/or Ignatius Mpambani and the Department of Human
Settlements and/or accused 1 and unlawfully and intentionally condoned the irregular
and/or illegal nature of the said agreement and illegally requested Ignatius Mpambani to
pay the said amount on behalf of Refiloe Mokoena.
CONTRAVENTION OF SECTION 4 OF ACT 12 OF 2004: – only against accused 13:

employed as the Premier and as such a public officer and a member of the Executive of the
Free State, directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or
offered to accept a gratification from Ignatius Mpambani and/or accused 5, whether for
on behalf of Refiloe Mokoena towards the tuition fess of her daughter, in order to act,
anything.
pay the said amount on behalf of Refiloe Mokoena.

employed as the Premier and a member of the Executive of the Free State, directly or
indirectly and wrongfully and corruptly accepted and/or agreed and/or offered to accept a
gratification from Ignatius Mpambani and/or accused 5, whether for the benefit of himself
or for the benefit of another person, namely payment of R 53 550-00 on behalf of Refiloe
Mokoena towards the tuition fess of her daughter, in order to act, personally or by
influencing another person so to act, in a manner –
anything.

Settlements and/or accused 1 and unlawfully and intentionally condoned the irregular and/or
illegal nature of the said agreement and illegally requested Ignatius Mpambani to pay the
said amount on behalf of Refiloe Mokoena.
In that on or during June 2015, at Bloemfontein in the district of Bloemfontein, the accused
, directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or offered to
accept any gratification, namely payment of R 470 000-00, paid on his request to M – TAG
Systems for the acquisition of 200 Electronic tablets, which was not legally due, from
Ignatius Mpambani and/or accused 5 in order to act and/or omit to act, personally and/or
by influencing another person to act, in a manner that amounts to:

pay the said amount to M – TAG Systems.
to M – TAG Systems for the acquisition of 200 electronic tablets, in order to act, personally
or by influencing another person so to act, in a manner –
anything.

That the accused are guilty of the crime of corruption in contravention of section 7 (1) (a) (i)
gratification from Ignatius Mpambani and/or accused 5, whether for the benefit of
himself or for the benefit of another person, namely payment of R 470 000-00 to M – TAG
Systems for the acquisition of 200 electronic tablets, in order to act, personally or by

anything.
In that on or during the period 31 August 2015 and 1 September 2015, at Bloemfontein in
the district of Bloemfontein, the accused , directly or indirectly and wrongfully and
corruptly accepted and/or agreed and/or offered to accept any gratification, namely
payments of R 200 000-00 and R 100 000-00 respectively, paid on his request to Griffin
Edge (Pty) Ltd. for the acquisition of 200 Electronic tablets, which was not legally due,
from Ignatius Mpambani and/or accused 5 in order to act and/or omit to act, personally
and/or by influencing another person to act, in a manner that amounts to:

pay the said amounts to Griffin Edge (Pty) Ltd.
the benefit of himself or for the benefit of another person, namely payments of R 200 000-
00 and R 100 000-00 to Griffin Edge for the acquisition of 200 electronic tablets, in order
to act, personally or by influencing another person so to act, in a manner –

anything.
himself or for the benefit of another person, namely payment of R 200 000-00 and R 100
000-00 respectively to Griffin Edge (Pty) Ltd for the acquisition of 200 electronic tablets,
in order to act, personally or by influencing another person so to act, in a manner –

anything.
That the accused is guilty of the crime of corruption in contravention of section 3(a) (ii)
In that on or during June 2015, at Bloemfontein in the district of Bloemfontein, the accused
, directly or indirectly and wrongfully and corruptly accepted and/or agreed and/or offered to
accept any gratification, namely payment of R 30 000-00, paid on his request to S W C
Nkate, which was not legally due, from Ignatius Mpambani and/or accused 5 in order to
act and/or omit to act, personally and/or by influencing another person to act, in a manner
that amounts to:

pay the said amount to S W C Nkate.
to S W C Nkate, in order to act, personally or by influencing another person so to act, in a
manner –

anything.
gratification from Ignatius Mpambani and/or accused 5, whether for the benefit of himself
or for the benefit of another person, namely payment of R 30 000-00 to S W C Nkate, in
order to act, personally or by influencing another person so to act, in a manner –

anything.
In that during the period November 2015 and January 2016, at Bloemfontein in the district
of Bloemfontein, the accused , directly or indirectly and wrongfully and corruptly accepted
and/or agreed and/or offered to accept any gratification, namely payment of R 250 000-00,
paid on his request to Astra Travel towards travel expenses of a delegation to Cuba, which
was not legally due, from Ignatius Mpambani and/or accused 5 in order to act and/or omit
to act, personally and/or by influencing another person to act, in a manner that amounts to:

pay the said amount to Astra Travel.
to Astra Travel towards travel expenses for a delegation to Cuba, in order to act, personally
or by influencing another person so to act, in a manner –

anything.
CONTRAVENTION OF SECTION 7 OF ACT 12 OF 2004: - Only against accused 13.

himself or for the benefit of another person, namely payment of R 250 000-00 to Astra
Travel towards travel expenses for a delegation to Cuba, in order to act, personally or by
anything.
COUNT 20: CONTRAVENTION OF SECTION 86 OF THE PUBLIC FINANCE
MANAGEMENT ACT 1 OF 1999 (PFMA): - Only against accused 1.
That the accused is guilty of contravention of section 86, read with sections 1, 2, 3, 36 and
38 of the PFMA:

In that during the period 2014 to 2016 at Bloemfontein in the district of Bloemfontein, the
accused, on whom a legal duty existed in terms of section 38: -
(a) To ensure that the Department (of Human Settlements), has and maintains –
(i) Effective, efficient and transparent systems of financial and risk management
and internal control and/or
(ii) …
(iii) An appropriate procurement and provisioning system which is fair, equitable,
transparent, competitive and cost-effective and/or
(b) Is responsible for the effective, efficient, economical and transparent use of the
resources of the Department and/or
(c) Must take effective and appropriate steps to –
(ii) Prevent unauthorized, irregular and fruitless expenditure and losses resulting
from criminal conduct; and/or
(iii) Manage available working capital efficiently and economically and/or
(d) Is responsible for the management, including the safeguarding and the maintenance
of assets, and for the management of the liabilities of the Department and/or
(g) On discovery of any unauthorized, irregular or fruitless and wasteful expenditure,
must immediately report, in writing, particulars of the expenditure to the relevant
treasury and in the case of irregular expenditure involving the procurement of goods and
services, also to the relevant tender board and/or
(l) must take into account all relevant financial considerations, including issues of
propriety, regularity and value for money, when policy proposals affecting the accounting
officer’s responsibilities are considered, and when necessary, bring those under
considerations to the attention of the responsible executive authority and/or
(n) must comply, and ensure compliance by the Department, with the provisions of this
Act,
Unlawfully failed to act as stipulated in the Act.
COUNT 21 TO 65: CONTRAVENTION OF SECTION 4 (a) AND/OR (b), READ
WITH SECTIONS 1 AND 8 OF THE PREVENTION OF ORGANISED CRIME ACT
121 OF 1998 – MONEY LAUNDERING;

In that the accused knew or reasonably ought to have known that the property, namely the
amounts of money and/or payments mentioned in counts 1 to 18 and Annexure A to F, was
or formed part of the proceeds of unlawful activities, namely the offences mentioned in
counts 1 to 18;
In that on the times and places mentioned in counts 1 to 18 and Annexure A to F, the
accused unlawfully:
(a) Entered into any agreement or engaged in any arrangement or transaction with
anyone in connection with that property and specifically the agreements,
arrangements or transactions mentioned in counts 1 to 18 and the preamble,
whether such agreements, arrangement or transaction is legally enforceable or not
and/or
(b) Performed any other act(s) in connection with such property, whether it is performed
independently or in concert with each other or other persons and specifically the acts
mentioned in counts 1 to 18 and the preamble,
which had or was likely to have had the effect of:
• Concealing or disguising the nature, source, location, disposition or movement of the
said property or the ownership thereof or any interest which anyone may have in respect
thereof and/or
• Enabling or assisting one or some or all of the accused and/or other people unknown
to the State who had committed or where committing an offence, whether in the Republic or
elsewhere, namely the offences mentioned in count 1 to 18;
• To avoid prosecution and/or
• To remove or diminish the said property acquired directly, or indirectly, as a result
of the commission of the said offence.

ANNEXURE A: Payments to Blackhead by the Department of Human Settlements:
COLUMN 1 COLUMN 2 COLUMN 3
COUNT: DATE: AMOUNT:
21: 22/12/2014 R 20 000 000.00
22: 15/01/2015 R 31 000 000.00
23. 26/03/2015 R 25 000 000.00
24. 04/06/2015 R 15 000 000.00
25. 11/08/2015 R 36 500 000.00
26. 28/01/2016 R 10 000 000.00
27. 28/04/2016 R 15 000 000.00
28. 04/08/2016 R 77 500 000.00
Total R 230 000 000.00
ANNEXURE B: Payments to 605 Consulting by Blackhead:
29. 23/12/2014 R 3 500 000.00
30. 16/01/2015 R 8 750 000.00
31. 27/03/2015 R 4 000 000.00
32. 27/03/2015 R 3 000 000.00
33. 05/06/2015 R 2 450 000.00
34. 11/08/2015 R 1 575 000.00

35. 01/02/2016 R 4 681 500.00
36. 28/04/2016 R 7 500 000.00
37. 04/08/2016 R 77 500 000.00
Total R 112 956 500.00
ANNEXURE C: Payments to Blackhead Consulting by Blackhead:
38. 23/12/2014 R3 200 000.00
39. 16/01/2015 R 18 250 000.00
40. 16/01/2015 R 4 000 000.00
41. 28/03/2015 R 3 200 000.00
42. 28/03/2015 R 2 400 000.00
43. 05/06/2015 R 6 050 000.00
44. 11/08/2015 R 13 332 000.00
45. 29/01/2016 R 4 718 500.00
46. 28/04/2016 R 7 500 000.00
Total R 62 650 500.00
ANNEXURE D: Payments to Mastertrade 232 by Blackhead:
47. 23/12/2014 R 13 283 427.16
48. 27/03/2015 R 10 000 000.00
49. 05/06/2015 R 3 500 000.00
50. 11/08/2015 R 9 100 170.74

51. 29/01/2016 R 600 000.00
Total R 36 483 597.90
ANNEXURE E: Payments to Diamond Hill Trading by Blackhead:
52. 27/03/2015 R 2 400 000.00
53. 05/06/2015 R 3 000 000.00
54. 11/08/2015 R 12 500 000.00
Total R 17 900 000.00
ANNEXURE F: Payments to Ori Group by Mastertrade:
55. July 2014 R 9118-00
56. November 2014 R 603 716-00
57. December 2014 R 1 613 000-00
58. January 2015 R 640 000-00
59. February 2015 R 62 000-00
60. March 2015 R 1 765 000-00
61. June 2015 R 304 000-00
62. August 2015 R 1 310 000-00
ANNEXURE F: Payments on behalf of accused 1 by accused 3/4/5:

63. 2/04/2015 R 650 000-00
ANNEXURE G: Payments on behalf of accused 11 by accused 3/4/5:
65. 26/05/2015 R 1 000 000-00
66. 21/12/2015 R 600 000-00

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