STATEMENT

1. I the undersigned, Brett Norton Herron, am an adult male Member of the Western Cape Provincial Legislature, Secretary-General of GOOD, a registered political party, and a lawyer, with an office address at 4th Floor, 7 Wale Street, Cape Town.

2. I have received copies of conversations conducted in three WhatsApp Groups that relate to the acts of terrorism, insurrection, looting and violence that followed the incarceration of former President Jacob Zuma.

3. These three WhatsApp Groups were called (saved on the USB stick attached):

• ETHEKWINI SHUTDOWN

• INK SHUTDOWN 10/07/2021

• FREE ZUMA INFORMATION 4. The “ETHEKWINI SHUTDOWN” WhatsApp group was set up with the primary

objective of promoting and coordinating actions in Ethekweni. It was opened on morning of the 8th July 2021. Instigators and potential instigators were then encouraged to join the group through its link.

5. The “INK SHUTDOWN 10/07/2021” WhatsApp group was set up on the 9th July 2021 at 11:31 am. “INK” refers to Inanda, Ntuzuma and Kwamashu regions in the ANC. This group’s objective was promoting, coordinating and sharing information of actions in “INK”.

6. The “FREE ZUMA INFORMATION” WhatsApp group was created on the 8th July 2021, initially called FREE ZUMA COORDINATORS. This group’s objective was promoting and sharing information on actions around the country. Notable members in this group include Carl Niehius and Andile Lungisa.

7. We have identified individuals who participated in these groups and are directly implicated in the insurrection.

8. Our information was obtained from whistle blowers, researchers and members of the public who approached us with information to act upon.

9. It is clear that these WhatsApp groups contain clear evidence of incitement, planning and involvement of many individuals in the insurrection, looting and acts of terrorism witnessed in KwaZulu Natal and Gauteng.

10. The names were obtained from information volunteered to us and sourced through researching the mobile numbers, True Caller and submissions from various whistle blowers.

11. The names and numbers that have been identified to date include the following 26 people:

• Samke Gumede: 0722232050, ANC member ward 77 eThekwini, possibly a Senior Clerk at eThekwini Municipality (Samkelisiwe Gumede)

• Jeffery Mzobe 0711598033

• Sandile Zakhele Masuku, 0812402397 is an ANCYL member and works for uMhlatuze municipality.

• Vusi Mavura 0827320014

• Zinhle Hlengwa, Ward 56 ANCYL Ethekweni 0659818222 claimed to be Cele’s niece

• Mbali / Lerato SANDF soldier- 0672008355

• Nkukluleko Zulu (sherrif) 0744959688

• Bongie Ayanda Khanyeza 0824387411

• Mduduzi Mkhize 0823246806 self proclaimed MKMVA person who was at Nkandla

• Linhle Mnguni 0781889210

• Tsekiso Simamane 0769416123

• Ziphoh Djvezah Zuma Mtungwa 0736444763

• Thabile Mazibuko 0848076763 works as an administrator for ANC MPL

• Sibusisu Gwala 0839235510

• Mabongi Thabede 0797338258

• Henry Siyabuka Mdunge 0635549741

• Sibonelo Xulu 0622331045

• Dumisane Nhlapo 0766432686

• Sipho Mhlongo 0722601249 Zulu regiment protested at Nkandla and allegedly a member of the NFP in KZN

• Mbali Ka Ncube 0725031706

• Andile Lungisa 0789686760

• Sfiso Sokhulu 0621011640

• Siyabonga Shandu 0618090772 works at eThekwini municipality

• Lesley Kgogo 0824980498 (JHB)

• “Thulani Jabu”- 0744824720 (JHB)

• Senzo Nkabinde 0782179234 (JHB) 12. I have provided copies of these WhatsApp Group discussions on a USB stick

including examples of the apparent participation (in the form of voice notes, videos and screenshots) in the groups for those mentioned. There is a separate folder for each person.

13. Samke Gumede: 0722232050, ANC member ward 77 eThekwini, possibly a

Senior Clerk at eThekwini Municipality (Samkelisiwe Gumede)

She created the ETHEKWINI SHUTDOWN group. Messages include her first introduction on the 8th to everyone:

And others on the 8th of July include:

On the 11th of July:

14. Jeffery Mzobe 0711598033 joined 2 groups where he posted videos of actions,

messages planning and evidence of actions in the group:

Messages include:

• A video he filmed and sent of a roadblock where rubbish and sand were poured on the road at the very beginning of the shutdown.

• Numerous and inflammatory voice notes discussing activities

• WhatsApp messages including the following, notably “I have the equipment”

15. Sandile Zakhele Masuku, 0812402397 is an ANCYL member and works for uMhlatuze municipality. On the 9th July at 8:36 am he sent a video to the FREE ZUMA INFORMATION WhatsApp group, where he was at a roadblock with lots of trucks, blocking a major road and then a voice note in Zulu: His voice note (in Zulu) “We are very busy, let nxamalala out..... Comrades nothing is coming in and nothing is going out of Bay. We asking that wherever you are do the same close all angles , so that police don't focus on one area. We are asking that you go out to the road even if you are 10 you can stop 4 trucks. Block the roads with them, take the keys and leave”

16. Vusi Mavura 0827320014 - his messages include:

17. Zinhle Hlengwa, ward 56 ANCYL Ethekweni 0659818222

She was arrested, sent video and voice notes from inside a police van. She appears to have claimed she was Bheki Cele’s niece and convinced the police to release her. According to the messages she sent to eThekwini group. She was very active sending numerous messages, videos and pictures including from sites where looting happened. She also sent targets to the group that were later attacked, burnt or looted.

18. “Mbali” SANDF soldier- 0672008355 who stated in the group that she is a serving SANDF soldier: On the 9/7/2021 in voice note at 11:57am in ZUMA INFORMATION GROUP she said: “cdes lets save nothing, its time to burn everything even those shacks, these people they undermine us..”

19. Nkukluleko Zulu (“Sheriff”) 0744959688 appears employed by KZN Department of Health:

20. Bongie Ayanda Khanyeza 0824387411 was located, by what was posted in the groups, at several different places when looting was happening and was reporting back to the group, she also made several inflammatory remarks.

21. Mduduzi Mkhize 0823246806 – claims to be a commander of the Umkhonto we Sizwe Military Veterans Association (MKMVA). Mduduzi Mkhize was an administrator for the aforementioned “INK” WhatsApp group and sent the following messages:

22. Lihle Mnguni 0781889210 messaged from many locations that were attacked and sent the following messages to Ethekweni Shutdown WhatsApp group:

23. Tsekiso Simamane 0769416123 sent a number of messages including one voice recording on the 12th July 2021 12:35 am saying “we will retaliate, their families will cry, we are going to kill them back, we will burn them”

24. Zipho Djvezah Zuma Mtungwa 0736444763 several messages in the

Ethekweni shut down group including this one:

25. Thabile Mazibuko 0848076763 an administrator in ANC MPL Hon. AG Mapena office sent a video message on the 11th July 2021 at 7:48pm of a road being blocked with sticks and then a video of a Spar- in the video he says “We have closed Porter/Botha, now we are going to empty Spar...”

26. Sibusiso Gwala 0839235510 messages include:

27. Mabongi Thabede 0797338258 Sent a video of a man burning tyres and calling the activity a revolution.

28. Henry Siyabuka Mdunge 0635549741—Posted several voice notes and one in Zulu out of breath after sending this picture:

29. Sibonelo Xulu 0622331045 sent a number of messages including on the 12th July at 1:17 am a video from Village Mall.

30. Dumisane Nhlapo 0766432686

31. Sipho Mhlongo, 0722601249, apparently a NFP leader and a general in the Zulu regiment. He posted a video of an ATM being broken and stolen using a small bulldozer.

32. Mbali Ka Ncube 0725031706- posted a picture of tyres preparing for the night ahead and then a voicenote saying “ lets become official terrorists of South Africa, lets destroy everything that comes our way” at 11:28 pm on the 9th July to the Zuma Information group.

33. Andile Lungisa 0789686760.

34. Sfiso Sokhulu 0621011640, he claims to be employed/volunteering at the ANC, he appears to have directly planned an attack on Bridge city mall. He also sent a video in which a man is talking, it seems to be him- it is not forwarded.

35. Siyabonga Shandu 0618090772 appears to be employed at eThekwini Municipality. Sent messages planning and video from Bridge City Mall and several other messages when he appeared to be inciting the “shutdown” messages include:

36. I am handing you a USB stick, which contains screen videos of the three WhatsApp Groups plus folders for those mentioned above with audio-visual content in each folder.

37. I am requesting that you include this information in your investigation into the events that occurred in KwaZulu Natal and Gauteng, described by the President as an insurrection, and investigate those in these groups for their participation and instigation of crimes of sedition, terrorism, destruction of infrastructure, theft and looting.

38. The original audio visual material will be available should you need it. Signed at Cape Town on this day of August 2021 BRETT NORTON HERRON