The long-delayed document

Chronicle of the Hijack of EcoPeace

Note: This account is written with the benefit of hindsight and in particular,
careful study of documents, of which some were only obtained in terms of a court order of 21 Feb 2005. For most of the period discussed here I and most others were unable to see the big picture, because of partial information and what seemed to be unpredictable, even psychiatric events.

(Numbers in brackets denote sources which are listed, and in some cases quoted, at the end)

July 2003:

(At this time I had resigned as councillor – one of our key election promises was rotation of councillors - and I was overseas.)

Minutes of an “open” (i.e. mostly non-members, in fact mostly people who had never been to an EcoPeace meeting before) meeting reflect the following resolution: “3.1 EcoPeace will empower individual members to do outreach work in communities.” (1)

This resolution is tabled with 3 other controversial resolutions dealing with disciplinary action, and the active membership as a group does not discuss the precise meaning of 3.1 then or later.(2)

This is the sole mandate used to shut down the program of funding community projects that had been set up in accordance with a key election promise, and instead to acquire with EcoPeace funds, computer and video equipment (which we later find to be valued at R32 020,82 (3)) to become the property of individual members (4), without review by the general membership.

After returning from my overseas travels I object (in early 2004) that this is contrary to our election promises. A fig-leaf is then offered, namely that the equipment will only become the property of those individuals after they have worked for EcoPeace for certain numbers of hours (4). However the nature and performance of the work are never submitted to oversight by the general membership.

Instead the four beneficiaries (Alan Murphy, Gail Majola, Colleen Clifford – EcoPeace councillor at the time, and S’lu Sibiya – Alan’s girlfriend’s sister) themselves hold Finance Sub-Committee meetings. No minutes of these are presented to the general membership. I ask to attend Finance meetings but am never given notice of when or where they are.

As a process of conflict resolution is already planned, I resolve to wait for the appropriate time in that process, to pursue this issue. Even the choice of conflict resolution service provider becomes a source of conflict, with Alan railroading us into going with his choice (18).

24 July 2004

After several months of “organisational development” involving Laura Washington, a professional “therapist” facilitating EcoPeace meetings, I propose that what is really needed is a “truth commission” into the events of the previous several months; the meeting supports me with only Alan Murphy objecting; a trio (Laura, S’lu and myself) is mandated to convene the commission.

The meeting specifically instructs Alan to refrain from any steps involving Colleen’s employment, for instance firing her, without referring back to the committee (5).
29 July

After a “Co-ordination” meeting of 4 members (held without my knowledge), Alan minutes that the meeting accepts that I am not a member of EcoPeace and should not be invited to future meetings until I have undergone a conflict resolution process to his satisfaction ; only one person other than himself later ratifies these “minutes” (6).

3 August

Alan and Colleen meet, which he later claims to have been a meeting of the Councillor Support And Reference Group (she refutes the “minutes” he later issues); he records obtaining a mandate to remove Karen Read from EcoPeace’s candidate list; however, he is the sole signatory of these “minutes”! (7,8)


4 August

Alan Murphy, without consulting the general membership of EcoPeace, alters the recorded candidate list held by the I.E.C., moving himself from position 4 to position 1(9).

6 August

An EcoPeace meeting scheduled at the City Hall committee rooms is aborted because Alan Murphy uses armed municipal security to exclude me from the meeting. Members present vote 5 versus 3 in favour of admitting me but Alan refuses. His explanation is that firstly I am not a member of EcoPeace, and secondly that approximately 2 and a half years previously, I allegedly plied his girlfriend with alcohol and tried to seduce her (8).

[The latter allegation is currently the basis of a defamation suit by myself so I will not comment on the substance of it, but I can say that Alan had never previously accused me of such, and that I gave him every opportunity to withdraw the allegation during negotiations about the issues surrounding the mass expulsion and firing of the councillor, only resorting to legal action when all else failed (10,11).]

Alan hands Colleen a letter of ultimatum and gets members to witness her receipt of the letter. He instructs members to attend a meeting at his house on 11 August, which they object to because there is a standing agreement not to hold meetings there (12,13) after he previously told someone to leave his property during a meeting, and because of my exclusion.

Gail Majola submits her resignation and returns computer equipment bought with EcoPeace funds; this reduces the Finance subcommittee/cabal to three members.

10 August

Alan Murphy informs Colleen that she is dismissed by virtue of not having signed a contract at the meeting of 6 August. It transpires that he has at some stage altered the records at the I.E.C. to list himself as sole party leader (14), so the I.E.C. accepts his right to dismiss Colleen, and his right to become councillor in her place; the cabal now consists only of Alan and S’lu.

Both the I.E.C. and the Speaker’s office indicated that if we felt EcoPeace’s constitution had been breached, and were unable to resolve the matter internally, that our remedy would be court action (14,8).

11 August

Attempted meeting at Alan’s house fails as only himself and S’lu (the only other remaining member of the “Finance” cabal) attend (15). The constitution provides that if a special general meeting fails to achieve quorum, it can be re-scheduled, members given a week’s notice, and then it will be automatically quorate. However the aforementioned meeting was not only unquorate but improperly convened as insufficient notice was given and not all members were notified.

The majority of committee members, believing that Alan perceives me as waging a vendetta (whereas I, in proposing the “truth commission”, was advocating what many had expressed privately), decide to caucus without me, formulating their own grievances and launching their own response to Alan’s dictatorial actions (16).

13 August

Three of the members who boycotted the meeting of 11 August petition Alan in a hand-delivered letter, to call a special general meeting as he has the membership contact lists in his house. He is informed that this meeting is to deal with his recent actions (17).

13 & 14 August

“Majority faction” members give letters to John Govender, an attorney engaged to draw up the councillor contract (asking him to refrain from acting further for EcoPeace), to the I.E.C., the Speaker’s and Deputy City Manager’s offices (informing them that there is a dispute over succession to the councillor’s seat, and asking them to grant time for internal constitutional resolution)(19, 20, 21).


19 August

The special general meeting as petitioned by the three members is convened, not knowing whether Alan will arrive or whether he has transmitted the notice to wider membership. It is attended by 6 regular committee members (Gail Majola having withdrawn her resignation tabled at the aborted meeting, only to submit another within a week), one ordinary member, and one supporter, with one apology (from a regular committee member).

[It later transpired that this meeting was also improperly convened, as Alan was only given 6 instead of 7 days’ notice. But at the time, it proceeded in good faith; the relevant members would not get a second chance, as their membership would in future be denied by Alan.]

Since Alan fails to arrive, the meeting suspends him in absentia, resolving to send him minutes outlining members’ grievances, urging him to submit to a democratic investigation, and instructing him to hand over EcoPeace records and assets to Lihle Mbokazi.

The meeting also instructs me as a signatory of the EcoPeace account, to ask the bank to freeze the account (when I did this I was told Alan & S’lu had removed me from the signatories’ list, leaving only themselves. However when shown the abovementioned letters, and the minutes of 19 August, the bank agreed to freeze the account)(18).

27 August

Alan and S’lu hold a “meeting” at his house, with nobody else present (22). They amend the constitution, among other changes:

* Removing the requirement for rotation of councillors (giving Alan an indefinite term of office);

* introducing hierarchical structures, replacing the formerly explicitly egalitarian “Synergy Forum” with an Executive Collective, and within that, raising the portfolio of Co-ordinator to the status of “CEO” with emergency powers to act without consultation when s/he deems necessary (23,24).

Hereafter, new membership application forms appear which require the approval of the Co-ordinator/ “CEO” before membership is granted, and, if granted, the consent of applicants that the Co-ordinator/ “CEO” may terminate their membership(25).

This meeting marks a turning point; from here the two surviving cabalists, Alan and S’lu, gather around themselves a new committee of people too naïve and/or timid to question a one-sided account of the disappearance of the previous committee. None of these has filled in a membership form before September 11, although most have their forms arbitrarily backdated by the self-proclaimed “CEO”(25).

On the same day the original committee, minus cabalists and one apology
(i.e. 7 members) plus an ordinary member and two supporters, meets to discuss the situation; Colleen has already engaged an attorney in her personal capacity and presents a draft resolution and affidavits, but the meeting prefers to remain legally independent; and to prioritise protest action [in the event, this never materialises except for a heckle from the public gallery at Alan’s first council meeting](26).

31 August

The majority committee meets (six members, two apologies plus one ordinary member and one supporter); the principle of legal action is accepted; the meeting decides to invite John Govender for a briefing; one member offers to get a quotation for a Private Investigator!(27)

1 September

Floorcrossing begins. This should have been the deadline by which Colleen had to sign a contract restraining her from crossing the floor. Alan’s explanation of his unilaterally dismissing her three weeks earlier is that there used to be a rule preventing newly appointed councillors from taking up their seats for 21 days, and he thought this rule still to be in force (15).

(However the rule, even when it was in force, did not prolong the incumbency of a sitting councillor (28). If, hypothetically, Colleen had still failed to sign a contract restraining her from crossing the floor by the end of August, the committee intended to democratically dismiss and replace her – but possibly with someone other than Alan (Lihle Mbokazi had actually received more votes than Colleen in 2003 for the position of councillor but had withdrawn her candidature at the time, but was now available again)(1).

In any case, such a unilateral action was a violation of the EcoPeace constitution, as Alan was later forced to concede (29, 23).

3 September

The EThekwini Social Forum (since renamed People’s Social Movement), of which EcoPeace is a constituent organisation, places EcoPeace’s internal conflict on its agenda. A 20-minute slot is provided at the end of a 2-hour meeting, and a delegation of four from the majority faction of the committee makes a presentation emphasising our status as majority, and referring to documents which are tabled, for specifics of the grievances of the majority.

Besides the fact that quite some of the 20 minutes is used by certain E.S.F. members to make speeches encouraging resolution in terms of the EcoPeace constitution (thereby preventing us from detailing our attempt at just such a constitutional remedy), another disappointment is that the sole copies of the documents in question, which we had been unable to photocopy as intended, are intercepted by S’lu, who keeps them until the end of the meeting, seemingly taking notes. We therefore undertake to circulate copies to other members later; a member of our delegation was invited to take part in an E.S.F. delegation to Pietermaritzburg.

[It must be understood that having been cut off from the resources of EcoPeace, and being with the exception of my unemployed self, working class people, the majority faction is secretarially and communications-challenged: for instance we chip in to type and print minutes at internet cafes. Alan, on the other hand, has possession of all the resources and records of the group, and soon makes extensive use of these to promote his cause, and launch a domesticated, amnesic version of EcoPeace.]

At the E.S.F. meeting, Alan distributes (except to me) invitations to a “celebration” of EcoPeace’s new councillor, to be held at his home on 11 September. The other members of the delegation from the majority faction, of course, resolve to boycott.

10 September

The majority committee meets (7 members, one apology plus one ordinary member); the principle of a civil court case is supported; after a reportback on the E.S.F. meeting, Lihle Mbokazi is mandated to use the invitation to Pietermaritzburg to circulate our minutes to E.S.F. members and further brief them if the agenda permits.

The same meeting also debates whether to take direct action at a forthcoming meeting at Alan’s house (since Refuge Gcabashe, a member of the original committee who attends our meetings, had made excuses when Alan telephonically invited him to the various meetings at his house, he was minuted under “Apologies” and continued being invited); the majority of the meeting feels that to picket outside Alan’s house is too confrontational and/or dangerous; I express willingness to post myself there solo just to show the incoming “members” our minutes and tell them they are being led up the garden path, but the meeting asks me not to, in the interests of future negotiations (30).

11September

Alan minutes a “Members” meeting at his home. In addition to himself and S’lu, and six putative members (some filled in membership forms later), it is attended by Rasool Snyman of E.S.F. and by Chris Macdonald, who are minuted as “observers” [Chris later told me he was invited on the basis of a “social” braai, and refused to apply for membership]. The minutes claim the “meeting” resolved:
* To endorse the Councillorship of Alan Murphy;
* That he be paid pro-rata the same as Colleen for August, with
further payment as per a contract yet to be negotiated;
* That Gail Majola’s resignation be accepted, and the rest of the
old committee, with the exception of Refuge Gcabashe who gave
apologies, forfeit their membership until re-admitted by Alan;
* To adopt an “updated” constitution;
* To have the finances drawn up (31).

16 September

Five more general committee members are sent letters informing them that they have “forfeited their membership” by not attending meetings held at Alan’s house, which they considered improperly convened (15).




20 September

Tbe bank informs us that after Alan showed them his letter of appointment from the municipality as well as minutes of meetings held at his house, their legal department decided to unfreeze the account.

(Up to this time our group, seeing that it contains 7 of the 9 remaining committee members (Gail Majola having submitted a second resignation), and has frozen the bank account, is somewhat complacently waiting for the floorcrossing period to end, hoping that Alan and S’lu will then come to their senses and negotiate. To find out from the bank that minutes have been submitted indicating that a whole new committee has been created, is a shock.)

Wishing to ensure that the account remains frozen, given that we suspect financial mismanagement and/or misappropriation, and that the frozen account is a major incentive for negotiation, we immediately take legal advice.

21 September

A meeting of six committee members, with apologies from the seventh and from another ordinary member, considers the situation and approves the lawyers’ suggestion that we immediately apply for a rule nisi court order, and that I make the founding affidavit in the name of EcoPeace, rather than Colleen, as originally envisaged, but that she be the “Second Applicant”; before co-operating thus with Colleen, we got her to submit a written assurance from her attorney that she waived any claim against EcoPeace.

The meeting hears that Rasool arrived for an earlier attempt at the meeting, when it was postponed due to lack of quorum; those present then had got the impression that he and Roy Chetty (another leading E.S.F. member) had attended the “celebration” of 11 September [by his use of the word “we”; only later we got access the relevant minutes which don’t mention Roy]; Rassool had also told those present that at the end of the day, “we” would work with whoever holds the councillor seat [later, on talking to other E.S.F. members, I realised that the E.S.F. hadn’t come to a formal position on the matter]; furthermore Lihle had never been contacted about the delegation to Pietermaritzburg, and had therefore not circulated minutes to E.S.F. members (32).

The order applied for would restrain Alan from acting as councillor and from purporting to expel any members, and would cause the bank account to remain frozen (33).

29 September

Alan minutes a “Synergy” meeting of 4 at his house mandating him to instruct attorneys “on behalf of EcoPeace” to defend him against our court application. (34)

October 2004

Early in the month I circulated amongst my fellow applicants and other interested parties, a proposal for an out-of-court settlement (10). The main feature of this proposal is that it involves the entire membership of EcoPeace getting together without lawyers, and democratically resolving the matter after considering all the evidence.

At the first court hearing on the matter, Alan’s lawyer requests and is granted more time, and simultaneously presents to our lawyers a proposed out-of-court settlement whereby excluded (de facto expelled) members would be readmitted on condition that they accepted Alan’s status as councillor; with EcoPeace funds covering costs. As this flies in the face of democratic procedure, it is ignored (35).

November 2004

Having received only positive feedback on my proposal for an out-of-court settlement, I pass it on to Alan’s lawyer at the beginning of the month. Later there is another court appearance, another postponement and another derisory proposal from Alan’s lawyer featuring guaranteed councillor status and use of EcoPeace funds to pay costs (36).

December 4

Having received no formal response (nor was any to come later) to the proposed participatory resolution, I print and photocopy it – at my own expense of course – and arrive for the monthly E.S.F. meeting, hoping to generate peer pressure to encourage Alan and S’lu to submit to a democratic process. I also plan to seek clarity on the E.S.F. position in the matter, in view of the seeming alignment of certain members.

Alas, nobody else arrives except me - and Alan; the meeting is booked at the same committee rooms as the EcoPeace meeting of 6 August, and once it is clear the E.S.F. won’t meet, I depart before Security can be called.

Alan, who now has at his disposal the councillor’s monthly telephone subsidy of R1 500, contacts all the Zulu-speaking members of the applicant group (i.e. all except Colleen and myself) promoting his proposed route to an out-of-court settlement, and inviting them to a dedicated meeting with himself. None attend.

[Incidentally the socio-linguistics of this whole saga would make a mini-dissertation on their own. Since I speak some Zulu and understand more, gatherings of the majority faction – now calling itself the old committee – tended to use that language if Colleen was not present.]

December 15

The High Court closes for its annual recess of six weeks. This means our case will only come before the court in February.

January 2005

A meeting of the two sides and their lawyers is held, to seek an out-of-court settlement; only Colleen and myself from the applicant group are able to make it; when our side makes it clear that we hold Alan personally liable for the costs of the whole affair he claims to be bankrupt; the meeting ends with Alan’s attorney storming out, babbling about how much good his client has done for EcoPeace.

Alan circulates by email two proposals presented by Rasool for campaign consultancy; one for a R20 000, one-year package, the other for “situational analysis” at R350/hour [I don’t know what the decision was but have noticed that many EcoPeace meetings have since been held at ConsultX, Rasool’s firm](37,38).

The “Smoking Gun”: Later in the month Simon Read, EcoPeace’s
accountant, releases a financial report (3) based on documentation submitted by Alan for the period July 2003 to 20 August 2004 (in hindsight, this casts new light on Alan’s timing in getting rid of his critics, but at the time nobody from the old committee examined it in detail).

Whereas at the time of the purge, we were demanding financial transparency because we knew that computer and video equipment had been bought (4), “business lunches” held (8), etc., now it was revealed that in addition, many thousands of rand are simply unaccounted for:
· a total of R5 500 is written off as “money owed to A. Murphy”;
· amounts totalling R9 000 have mixed descriptions, e.g. “Alan, Petty Cash”;
· items described as Petty Cash amounting to R11 192,30 are not substantiated by slips.

N.B. the above amounts (totalling R25 692,30) are in addition to other expenses under the headings of Sundry, Refreshments, Educational Seminars, Projects, Salary Advance, Website, Equipment, Pension, Legal, Rent, Bank Charges, Salary, Stipends, Telephone and Transport. Therefore if they were not for any of these purposes, what were they?

Even if no misappropriation can be proved, a strong argument can be made for Alan to repay amounts for which he kept no proper records. This is the money, remember, which we promised the voters would be used for community projects. And that’s not all…

The period after 20 August 2004 is unaccounted for, as a bank statement is missing. Later attempts to access source documents under a court order are unsuccessful as Alan claims they do not exist (39).

15 February 2005

Alan holds a public meeting in Durban South; Roy Chetty of E.S.F. acts as M.C.; many people fill in membership forms (40).

Later in the month, as the trial date approaches, last-minute efforts are made by Karen Read, who was EcoPeace councillor before Colleen, to bring about an out-of-court settlement. The resulting meetings (held at the Botanic Gardens) get off to a bad start, with late arrivals by Alan and companions, poor attendance from the applicants, a confrontational approach by one of the long-inactive members recently bombarded with Alan’s side of the story, and an unfortunate attempt by the facilitator to get each side to acknowledge that the other has acted in good faith. What really doomed the proceedings was Alan's tendency to make statements that he could not have got away with in court, where the presence of witnesses would have established the perjurous nature of the statements.

By the second such meeting, both sides have new proposals for out-of-court settlements:
· The applicants’ proposal, drafted by our advocate prior to the first meeting, replaces the idea of a participatory investigation with an admission by Alan that he acted unconstitutionally in expelling us, firing Colleen, making himself councillor, and then refers the way forward to a special general meeting of EcoPeace members (11);
· The respondent’s proposal at last concedes that Alan needs to submit to a democratic process, but still features use of EcoPeace funds for legal expenses; we reject this as we feel that the membership should, on consideration of the evidence, have the option to hold Alan liable (41).

February 21

The day of the court case arrives. Alan arrives at court on a new motorcycle.

Alan’s lawyers attempt to have the case dismissed on the grounds that I was not mandated by EcoPeace to depose the founding affidavit for the application. Although I submit an original copy of the minutes of September 21, signed by 4 of the 6 attendees, rather than get bogged down in debating this, our lawyers put it to the court that Colleen (technically the “Second Applicant”) is entitled in her own right, to all the relief sought in the application. The court agrees to proceed on this basis, and to hear the matter if the parties fail to reach an agreement within a few hours.

Alan has belatedly obtained a second legal opinion and eventually sees the value of admitting that he acted unconstitutionally in firing Colleen and making himself councillor – namely that if he doesn’t, he will probably end up being found to have done so by the court – and will be liable for the additional costs of the court hearing.

Accordingly, an agreement is drafted which is essentially the same as that offered by our side at the Botanical Garden meetings – with the unnoticed omission of an acknowledgement of our continued membership. The court records the consent of both “parties” to this and issues the document as an order (29).

March/April

Each “party” (legalese for the sides in the court case) must provide the other with documents not already supplied in the proceedings. From our side we have only some additions to the membership lists issued by Alan and one set of minutes, as well as Colleen’s waiver.

However, access to the records of EcoPeace is one of the reasons we have resorted to legal action and we copy many minutes, policy documents, etc., enabling resolutions and a presentation to be prepared for the special general meeting to be held in terms of the court order [ultimately this chronicle is only possible because of those documents]; as mentioned above, Alan fails to produce financial records after 20August 2004, claiming they do not exist (39).

May

The court-ordered meeting is held at Umkhumbane Community Hall.
It starts about 90 minutes late as two taxis with newly recruited members from Durban South arrive late, and then the chair permits them to go through lengthy paperwork at a table set up by Alan and assistants, before calling the meeting to order. Interestingly, Rasool of the E.S.F. attends, claiming to be a member “of long standing”(41).

Although the court order specifies that the agenda shall include Colleen’s severance and “any other matters raised by any party”, the chair, citing time constraints, interprets this to mean no other matters; he rules that all other matters be resolved through democratic process in normal meetings of EcoPeace.

Unfortunately, not having foreseen such a possible turn of events, nobody from the applicants’ group has drawn it to his attention beforehand that the reason we were obliged to take legal action was precisely that there is no longer a normal democratic process due to autocratic manipulation of who could and could not participate as members; I put up my hand to point this out but am not allowed to speak.

Because we as survivors of the purge are unable to present our side of the story, the decisions taken by the meeting are not informed decisions, and therefore not democratic. Indeed, some quite intelligent, articulate members come away from the meeting still in the mistaken belief, fostered by the one-sided information overload, that EcoPeace had been sued by Colleen, rather than Alan being jointly sued by the old committee and Colleen (42).

The decisions are, to pay off Colleen with EcoPeace funds to the tune of R25 200, and to unfreeze the bank account, making Alan, S’lu and a third member signatories.

At that stage, in an exhausted condition, I feel that whatever the outcome, I have done my best and that my duty to the voters and the cause of truth can now give way to my need to return to my global migrant labourer role. I merely obtain the chair’s assurance that the resolutions I had tabled, would be attached to the minutes (43,44).

Postscript

Subsequent to these sorry events, I was persuaded (and assisted, by an offer of employment) to stay in Durban, and am thus in a position to produce this history. My only regret is that my finite spare time and finite access to word processing have overlapped so seldom; this and the need for legal vetting, have delayed the release of the text.

Sources

1) EcoPeace: Minutes of Open Meeting, 19 July 2003

2) EcoPeace: Minutes of meetings before and after the abovementioned Open Meeting; personal conversations with members.

3) Simon Read: Financial report circulated Jan 2005.

4) Alan Murphy: personal communication.

5) Draft minutes of EcoPeace, 24/7/04; paragraph 3 begins as follows: “Colleen’s Contract: Michael questioned clause 1.5 which empowered Alan to sign all documents; members present who had seen previous drafts said they did not remember this clause appearing before; the meeting asked Alan to have the clause removed, and Alan claimed it was a legal requirement; he was then instructed that even if [the attorney] insisted on keeping the clause for legal reasons, Alan was not to take any step such as firing Colleen without reverting to the committee”(emphasis added).

I prepared these from memory a few weeks later since Alan, who usually drafted and circulated minutes of meetings, failed to do so in this case. They remain a draft as I have been prevented from presenting them at subsequent meetings. Other members present were S’lu Sibiya, Lihle Mbokazi and Paulos Gwala, as was Laura Washington, the “therapist”

6) Alan Murphy; “minutes” of “Co-ordination”, 29 July 2004.

7) Alan Murphy, purported CSARG minutes, 3 Aug 2004.

8) Colleen Clifford, pers. comm.

9) Godfrey Naidoo, I.E.C. Durban office, personal communication with Viren Singh.

10)Michael Graaf, settlement proposal, Oct 2004.

11)Paul Schumann, settlement proposal, Feb 2005.

12)Karen Read: pers. comm.

13)Patrick Mdima: pers. comm..

14)Godfrey Naidoo : pers. comm.

15)Alan Murphy: Letter to Lihle Mbokazi, Sept. 2004.

16)Laura Washington: pers. comm.

17)Lihle Mbokazi et al: letter to A.Murphy, August 2004

18)EcoPeace: minutes, 19 August 2004.

19)Mbokazi et al: Letter to John Govender, August 2004

20)Mbokazi et al: Letter to I.E.C., August 2004

21)Mbokazi et al: Letter to Deputy City Manager, August 2004

22)Alan Murphy: “minutes”, 27-8-04

23)EcoPeace: constitution, 2000.

24)EcoPeace: purported constitution, 2004.

25)EcoPeace: membership forms as submitted with affidavit by Alan Murphy, October 2004

26)EcoPeace: Minutes of meeting, 27 August 2004

27)EcoPeace: Minutes of meeting, 31 August 2004

28)Republic of South Africa: (21-day rule/whatever)

29)Durban High Court: Consent order, 21-2-05

30)EcoPeace: Minutes, 10-9-04

31)Alan Murphy: “minutes”, 11 September 2004

32)EcoPeace: Minutes, 21 September 2004

33)EcoPeace: Application to Durban High Court, September 2004

34)Alan Murphy: “minutes”, 29 September 2004

35)John Govender: First settlement offer

36)John Govender: Second settlement offer

37)Rassool Snyman, proposal published by Alan Murphy, January 2005.


38)Rassool Snyman, proposal published by Alan Murphy, January 2005.

39)Alan Murphy: verbal statement before witnesses at office of Viren Singh, April 2005

40)Alan Murphy: minutes of public meeting, 15 Feb 2005

41)Rassool Snyman: pers. comm..

42)Neil Wayman: pers. comm.

43)Michael Graaf: resolutions tabled May 2005.

44) Muna Lakhani: minutes of special EcoPeace meeting, May 2005.