oa AFFIDAVIT (Main Division) Inthe matter between: {AN TSUMIB MANNETJIE GABISEB BANDU KOMOB DaWiD WILLEM ANNA AIS. ELIAS |AOKOEOS GUXAB ALEXANDER ARAEB. NIKODEMUS HABUE HAWASEB: DAVID OASEB and ‘THE GOVERNMENT OF THE REPUBLIC OF NAMBIIA [NAMIBIA WILDLIFE RESORTS LTD HAI|OM TRADITIONAL AUTHORITY NAMIBIA DEVELOPMENT CORPORATION IGOABAUB HAI|OM ASSOCIATION NAMIBIA POWER CORPORATION (PTY) LTD ‘WEXFORD INVESTMENTS (PTY) LTD. JOACHIM LENSSEN NAMIBIA HD MINING AND INVESTMENT eemuD ANDREAS TUTA RUNONE NAMIBIA WATER CORPORATION LIMITED a s /2/°" were wien court oF Namiaia CASE NO: A 206/2015, {APPLICANT 2° APPLICANT 39 APPLICANT 4° APPLICANT 5 APPLICANT 6° APPLICANT 7 APPLICANT 8" APPLICANT 9" APPLICANT ‘4 RESPONDENT 2°'RESPONDENT 3 RESPONDENT 4 RESPONDENT ‘5 RESPONDENT 6 RESPONDENT 7 RESPONDENT ‘8° RESPONDENT ‘9 RESPONDENT 410 RESPONDENT +11 RESPONDENT ee WH Mad cctearedeEHIROVIPUKA CONSERVANCY ‘SHEVA SHUUSONA CONSERVANCY KING NEHALE CONSERVANCY (OSHIKOTO COMMUNAL LAND BOARD (CHAIRMAN) ‘OHANGWENA COMMUNAL LAND BOARD (CHAIRMAN) ONDONGA TRADITIONAL AUTHORITY ‘OUKWANYAMA TRADITIONAL AUTHORITY ‘THE COUNCIL OF TRADITIONAL LEADERS ATTORNEY GENERAL |. the undersignes, JAN TSUMIB, Do hereby make oath and state tha: 1. am the fist applicant inthis matter. 2. Allofthe facts deposed to by me herein are within my own personal krowlede, Unless indicted tothe contrary or as the contest may imply, and are tothe best lof my knowledge tue and correct. Where I make legal submissions, \do.s0 on the basis of advice by my legal representatives. correct 3,1 have read the answering affidavit of ABED SHUM yaSHIIMI. | frstprovide a 12 RESPONDENT 43 RESPONDENT 44 RESPONDENT 418 RESPONDENT 46 RESPONDENT 17 RESPONDENT 18 RESPONDENT 419 RESPONDENT 20% RESPONDENT general response to it, and then respond ad seratim to each paragreph Us | believe that advice to beGENERAL RESPONSE 4. The affidavit claims that the Haillom did not have exclusive ownership or beneficial use of Etosha. It claims, futher, thatthe Aandonga people infact hhad rights to Etosha that exclude the Haillom ftom claiming the land. It relies (on the deponent's personal knowiedge and oral history that has been passed down amongst the Aandonga people. 5. The Applicants have five general responses tothe affidavit 6. Fits, itis wrong as a matter of fact, The Applicants wil fle, together with this affidavit, an expert report prepared jointly by Robert Hitchcock, Thoma: Widlok land Ute Diekmann which responds to the historical claims Shimi yaShimi ‘makes. They demonstrate thatthe historical record in fact confirms thatthe Haijom gid have beneficial ownership, use and occupation of Etosha, To the cextont thatthe Aandonga or others entered Etosha without the consent ofthe Haillom, they were acting unlawful in violation of the Haillom people's rights. ‘Those unlawful acts did not undermine the legimate Haillom claim to he land. 7. The position set out by the experts confims my own knowledge of the history ‘of my people which I set out in the ad seria response below. cond, at best forthe Respondents, the afdavit rates a dlsputo of fet. That sa dlapute that will ned tobe determined at tial. Allthe relevant experts wil have to testy to alow this Court to determine whether the Applicants have established ther claim. The existence of a sispute of fact isnot reason to refuse to allow the applicants to represent the Haillom people in a representative action so thatthe dispute of fact can be determined, Ul10. 1. 12, ‘Thitd, even if his evidence, tothe effect thatthe Haljom did not exercise rights of ownership or exclusive beneficial use over the entire Etosha National Park and its resources, were to be accepted in whole o in part, this would net defeat the Applicants’ ciaim. It would serve only fo reduce the extent ofthe land to ‘which the Hallom are eniled, or to show that ther rights over part ofthe land claimed are not exclusive rights, That does not defeat any of clams wich are rot premised on exclusive ownership rights Fourth, the affidavit relates only to part ofthe land claimed by the Haillom, even if twas all accepted as tru, it would not defeat the calm, but limit. That is no reason to deny the Applicants the right to represent the Hailom people in a representative action Eh, Applicants’ third and fith claims do not rely onthe claim of beneficial use and ownership. They rest, instead, on the violation of the Haillom people's human rights as protected by international law, Those rights were violated ‘whether or not the evidence in Shimi yaShim's afdavit is accurate, In sum, given that there is, at worst for the Applicants, a factual dispute about the nature and extent oftheir occupation and ownership ofthe subject land, the dispute should be resolved at trial. tis Largely ielevant tothe lites question before this Court — whether the Applicants should be entitled to represent the Haillom people in that ti [AD SERIATIM RESPONSE, 13, ‘Ad paragraphs 1.2 ut|/do not personally know Mr Abed yaShiimi. Save for neting the content of these paragraphs, | do not take any issue with what is stated therein 14. Adparagraph 3, ‘The deponent does not state the bass for his expertise regarding the history of Etosha and the lands described inthis paragraph, 18. Adparagraph 4, | admit the content of is paragraph 16. Ad paragraph 5, | admit that the Applicants, including mysel, contend and continue to contd that histricaly the Haijom held beneficial and exclusive rights over the lands which include Etosha, | deny that there is any misrepresentaton in any respect ofthe factual {established historical records of our people and latly ofthe European missionaries ‘and two colonial administrations. Although {do not know about the oral hisory and praise songs ofthe Aandonga peopl, its unikely thatthe Aandonga people would hhave had oral histories and praise songs about the Haillom people. The praise song 's subjective to the Aandonga people. The deponent doesnot state tha the Aandonga told stories of the Hallom people that to have been passed down the generations as part ofthe oral history ofthe Aandonga people. As the expert report points out, the coral histories of the Aandonga are inevitably one-sided. uel"7 ragraph 6. {Ihave no knowledge of these alleged facts. However, Ido not dlspute the deponent's qualiiations to depose tothe history ofthe Aandonga people. 18. Ad paragraph 7, | do not know about the deponent’s grandfather and father or the other facts alleged In this paragraph. 19. Adparagraph 8 | nave noted the content of ths paragraph, and point out thatthe “subject land” the Etosha area ané the Mangett area. 20. Ad paragraph 9 | do not take fseue regarding thet which constitutes the Aawamnbo peopl. | know itis ‘ke that today ~ that there are several tibes who together are known as the Aawambo people of Namibia | also know that each of the Aawambo tbes was and ao distinct because they each had and sil have ther own respective kings and admiistrative structures and geographical areas, none of which were or are inthe “subject and”. | deny that the Aandonga people had a “radiion of mining saltin the Etosha pans, or that they had any connection with the mining of copper in Tsumeb. tis common established knowledge that the Aandonga and other Aawambo people taded for al TFcopper and salt with the Hajom people. The young iniates ofthe Aandonga people were sent to recover sl fom the Etosha sal pans, after which they retumed to their people. The Aandnga people didnot physically and permanently occupy ary part of {he subject land or permanenty or traditionally mine th sal pans in Etosha conf this is my own understanding ofthe history ofthe Haim people. 2. Adparaaraph 10, | do not have special knowledge of the migration of the Aawambo and other Ban tribes from other regions in Attica, though I know these stories from our own oral histories and accounts ~ how Haillom people sheltered certain people from me to time and pointe them to adequate grazing and water throughout the Nosh Central Namibia areas in olden times. There were no permanent settlements of any ofthe ‘Aawambo tribes in the subject and. | do net know any ofthese places ~ Maakuku or (Oshamba or how far they are from the Northern boundary of present day Etech 22. Ad paragraph, |1do not deny these allegations. Although | point out thatthe regions mentioned by the ‘deponent are not and have not been exclusively occupied by the Aawambo people. | ‘also note that these areas are not part ofthe subject land 23. Ad paragraph 12, | have noted the content ofthis paragraph. The Haillom people themselves did not ‘occupy such a large teritory as the whole of Namibia. There are other San people in LyNamibia which have their own distinct cultures and languages and histories and who have radiionaly each occupied their own distinctive teenies in present day Namibia 8 did the Haijom peopl. 24. Ad paragraph 13, 2a 242, 243. | dony that the deponent has qualified himself to make an expertopinion regarding the mode of existence ofthe Haljom people. By his own admission his family was historically acquainted with afew San who were inthe bondage of the Aawambo people —used as servan's, cate, herders and trackers. ‘The Hailom people di not bud stuctues fom materials other than what was necessary to provide shee. | have already slated thatthe Haijom people had permanent settlements throughout the subject land ‘and further afield. These were mosty situated atthe various water ‘sources, The men hunted and followed game asthe seasons dictated ‘Similarly women gathered veldkos which vaied according to seasons. | point out that there are no permanent Awambo buildings on the subjact land or any evidence of such | deny that San people migrated to Etosha because ofthe game inthe atea. The Haljom already occupied the area and conserved the natural resources in acsoxdance with ther mode of living on those lands. This ‘occupation may have been as a recut ofthe ample resources ofthe area, however the Hallom did not migrate therefrom somewhere els. Thus the game was always plentiful until it was decimated by foreign hunters inthe 1800's. The deponent himsei has already stated that the ut rr‘Aawambo found the San people in occupation when they settled in the northern parts of Namibia, 25, Ad Paragraph 14, ‘To the extent that there were no wars between the Haillom and the Aandonga people | admit that there was a peaceful co-existence. 1 deny however that the peaceful co- ‘existence occured onthe same shared teitories occupied by the respective groups. Furthermore, iis in my opinion a generalisation that “San worked as cattle herders and trackers for Aawambo" and that “Aawambo provided sholtor and food tothe San intimes of need. | say this because although there may have been instances of such ‘employment of San people, this was net the norm. The Haillom people continued to pursue their own livelihoods long before and long after the Aandonga people settled inthe area which they presently and have traditionally occupied which are not part of the subject land, The Hallom people didnot have to learn how to hunt and gather ‘veldkos from the Aandonga people o ely onthe Aawambo people to “provide shel and food 26. Ad Paragraph 16 26.1. | deny that the reason that there was a peacelul relationship setween the Aandonga and the Haijom has any sigifleance. Each accupied their own distinctive terrtores and merely taded with one another rom {ime to tie. To make my point | can stato that the Hallam and the Nama people of the south of Namibia also Ived peaceful with one another. This is simply because they did not engage significantly with Ut ns27, ‘one another and occupied distinc tritores. There was no competition for resources. Itis also not customary forthe Haillom people to engage in war with other people, Other than the singular incidences and skimishes with other tribes relating to livestock rusting, the Haillom ‘people are not known for wake tendencies. 26.2, The Aandonga may have established permanent settlements and courts ‘and claimed ttle over land, but this land was not inthe subject land of the Haljom people. itis false to suggest thatthe San peogle never ‘sought to acquire or assert rights to their tertories, Our founding and replying papers have narrated the basis on which we assert cur cam, Itis supported by detaled expert evidence. 26.3. The deponent states that it i only because the San people were not perceived as a threat that there was no confit. This suggests that is the deponents opinion that because other communities asserted themselves on the Hallo terrtories without fear of conic, thatthe Haijom clinuished their rights. | deny that this isthe case at al. Even during 1954 when the Haljom were evicted from the National Park, there were no oer tibe's members who were simiary evicted because none ‘wore in occupation. This recent demonstration of exclusive occupation ofthe Haim is implicit a a result ofthe historical recognition by other neighbouring tribes thatthe subject land was occupied and cortrolled by the Haljom peop as of right ~ at least unt we were deported from the park in 1954 ‘Ad Paragraph 16| do not know the source or accuracy ofthis information although it would appear that itis authored at the instance ofthe Fest Respondent. | do not deny that ror te to time that other people would utlise certain resources, but never ona permanent basis and fractionally and eticaly wth the consent ofthe relevant Hallom aurhonty in charge of the resource, | have already descibed for example how the Aawambo ‘people would be assisted by Haillom from time to time allowing them to water their ‘cattle o for forage during the pre-colonial migration of people of central Aftican origin, 28, Ad Paragraph 17. “This version isin confct wth the generally accepted historical fact. To the extent that, | have pointed out above, none ofthe resources were shared generally or a8 a rue Sometimes in times of drought and need the Aandonga and Aawambo people sought pastures and water inthe subject lands and the relationship between these people and the Hailjom was determined by the respective customs ofthe peoples fom time to time, | deny thatthe land or resources wore "shared" by the Haillom and other people. 29. Ad Paragraph 18, ‘Although I do not deny thatthe Aandonga may have had their own names for certain, places, | donot admit that because they had given a place a name that they came to ‘unit. | deny that there was ever a permanent presence of Aandonga or Ova or other people inthe subject and. Ihave never heard of any story that the subject land (ofthe Haillom was ever ruled by any kings of any other tribes Wy 3T30. Ad Paragraph 19, ‘Tho doponent stats thatthe Aandonga King hunted game in Okashana durng June ‘and July only tthe time that they needed some mea for their Mahangu. While I do ‘not even adritthat his was the case (because have never heard of any sos trom the Hallom oral histori ‘merely indicates thatthe King came once a year from his place tothe place thatthe Aandonga called Okashana to hunt. Even ifthis's tue, it does not constitute permanent occupation or any ether mode of ewmership of the lan, its widlfe and resources. And it does not affect the Hallam calm tothe lan. 31. Ad Paraaragh 20, {do not know this saying because itis the oral history made by the Aandonga people | not think itis easy to catch and castrate any wife such as the huntable game types ike Eland, Oryx, Kudu or Giraffe. The Hallom dé not castrate the animals since this would be very dangerous and counterproductive to nature. Even i this foklre Is ‘tuo, the Hillom people continued to hunt game despite the King ofthe Aandonga's belie that his castrated animals are holy. There are no records thatthe Aandonga ing forbade Hallom people trom hunting animals or that any confit had arsen as @ resuit 32. Ad Paragraph 21, | do not concede that the cattle herding song of the Aandonga people conveys any Important message in relation to the claim of the Haillom people, It seems te me that uy 3+the Aandonga people simply disregarded the realty of the existence ofthe Hallom people when they made their songs about their own affairs. The Haijom sengs and tories simiary do not record the interests of the Aandonga people who lived outside ofthe subject and 33. Ad Paragraph 22 Itis noteworthy that the deponent asserts thatthe Aandonga people didnot have to {88k for permission to hunt on the Hallom lands, yet a the same time coud not hunt without the expertise of the Haillom trackers and hunters. f the Aandonga people were the owners and occupiers of the subject lands, they would have ininsic traditonal knowledge of the movement of wilsife and how to track and hent them without the need to ety on the tradiional knowedge of the Hallm for this purpose. ‘They would not have to ask the Haillom to hunt. they dia 34, Ad Paraoraph 23, | do not have any knowledge of the story related inthis paragraph, 35. Ad Paragraph 24 As | pointed out above, the initiation procedures of the Norther Tribes required the inates to travel by themselves through unfamiliar lands and dangers and fo return wth irom the Haillom pans as a test oftheir adulthood. If the salt pans were part ofthe tribal lands of the Aandonga, then itwould not bea task ft fr intiation purposes.‘The initiates did not settle in the subject land and always retumed home after geting some salt 36, Ad Paragraph 25, ake note ofthis song's lyrics, but have no prior knowledge of i 37. Ad Paragraph 25, | know that the practise of salt mining continues to this very day. Except the salt pan ‘rom which the inflates harvest salts not the sal pan inthe subject land, but adjacent to the National Park on the northern side. It not clear from the affisavit why the ‘Aandonga people didnot ask for any permission from Haillom when they wert to theie {eritries to take these resources from them. 38. Ad Paragraph 27 38.1. know thatthe Hallom people also occupied the area now known a. ‘Teumeb and raded the copperto various peoples, incuding the rothern tribes, for things such as mahangu and tobacco. | did not rear any stories thatthe Aawambo mined any minerals there, but rather they traded withthe Haifom people to get the capper ka many others. 38.2, | also note there is no map attached, nor have | received any tom the ‘eponent. Despite the Applicants legal representatives” request othe Respondents’ legal representatives to prove @ copy ofthe map, no such copy has been received or confirmed. | attach copies of this ul 7correspondence marked JT1. The only conclusion to draw is that this ‘map does not exist. 39. Ad Paragraph 28. | note the content ofthis paragraph. 40. Ad Paragraph 28, 40.1. The Aawambo did not exclusively mine at Tsumab. if they corstucted the tunnels they would not getlostin them. Instead the unfamiliar layout could have led some Aawambo people who were mining without permission to go astray. It does not make sense to caim that ifthe Aawambo came and asserted themealves as owners of another's resources that this transfered any tile to the Aawambo kings 402. {repeat that theres no map attached, nor have the Applicants received ‘any from the Respondents, 41. Ad Paragraph 30, | do not know about the incident described inthis paragraph. 42, Ad Paragraph 31 | de not know when the songs were produced that testified to what the Ondonga kings ‘maintained was theirs, According o the deponent the Aandonga have apparently long Lt]regarded many things a8 thers which were not. The deponent does not sate any Aauthorty for his assertions thatthe Kings of Aandonga regarded all the mentioned teritory as their own, This assertion is simply nt borne out by, among othe things, evidence of occupation of Hallom peopl andthe lack of any evidence of occupation by the Aandonga people inthe subject land and elsewhere atthe places mantoned. | deny again that there ts any map attached to the deponent’s afdavit. 43. Ad Paragraphs 32-38, ‘The deponent does not state the reasons why the King Kambonde sold the land to Jordan. He did not own it. Nordid the Herero Chief, The absence of any opposition to the sale from the Haillom people or the fact that the Haillom people did not rmurderldispatch Jordan does not mean that the Haillom did not exist on the land or ‘that they voluntary gave up any oftheir rights to the Aandonga king or anyboty ese. 44. Ad Paragraph 39. ‘have no knowledge of any precooil catle pots Inthe South and SouthEast pasts of Eloaa, There asp no sch aos. The porn oon no ain sate wen these alogod ctl posts were stbished. Tshisbi enol part ofthe subject land ood nts appcaton. | now that hae ar many rock in the ity of Maka ode but dont know pon which onthe Aandong sharpened the speare or which may have speci stgnicace tote Aandonga people. Tere stay about the Anwarbo labore who was eetiring home fr the min ne early 1000's wih his esock anda car, When hose to lng the Halon poole chased him outa he went home Hy TT45, Ad Paragraph 40 | deny the contents ofthis paragraph forthe reasons set out above. Ton bared Jan TSUMIE | hereby dectare that the deponent has sworn to and signed this statement in my presence at OSHIVELO on the 1éth day of JUNE 2017 and ha declared a follows: that the facts herein contained fall within his personal knowiedge and that he understands, the contents hereof; thathe has no objection to taking the oath; that he regards the oath ‘as binding on his coneclence and has dectared as follows: swoar thatthe contents ofthis Swom Atay Hetso tee re God? Utea gos folsale, a “ COMMISSIONER OF OATHS! Garver cape” ruunames: MOS oorcaLe TPAETAA TPusoaica capaci. Sergeant pooress) omar OSKIVELLeoeta Peter Watson From Peter Watson Sent Frey, 21 Ape 2017 203 Pi to "Wimion Wicob Subject ‘JAN TSUNA 8 OTHERS v GAN & OTHERS AFADAVIT OF ABED Shi ye Shi Legal Assistance Contre moron Tt evap 2s Fema 2s Fro: Lovie Naam haa [mai ovataiwae@gnal com Sent Thuredby, 23 Ap 2017 3:32 PM Tor PeterWtson ‘tbjec Rec JANTSUNAIS& OTHERS v GRN & OTHERS: AFHOAVIT OF ABED Shi ya Si Goode-day Me, Watson, tam only seeing your email now. Our ofice closed at 10h00 as all government offices today as pe the tdzcctives of the Prime Minister. I's rater short tice and Tam out ofthe office {wil ony be able to ‘toos the fle next week, aditonally will only beable to Use with Mr. Nekwaya who previously handled the mater by next week Best Regards, Sent From my iPhone (On 13 Ape 2017, a 11:55, Peter Watson wrote: Dear Ms tala, Mr ya Shi efrs toe map t paragraph 31 in his afidevit. However, we donot have copy ‘rite map. Please would you let me have its soon as posible. We consult with ens this weckend and would appreciate tif this could be made avilable to us before te close of Tusiness today. ‘Many thanks and kind regards, Pster WatsonTO: THE REGISTRAR HIGH COURT OF NAMIBIA MAIN DIVISION - WINDHOEK AND TO: — GOVERNMENT ATTORNEY gots LEGAL PRACTITIONERS / FOR FIRST RESPONDENT i co 2 FLOOR SANLAM CENTRE . INDEPENDENCE AVENUE WINDHOEK COPIES RECEIVED: DATE: TE: pp Goverment Aoney ANDTO: — SHIKONGO LAW CHAMBERS, LEGAL PRACTITIONERS FOR THIRD RESPONDENT 4 BANTING STREET WINDHOEK WEST WINDHOEK ANDTO: KWALA& COINC LeekE PRACTITIONERS Liga MaincnrProtrere FOR SIXTH RESPONDENT “ Ene 3720 2a 6-16 clo FOUCHE & PETTENKOFFER selena PO Box 24350, Windhoek WINOHOEK REPUBLIC OF NAMIBIA (COPIES RECEIVED DATE... WLS) TNE: 33. pp kala & ColneFlos by Managing Judge: Parker J ‘Legal Assistance Centre Date of Hearing: 24 June 2017 Per Time of Hearing: 0Bh0 Legal Practitioners oll Case Management {or Applicants 4 Marien Ngouab Steet ‘Windrook / [AFFIDAVIT ~ THOMAS WIDLOK IN THE HIGH COURT OF NAMIBIA (Wain Division) CASE NO: A 20672015, In the mattar hana: JAN TSUMIB, +: APPLICANT MANNETJIE GABISEB 2% APPLICANT BANDU KOMOB 3 APPLICANT DAWIO WILLEM 4° APPLICANT ANNA AIS. 5” APPLICANT ELIAS IAOKOEOB GUXAB 6" APPLICANT ALEXANDER ARAEB 7° APPLICANT NIKODEMUS HABUE HAWASEB ‘8 APPLICANT and ‘THE GOVERNMENT OF THE REPUBLIC (OF NAMIBIA +" RESPONDENT [NAMIBIA WILDLIFE RESORTS LTD 2°4 RESPONDENT HAIOM TRADITIONAL AUTHORITY 3 RESPONDENT [NAMIBIA DEVELOPMENT CORPORATION 4° RESPONDENT IGOABAUB HAIIIOM ASSOCIATION ‘5 RESPONDENT [NAMIBIA POWER CORPORATION (PTY) LTD. (6 RESPONDENT WEXFORD INVESTMENTS (PTY) LTD ‘7? RESPONDENT JOACHIM LENSSEN 8" RESPONDENTNAMIBIA HD MINING AND INVESTMENT emuD ANDREAS TUTA RUNONE NAMIBIA WATER CORPORATION LIMITED. EHIROVIPUKA CONSERVANCY ‘SHEYA SHUUSONA CONSERVANCY KING NEHALE CONSERVANCY (OSHIKOTO COMMUNAL LAND BOARD (CHAIRMAN) ‘OHANGWENA COMMUNAL LAND BOARD (CHAIRMAN) ‘ONDONGA TRADITIONAL AUTHORITY ‘ONKWANYAMA TRADITIONAL AUTHORITY ‘THE COUNCIL OF TRADITIONAL LEADERS. ATTORNEY GENERAL |. the undersigned, ‘THOMAS WIDLOK {do hereby make oath and say that 9" RESPONDENT 410 RESPONDENT ‘14 RESPONDENT 42 RESPONDENT 43” RESPONDENT 44 RESPONDENT 18 RESPONDENT 16 RESPONDENT 17 RESPONDENT 18 RESPONDENT 410 RESPONDENT 20 RESPONDENT 1. 11am an adult male employed as a Professor forthe Anthropology of ‘Atica, University of Cologne, 50523 Koln, Germany. 2. have personal knowledge of the facts confirmed by thi affidavit, unless I state or imply otherwise, and they are rue and corte 3. 1 confirm that | participated in the dratng ofthe report, ‘Response to the Abed Shimi yaShimi Afidavit, with Dr Ute Dieckmann and Prof Robett Hitchcock. have expert knowledge of the contents of that report