reference : nobest harriet magxunyana … : nobest harriet magxunyana date of birth : 15/10/53...

32
REFERENCE : NOBEST HARRIET MAGXUNYANA DATE OF BIRTH : 15/10/53 MARITAL STATUS : MARRIED 3 CHILDREN EMPLOYMENT : At the request of Nicholls, Cambanis & Associates I saw and examined this 39 year old lady in my rooms in Mayfair in April 1993. She told me that on the 8th April whilst asleep in her house, police allegedly broke into her house and started assaulting her. She was : - a. hit with a fist on her face and lost one tooth; b. hit with the butt of a rifle over her left eye; c. hit with the butt of a rifle on her body; and d. kicked on her back. She was taken to Natalspruit Hospital the next morning, was examined and given some treatment. She subsequently had to see a private dentist for further treatment. Mrs. Magxunyana complained primarily of pain in both shoulders and told me that this was aggravated by doing any hard work.

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REFERENCE : NOBEST HARRIET MAGXUNYANADATE OF BIRTH : 15/10/53MARITAL STATUS : MARRIED

3 CHILDRENEMPLOYMENT :

At the request of Nicholls, Cambanis & Associates I saw and examined this 39 year old lady in my rooms in Mayfair in April 1993. She told me that on the 8th April whilst asleep in her house, police allegedly broke into her house and started assaulting her. She was : -

a. hit with a fist on her face and lost one tooth;

b. hit with the butt of a rifle over her left eye;

c. hit with the butt of a rifle on her body; and

d. kicked on her back.

She was taken to Natalspruit Hospital the next morning, was examined and given some treatment. She subsequently had to see a private dentist for further treatment.

Mrs. Magxunyana complained primarily of pain in both shoulders and told me that this was aggravated by doing any hard work.

- 2 -

Mrs. Magxunyana appeared to be a healthy 3 9 year old woman. On examination of the major medical systems there was nothing to be found. She still exhibited minimal tenderness around both her shoulders, but on further examination there was no wasting, and full movement was available at both shoulder joints. She definitely had lost of her upper right frontal tooth.

In summary, we have a 3 9 year old woman who was allegedly assaulted by the police in her home in Phola Park on the 8th April 1992. She continues to suffer pain and has difficulty working to her full capacity. She has also lost one upper tooth and due to lack of financial resources has not been able to do anything besides getting basic dental treatment. She continues to suffer from pain.

M F RANDERA(M.R.C.S.L.R.C.P.,B.R.C.O.G.)

M.BCh.B. (Cape Town) FCS (SA> OrthORTHOPAEDIC SURGEON / ORTOPEDIESE CHIRURG

PR No 2803267

204 MORNINGSIDE CLINIC CNR. HILL & RIVONIA RD MORNINGSIDE SANDTON 2146

24/02/1992

TELEPHONE/TELEFOON 884-5105/6 P.O.BOX 651194RESIDENCE/WONING 702-2031 BENMOREACCOUNT QUERIES 883-3500 2010 FAX; 883-3350

NICH0LLS CAMBANIS & ASS. p o box 8694 JOHANNESBURG 2000.

MEDICO - LEGAL REPORT.

NAMEDATE OF BIRTH OCCUPATION DATE OF ASSAULT DATE OF EXAMINATION

MRS NOBEST HARRIET MAGXUNYANA1 5 /1 0 /1 9 5 1

DOMESTIC0 8 /0 4 /1 9 9 2

1 6 /0 2 /1 9 9 4

HISTORY

At round about 11 pm on 08/04/1992 Harriet Magxunyana was awakened by the sound of gun fire outside her house. Then somebody knocked on the window and at the door.She was told to open the door. When she did so a lot of men entered the house and her husband was taken outside. Six of the men stayed in the house and started beating Mrs Magxunyana with the butts of their rifles.She was hit with a fist in her mouth. she was badly injured, having been hit on her back, shoulders and abdomen. The men then left.

2/...The men♦

Emergency: 331-8131 Code 440 Channel 11

2.

She was busy trying to wash her face when three more men came into her house and hit her with big sticks. She was hit many times.

Her left hand was hit. "It did not crac k it just went big." Following this the men left.

The next day she went to hospital to seek medical attention.

The injuries she sustained included bruising of her face, the loss of a tooth, bruising and swelling of her left hand and bruising of her shoulders, low back and abdomen.

At hospital she was given pills and an injection and was sent home later that day. Her arm remained swollen for about two months. The bruising on her back remained for about two months and during this period she was unable to work.

PRESENT COMPLAINTS

1. She is missing a tooth. This concerns her because of the effect it has on her appearance.

2. She experiences pain in her right shoulder.Her shoulder can be painful at any time, however it is more painful when she is working.

3 / . . . S o m e t i m e s

Sometimes her shoulder pain interferes with her sleep.

Certain activities are effected by her shoulder pain. for instance she is unable to carry a full load of wood which she was able to do prior to the assault. She also finds that she is unable to carry water more than once a day.Before the assault she was able to carry as much water as was required.

GENERAL HEALTH PRIOR TO THE ASSAULT

She was generally well and was on no medication.

EMPLOYMENT

Mrs Harriet Magxunyana was a domestic worker prior to the assault. Following the assault she was unable to work at all for two months. After this she returned to her normal work. However she finds that her right shoulder interferes with her work.For instance, prior to the assault she was able to wash all of the windows in her employers home in one day. Following the assault she finds that she has to do this in stages.

SOCIAL AMENETIES

Prior to the assault she helped at Sunday School.This she was unable to do for approximately two months following the assault.

4 / . . . S h e w a s u n a b l e

II4 .

She was unable to do her own washing at home and required assistance from her sister with this for approximately five to six months.

EXAMNATION FINDINGS

Mrs Magxunyana appeared generally well. Her right lateral upper incisor tooth is missing.

She is tender over the base of her neck and over the right scapula and along the right scapula margin. She is also tender over the third and fourth thoracic spinous processes and on the right side of the spine in this region.

Her range of cervical movement is reduced.

SPECIAL INVESTIGATIONS

X-rays of her dorsal spine and her right shoulder and scapula were taken on 16/02/1994. (Radiologists report enclosed).

DIAGNOSIS

AS a result of the assault Mrs Magxunyana has suffered the loss of her right upper lateral incisor tooth.She suffered facial bruising and soft tissue injuries to both shoulders, back and abdominal regions.She also suffered soft tissue injuries to her left hand.

5 / . . . S o m e o f

Some of her soft tissue injuries have healed, however she retains pain and loss of function over her upper dorsal spine and pain and loss of function over the base of her neck and scapula region.

PROGNOSIS AND FUTURE MEDICAL COSTS

1) RELATED TO HER TOOTH

She requires prosthedontic work to replace her right upper incisor. This is a functional and cosmetic requirement as failure to replace the tooth will result in deterioration of her remaining teeth and an earlier loss of teeth than would otherwise be expected. Advice on this and the cost involved should be sought from a prosthedontist.

2) RELATED TO HER SOFT TISSUE INJURIES

Nearly two years after the assault the soft tissue injuries she sustained to her dorsal spine area and right shoulder continue to cause her symptoms. These symptoms require treatment in the form of analgesic agents, anti-inflaminatory agents and physiotherapy. She may also require occasional visits to a medical practitioner. It would be reasonable to allow her approximately R 2,700.00 per year over a two year period for this purpose.

6/...CONCLUS

6 .

CONCLUSION

Mrs Magxunyana suffered a horrific experience when she was brutally assaulted by a large number of armed men. This occured following being awoken at night by gunfire. She must have suffered massive emotional and physical trauma.

She retains disability from her injuries relating to her right shoulder and upper dorsal spinal area. She has a disfigurement in the form of the loss of an extremely visible tooth.

She is likely to sustain significant medical costs in replacing her tooth and in treating her soft tissue injuries.

I find no reason to suspect that her life expectancy has been altered by the assault.

FCS (S A) Orth.

Dr. HYMIE LUNTZ Dr. PAUL SPIRO Dr. IAN SCHMAMAN Dr. RODNEY MILLER

RADIOLOGISTS • RADIOLOE

Dr. ISSY JAFFE Dr. ERROL PAPERT Dr. ARNO PRETORIUS Dr. BRIAN PAPERT

Dr. RALPH POSNER Assisted By:Dr. HAROLD BLOCH Dr. VICTOR GOUWS

301 Lister Building / Gebou

Sandton Clinic / Kliniek, Lyme Park Tel: 706-6166

Jeppe Street / Straat

Morningside Clinic / Kliniek Hill Road off Rivonia Road Tel: 883-3320

P.O. Box / Posbus 4878 Johannesburg 2000 Tel: 337-5022

Kempton Park, Trust Bank Emergency / Noodgevalle Tel: 975-0121, 975-0191 Autopage Tel: 804-2777

MEDICO LEGAL

Z57570

DAO:08/04/9842YWAITMorni ngside (General)

MRS NOBEST MAGXUNYANA ATT:THE PERSONNEL MANAGER P 0 BOX 8694 JHB 2000 16/02/94

DR G VERSFELD

DORSAL SPINEThere is a mild scoliosis of the mid dorsal spine concave to the left. There is a scoliosis o-f the lower dorsal spine extending into the lumbar spine concave to the right.There is slight accentuation of the dorsal kyphosis.

No obvious wedging or fractures are noted involving any of the vertebral bodies from D3 down to D12. There is no evidence of subluxation. There is a normal alignment.

The pedicles are all intact. There is a normal bony trabecular pattern.

There is some spurring noted adjacent to the disc space Detween D9 and DIG. Some ca1cification of the anterior longitudinal ligament at this level is also noted.

There does also appear to be slight narrowing of the disc space between 04 and D5 with some associated anterior spurring .

Due to the overlying ribs it is not possible to assess the spinous processes.

CONCLUSIONThere is a mild scoliosis of the mid dorsal spine concave to the left and of the lower dorsal spine concave to the right. There is slight accentuation of the dorsal kyphosis.

Spurring is noted at the D4/5 and DIO/11 level.

No old fractures are noted involving any of the vertebral bodies. There does appear to be slight narrowing at the D4/5 disc space.

The pedicles are all intact. There is a normal bony trabecular pattern. No paraspinal abnormalities are noted.

2 / ______

RADIOLOGISTS • RADIOLOE

Dr. HYMIE LUNTZ Dr. PAUL SPIRO Dr. IAN SCHMAMAN Dr. RODNEY MILLER

Dr. ISSY JAFFE Dr. ERROL PAPERT Dr. ARNO PRETORIUS Dr. BRIAN PAPERT

Dr. RALPH POSNER Assisted By:Dr. HAROLD BLOCH Dr. VICTOR GOUWS

301 Lister Building / Gebou

Sandton Clinic / Kliniek, Lyme Park Tel: 706-6166

Jeppe Street / Straat P.O. Box / Posbus 4878 Johannesburg 2000 Tel: 337-5022

Morningside Clinic / Kliniek Kempton Park, Trust Bank Emergency / NoodgevalleHill Road off Rivonia Road Tel: 883-3320 Tel: 975-0121, 975-0191 Autopage Tel: 804-2777

2/ ..............

MRS NOBEST MAGXUMYANA 16TH FEBRUARY 1994

RIGHT SCAPULA AND SHOULDER

The right scapula is normal in position and outline. No obvious old -fractures are noted. The acromioclavicular joint is normal in position and diameter.

No obvious abnormality o-f the glenohumeral joint is noted.

CONCLUSION

No abnorma I i. t ies of the right shoulder girdle are noted.

DR ERROL PAPERTEP/vk

%

'wmxwi Telephone: 788-5379 Residence: 678-1426

B.D.S., M.Dent. (Wilwatersrand)P.O. Box 73809 Fairland 2030PROSTHODONTIST

NICHOLLS, CAMBAINIS KOOPASAMMY & PILLAY P.O. BOX 8694 JOHANNESBURG 2000

MEDICO-LEGAL. REPORT

PATIENTS NAME MS N. MAGXUWYANA

DATE OF BIRTH 15 JANUARY, 1951

DATE OF EXAMINATION : 2 MARCH, 1994

THIS REPORT IS RESTRICTED TO PROSTHODONTIC OPINION ONLY.

HISTORY

During the course of an assault on 8th April 1992, the patient received a blow to the anterior maxilla, resulting in the loss of a tooth.

EXTRA-ORAL^ EXAMINATION

No apparent disorder was noted.

I N ™ =0RAL_EX AM I NAT ION

Tooth 12 was missing, having been avulsed in the incident. in question. Some minor scaring was evident on the inside of the lip in relation to the missing tooth.

RADIOGRAPHIC_.EXAMINAIIONThis confirmed the total avultion of tooth .12.

IBi^IMENJThe opinion of treatment is to restore the patient to an optimal state of dental health. This can be best achieved by providing her with a single tooth implant supported prosthesis, which will most closely restore her mouth to its natural state.

Another option would be to provide her with a fixed three-unit bridge. The downside of this is that two healthy virgin teeth will have to be prepared. A -further option would be theprovision of a partial denture. This would be the last choice of definitive treatment as it is the furthest from normality as regards comfort, aesthetics and function.

Costing

QEt;.i90_i._Z_I®P.i®Qt_Pro5thesi s8234 X

8592 X

8600 X

9183 X

9190 X

9189 X

8099

One Tooth Plastic partial dentureImplant AbutmentImplant Component (estimated)Surgical Placement of implantExposure of ImplantCost of ImplantLaboratory Fee (estimated)

321.48 1606.26 1000.00 1 0 3 1 .70 381.90

1200.00 iooo^oq6541.34

Q P . t i . g n _ 2

8751860986158099

x 1 Crown Lengthening x 2 Porcelain Veneered Crowns x 1 Anterior Ront.i c

Laboratory Fee (estimated)

1071 .. 60 2 6 7 9 » 00 1070.46 i20Q>._00 6021.06

Opt ion 3

86718099

Chrome cobalt denture Laboratory Fee (estimated)

2143.20iogo._go2143.20

PROGNOSIS

Option 1 gives the best, prognosis - implants should last up 35 years according to the latest literature.

Option 2 would need to be replaced every 10 years.Option 3 should be replaced every 5 years.

to

In all cases, provision should be made for routine maintenance on a regular ongoing basis - Currently R800 per annum.

The -fees are those -for .1994 as laid down toy the Dental Association of South Africa, and are subject to annual increase o-f 15 - 20"/-.

Yours -faithfully,

-0y*30

*

Case No.: 92/26572

In the Supreme Court of South Africa(WITWATERSRAND LOCAL DIVISION)

In the matter between:

CNOBEST HARRIET MAGXUNYANA Plaintiff.

and

THE MINISTER OF DEFENCE Defendant.

---------------------------------

To the sheriff or his deputy: j r U : ;

in fo r m jSgSPH K y - jTHE MINISTER OF DEFENCE, cited herein in his.official capacity as being the person legally responsible for the conduct of members of the South African Defence force,' c/o the Chief of the South African Defence force, (Finance Division), South African Defence Force Headquarters, Dequar Road, Pretoria.

(hereinafter called the Defendant(s) ) thatNOBEST HARRIET MAGXUNYANA, an adult married female domestic worker, duly assisted herein by her husband, resident at J8 Phola Park, TOKOZA.

COMBINED

SUMMONS

(hereinafter called the Plaintiff(s) ), hereby institutes action againstin which action the Plaintiff(s) claim the relief and on the grounds set out in the particularsannexed hereto.

INFORM the Defendant(s) further that if Defendant(s) disputes/dispute the claim and wishes/wish to defend the action, the Defendant(s) shall -

(i) Within 1 month {terorof the service upon the Defendant(s) of this summons,file with the registrar of this Court at Room 007, Supreme Court B u ild ing , Pritchard S tr e e t , JOHANNESBURG.Notice of Defendant(s) intention to defend and serve a copy thereof on the Attorneys of the the Plaintiffs), which notice shall give an address (not being a post office or poste restante) referred to in rule 19 (3) for the service upon the Defendant(s) of all notices and documents in the action.

(ii) Thereafter and within twenty days after filing and serving notice of intention to defend as aforesaid, file with the registrar and serve upon the Plaintiff(s) a Plea, Exception, Notice to strike out, with or without a Counter-claim.

INFORM the Defendant(s) further that if the Defendant(s) fails/fail to file and serve notice as aforesaid, Judgment as claimed may be given against the Defendant(s) without further notice to the Defendant(s), or if having filed and served such notice, the Defendant(s) fails/fail to plead, except, make application to strike out or counter-claim, Judgment may be given against the Defendant(s)

AND immediately thereafter serve on the Defendant(s) a copy of this Summons and return the same to the Registrar with whatsoever you have done thereupon.

DATED at JOHANNESBURG this 30th da>'of SEPTEMBER

NICHOLLS, CAMBANIS & SUDANOAttorneys of Plaintiff(s),23rd Floor, Kine Centre 1 1 Commissioner Street JOHANNESBURG Ref. Ms C H Nicholls

^ Registrar of the Supreme Court

ANNEXURE "A"

PARTICULARS OF CLAIM

Plaintiff is NOBEST HARRIET MAGXUNYANA, an adult married female domestic worker, duly assisted herein by her husband, and whose date of birth is 15 October 1954, resident at J8 Phola Park, Tokoza.

Defendant is the MINISTER OF DEFENCE, cited herein in his official capacity, as being the person legally responsible for the conduct of members of the South African Defence Force, c/o the Chief of the South African Defence Force, (Finance Division), South African Defence Force Headquarters, Dequar Road, Pretoria.

On or about 8 April 1992, and at Phola Park, Tokoza, the Plaintiff was unlawfully assaulted, by a member, or members, of the South African Defence Force, acting within the course and scope of their employment with the Defendant.

As a consequence of this assault, Plaintiff sustained injury as follows

4.1 a severely sprained left hand;

4.2 severely swollen lips;

4.3 one upper front tooth missing;

4.4 severe bruising on the back;

4.5 severe bruising on the left shoulder;

4.5 resultant continual internal bleeding for the period of two weeks.

Page 2

The disabilities suffered by plaintiff as a result of the injuries are as follows

5.1 temporary inability to bend her back without severe pain for a period of one month;

5.2 temporary inability to lift objects with left hand for a period of one month;

As a result of the bodily injuries sustained, Plaintiff has suffered damages in the amount of R32 000,00.

Such damages are computed as follows

PAIN AND SUFFERING AND C0NTUMELIA

7.1 For pain and suffering and contumelia, damages in the amount of R30 000,00.

DISFIGUREMENT

7.2 On front upper tooth missing, damages in the amount of R2 000,00

In the premises Defendant is liable to Plaintiff in the amount of R32 000,00

Despite demand, Defendant fails or refuses to pay the above amount of any portion thereof.

Page 3

WHEREFORE PLAINTIFF CLAIMS

i) the amount of R32 000,00.

ii) interest on the above amount at the rate of 18.5% per annum as from 14 days of date of judgment to date of payment.

iii) costs of suit;

iv) further and/or alternative relief

®4’vDATED AT JOHANNESBURG THIS I DAY OF AUGUST 1992.

D J M PITMAN COUNSEL FOR PLAINTIFF

NICHOLLS AND CAMBANIS PLAINTIFF'S ATTORNEYS 23RD FLOOR, KINE CENTRE COMMISSIONER STREET JOHANNESBURG REF: VS/PP/27

IN THE SUPREME COURT OF SOUTH AFRICA

(VrtTWATERSRAND LOCAL DIVISIONCASE NO; 92/26572 P/H 308

In the matter between

MAGXUNYANA NOBEST HARRIET Plaintiff

and

THE MINISTER OF DEFENCE Defendant

NOTICE OF INTENTION TO DEFEND

BE PLEASED TO TAKE NOTICE THAT the abovenamed Defendant intends to

defend this action and has appointed the following address as the

address for the service upon him of all notices and documents in the

action

STATE ATTORNEY888 ROYAL ST. MARY'S BUILDING 85 ELOFF STREET PRIVATE BAG X9 J O H A N N E S B U R G

BUSINESS ADDRESS: S.A. DEFENCE FORCE HEADQUARTERS, DEQUAR ROAD, P R E T O R I A .

DATED at JOHANNESBURG on this the day of OCTOBER 1992.

DEFENDANT'S ATTORNEYSTATE ATTORNEY/'888 ROYAL ST/MARY'S BUILDING 85 ELOFF STREET PRIVATE BAG X9 J O H A N N E S B U R G

_____ / 2

REFER TO: G. BOWEN REFER NO: 6674/92/P5/JC TEL NO: 29 2961

TO:The Registrar of the above Honourable Court J O H A N N E S B U R G

AND TO:PLAINTIFF'S ATTORNEYNICHOLLS, CAMBANIS, & SUDANO 23rd FLOOR, KINE CENTRE 141 COMMISSIONER STREET J O H A N N E S B U R G

REF: Ms C.H. NICHOLLS

COPY HEREOF RECEIVED ON THIS

THE OneM day OF -OCTOBER 1992

___ sLFor/PLAINTIFF'S ATTORNEY

IN THE SUPREME COURT OF SOUTH AFRICA

(WITWATERSRAND LOCAL DIVISION)

Case Number : 92/26572

In the matter between:

MAGXUNYANA. Nobest Harriet Plaintiff

and

MINISTER OF LAW AND ORDER Defendant

DEFENDANT’S PLEA TO PLAINTIFF'S PARTICULARS OF CLAIM

1. AD PARAGRAPH 1 :

Save to admit that Plaintiff is Nobest Harriet Magxunyana, Defendant has no knowledge of the remaining allegations

contained in this paragraph, accordingly denies same and

puts Plaintiff to the proof thereof.

2. AD PARAGRAPH 2:

Defendant admits the contents of this paragraph.

Page 2

3. AD PARAGRAPH 3 :

Defendant denies the contents of this paragraph and puts

Plaintiff to the proof thereof.

4. AD PARAGRAPHS 4. 5. 6. 7 and 8 :

Defendant denies the contents of these paragraphs and puts

Plaintiff to the proof thereof.

5. AD PARAGRAPH 9 :

Defendant admits a demand and a failure or refusal to pay,

but pleads that Defendant is not legally liable to pay the

amount claimed or any portion thereof.

WHEREFORE Defendant prays that Plaintiff's claim be dismissed

with costs.

DATED AT JOHANNESBURG ON THIS 2nd DAY OF DECEMBER 1992.

Page 3

TO:

AND

STATE Aa4oRNEY Defendant's Attorneys 888 Royal St. Mary's Bldg 85 Eloff Street JOHANNESBURG Ref: Mr Bowen/

667 4/92/P5 Tel: 29-2961

THE REGISTRAR OF THE ABOVE HONOURABLE COURT JOHANNESBURG

TO: NICHOLLS ft CAMBANISPlaintiff's Attorneys 23rd Floor Kine Centre Commissioner Street JOHANNESBURG Ref: VS/PP/27

Received copy hereof on the Q fL day of December 1992.

for: Plaintiff’s Attorneys

W IT H O LF PREJUDICErr 4IGHTS

IN THE SUPREME COURT OF SOUTH AFRICA

(WITWATERSRAND LOCAL DIVISION)

CASE NO: 92/26572

In the matter between

MAGXUNYANA NOBEST HARRIET Plaintiff

and

THE MINISTER OF DEFENCE Defendant

DEFENDANT'S NOTICE IN TERMS OF RULE 36 (4)

BE PLEASED TO TAKE NOTICE that the Defendant requires the Plaintiff in

so far as he is able to do so to make available within 10 (ten) days

after service hereof to the former any medical reports, hospital

records, X-ray photographs or other documentary information of a like

nature relevant to the assessment of the damages of compensation in respect of bodily injury alleged to have been suffered by the Plaintiff.

TAKE NOTICE FURTHER that the Defendant requires from the Plaintiff a consent to inspect all hospital records relating to the latter and that

such consent should mention the hospitals1 reference numbers as well as the dates on which the Plaintiff was treated.

DATED at JOHANNESBURG on this the / b day of NOVEMBER 1992.

TO:

AND TO:

DEFENDANT'S ATTORNEYSTATE ATTORNEY888 ROYAL ST. MARY'S BUILDING 85 ELOFF STREET

PRIVATE BAG X9 J O H A N N E S B U R G

THE REGISTRAR OF THE ABOVE HONOURABLE COURT J O H A N N E S B U R G

REFER TO REFER NO TEL NO

G. BOWEN 6674/92/P5/JC 29 2961

PLAINTIFF’S ATTORNEYSNICHOLLS AND CAMBANIS 23rd FLOOR, KINE CENTRE COMMISSIONER STREET J O H A N N E S B U R GREF: Ms C H NOCHOLLS

COPY HEREOF RECEIVED THIS THE

A DAY OF NOVEMBER 1992

For/PLAINTIFF'S ATTORNEY

W ITHOUT PREJUOICF J 0 RIGHTS

PH 466IN THE SUPREME COURT OF SOUTH AFRICA.(WITWATERSRAND LOCAL DIVISION) CASE NO : 95/56575

In the matter between i -MAGXUNYANA■ Nobect Harriet PlaintiffANDTHE.MINISTER OF LAW AND ORDER Defendant

REPLY TO NOTICE IN TERMS OF RULE 36(4)

BE PLEASED TO TAKE NOTICE that the Plaintiff hereby attaches relevant medical records as requested by the Defendant.

DATED at JOHANNESBURG on this the % day of DECEMBER 1992.

TO s THE REGISTRAR OF THE ABOVE HONOURABLE COURT JOHANNESBURG

_____NICHOLLS, CAMBANIS t, SUDANOPLAINTIFFS’ ATTORNEYS 23RD FLOOR, KINE CENTRE 1^1 COMMISSIONER STREET JOHANNESBURG REF : VS/PP/27

AND TO : STATE ATTORNEYDEFENDANT’S ATTORNEYS 8TH FLOOR, ROYAL ST.MARY’S BLDG 85 ELOFF STREET JOHANNESBURG M R . BOWEN/667*t/9 2 /P5

Received copy hereof on this the VO\V\iay ca±JkECEMBER 1992.

FOR s DEFENDANT’S ATTORNEYSS T A A T S P R O K U R G U R

Pfl«v'AAT8 * v . 1?R<VATE X9 MOOONTVAT& SO N D ilR Bc Na DLu NG <*AN nEGTfc

1932 -12- 1 0R E C E I V E D P F g J U D ; C E OF RI9MT§

TYD/TIME .i.m.nHWIHHtllljtltS T A T E A T T O R N E Y

fcP.-t. 0*2101*2 T.P.H. 2SB

BUITEPASlENTE EN/OF ONGEVALLE AFD. • OUTPATIENT AND OF, CASUALTY DEPT.

.......................... HOSPITAAL » HOSPITAL PASlgNT « PATIENT No.... j.*/.

5SSKK!..... .......................SS,.dd,ess ..3 1 .E....... .... L ..........I I ;

Foon................................... ................................................... Phone No......................................................

Huwelikstaat — Geslag Ras Marital state.......... ............................. Sex.. ............ ............................ R a c e . . _ .......................

Beroep >J\ / v GeboortedatumOccupation................... x....../....J ................................ Date o? birth...................................................

Naam van persoon verantwoordelik vir betaling van rekening Narne of person responsible for payment of account................... id.l

Volgno. Serial No.

Sy/Haar adres • His/Her address.

Naam van werkgewer • Name of employer.. y/c<£

dres van werkgewer • Address of employer............................... ....£x.* s _ , ...... .

4 j Name of sick fund.............................................................................................................................................. S/FNoaam van siekefonds

'Jaarlikse gesinsinkomste • Annual family income Uit alle bronne From all sources

Broodwinner • Breadwinner.

"/ r V.{£P<2rr<.. /&- J & L

Vrou • Wife..................................................................................................................................... r

Ander afhanklikes • Other dependants........................................................................................... r

Totaal • Total R

'Getal persone in gesin (broodwinner ingesluit)Number of persons in household (including breadwinner).

Meld ouderdomme van afnanklikesMeio ouoeroomme van atnanklikes y , State ages of dependants................................................................................

Rede vir afhanklikheid Reason for dependence.

. Minderjariges van 16 jaar en ouer wat selfopderhoudend is, moei uitgesluit word) ^inor children of 16 years and older who ye self-jtipporting must be excluded)

f Datum van ongeluk/besenng O' / if / L — • Plek K J Date of accident/injury......................J.rr / .................................... Piac,

Persoon wat beseerde ingebring het Person who brought in the injured.

Sy/Haar adresHis/Her address..........................

Sy/Haar handtekening en voertuig No His'Her signature.............................................................................................................................................. and vehj, | | No

Was beseerde: (i) Onder die invloed van drank? Was injured: Under the influence of liquor?..

(ii) By sy/haar bewussyn?Conscious?...........................

Geteken: Opnemingsbeampte Signed: Admitting officer.......

Die aard van die pasient se siekte mag vir rekeningdoeleindes vrygestel word. The nature of the patient's illness may be disclosed for accounting purposes.

Getuie Witness.

Datum Date......

GetekenSigned....

KlagteComplaint..

Huidige siekte Present illness

T.P.H. 25B

SLEGS VIR AFSKEURSTROKIES FOR COUNTERFOILS ONLY

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TO s THE SUPERINTENDENT NATALSPRUIT HDSPITAL

CONSENT TO SUPPLY CONFIDENTIAL KFnTPftl RrPnPT

NAME OF PATIENT

HOSPITAL REFERENCE NO

DATE OF TREATMENT

I» the undersigned>

Z-jt-W jcj-z.

do hereby request and authorize you to give a medical report on the injuries sustained and treatment received by me, and to supply copies of all medical records, x-rays and records of any other form of treatment to : -

THE STATE ATTORNEY 8B8 ROYAL ST.MARY'S BUILDING

85 ELOFF STREET PRIVATE BAG X9 JOHANNESBURG

as a matter of urgency.

I have fully considered the implications of my actions and authorize you to give all my medical records to my legal representatives or any private doctor they may advise me to see.

SIGNED at thiE the Cff^day of 1992.

AS WITNESSES s -

2. Cca r-C

SIGNATURE- OF CONSENTEE OR RIGHT HAND THUMB

Collection Number: AK2702 Goldstone Commission of Enquiry into PHOLA PARK Records 1992-1993 PUBLISHER: Publisher:-Historical Papers, University of the Witwatersrand Location:-Johannesburg ©2012

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