Broadcasting Bill: public hearings

Documents handed out:
Independent Producer's Organisation of South Africa (Appendix 1)
Radio Islam (Appendix 2)

Independent Producer's Organisation of South Africa
The Independent Producer's Organisation of South Africa representing local film and motion picture producers presented their written submission through their national chairman. The submission focussed on three issues regarding the Bill, namely: the Structure of free-to-air television in South Africa; local content; South African Broadcasting Production Agency/ Advisory Body.

Regarding the structure of free-to-air-television in South Africa, the IPO expressed their regret at the lack of clarity of the Bill on the exact number and structure of public and private free-to-air terrestrial television stations. This causes problems. As a result the IPO proposes that: SABC 3 be privatised as soon as possible; Bop TV be transferred to the Department of Education for redeployment as a national Education and Youth TV channel with private equity partners; reduce SABC TV to two channels having regard for their public service mandate and local content regulations; transfer the proceeds from the sale of SABC 3 to the South African Broadcasting Production Agency making funds available for local TV content on all five free-to-air stations.

This will produce the following structure of national free-to-air television: SABC 1; SABC2; Education and Youth channel; Midi TV; Private SABC 3

The IPO supports the policies of promoting local television content as articulated in the White Paper and Broadcasting Bill. The IPO regards it as unfair that terrestrial television should be regulated for local content while satellite television broadcasts a negligible amount of South African programmes. For this reason they support the proposed extension of local content regulation to the multi-channel broadcasting delivery system and further propose the following additional clauses to the SABC's objectives:
8 (q) to broadcast a significant amount of South African music and television, according to the regulations of the Authority;
(r) to include a significant amount of South African television programmes, acquired from the independent production sector, according to the regulations of the Authority.

The IPO further noted that the South African Broadcasting Production Agency, proposed in the White Paper has been changed into the South African Broadcast Production Advisory Body in the Broadcasting Bill. If this was done as a way of avoiding the financing obligations of an Agency, the IPO proposes that the proceeds of the sale of SABC 3 be transferred to the Agency so that it could operate a fund to finance local television content on South African television.

Questions raised by committee members:
Ms Vos (IFP) expressed her support of the concept of greater local content. She asked if the IPO proposes that in terms of the multi-channel system, every channel should have local content requirements. She further stated that she thought that the law states that the proceeds of the sale of any state asset should go directly to the state revenue fund.

Ms Van der Merwe (ANC) stated that according to the IPO model if the SABC 3 is sold off, how should the other SABC channels be funded to address their public mandate.

Mr Kekana (ANC) also asked how the IPO foresees the funding of the Agency other than the models presented, because the proceeds of the sale of SABC 3 would be a once-off payment.

Response from the IPO: Government should be an important instrument of financing the Advisory board or agency. It is also important that SABC 1 and 2 must still remain commercially viable, being able to compete for the market. This should be their main funding. They further stated that it would be unrealistic to expect every channel to submit to local content requirements.

Ms. Vos (IFP) asked what kind of advertising support do producers get for local productions.

The IPO responded by quoting examples from Australian television where local content in the 1960s and 70s started with little support but today receives the most support. It is difficult to unpack the SABC accounts but it is evident that of the ten most popular programmes, many are local productions. Advertising follows the popular programmes.

Mr. Kekana (ANC) asked how many jobs are created by local productions and if possible how much does the local production industry contribute to the GNP?

IPO responded by saying that there are no current statistics available regarding the contribution to the GDP and the number of jobs. It would be a good idea if the department could commission such as study. In the case of the TV programme, Generations, it employs over a hundred people per show. It should also be recognised that there are many secondary industries that also profit from local productions such as the hotel and catering industry etc.

Mr. Marsh (ANC) asked whether the provisions of the bill regarding local content go far enough in the eyes of the IPO to address the problems facing local industry. According to the SABC to air local productions costs eight times the cost to air international productions.

Mr. Green (ACDP) asked whether it would not be more appropriate for the Departments of Arts and Culture and Education to be involved in the debate about the transfer of Bop-TV to the SABC and the mandate thereof.

Ms. Vos (IFP) stated that there is already talk that government is seeking a wider frequency for Bop-TV. Thus far she has not heard any complaints from Midi-TV. How great an impact would this have on a station such as midi-TV?

The IPO responded by disagreeing with the argument of the SABC regarding the cost of local productions. International productions cost just as much but are imported at a fraction of the production cost due to the fact they have licensing rights. The state of the Rand also has brought local production cost almost to the level of that of international productions. The Bill does not go far enough. Criticism from international producers with whom South Africa has signed co-operation treaties is that there is no domestic incentives from government to persuade them to come and produce films locally. The government should address this problem to attract foreign participants. The IPO further suggested that agencies should work together with different departments such as DTI, Department of Education and Arts and Culture to fund local productions. Currently different departments are funding different functions of the same industry. There should be greater co-operation.

Hereafter the Department of Communications was allowed time to respond. They stated that the function of the Agency was carried over to the Advisory Board due to problems of resources. It was thought that the advisory board was limited in terms of resources but in the same sense the advisory board will be in consultation with the film and video board and with other departments to give full effect to the functions traditionally envisaged for the agency. The proposed study on the contribution of local productions to the GNP and other indicators is already in the pipeline. Other countries' methods of supporting local industries will also be investigated.

Radio Islam
Radio Islam as part of the National Independent Broadcasters Association stated that it endorses the written submissions already delivered by that organisation. The Bill and the White Paper on Broadcasting both give the impression that it is the aim of these policy papers that as wide a range of interests should be addressed. Radio Islam is committed to the objectives of the Bill which is essentially an empowerment issue but the current bill is restrictive in this sense. The past has created inequality in many aspects. The Bill requires the demarcation of South African society into geographical areas and no indication is given as to how this will be done and how the interests of communities in regards to language, religion etc. will be addressed. A geographically-defined area will not be homogenous. The White Paper speaks on the need for religious based communities to be able to air, in practice however the Bill denies these religious communities their rights. Religious communities perceive themselves under attack. The legislature runs the risks of alienating certain sectors of the religious community from broader inclusion.

The representative of Radio Islam asked the committee to reconsider carefully the matter and proposed that the Bill should not get rid of the concept of a community of interest but should rather limit the number of licences. Radio Islam should be allowed the right under the IBA Act to apply under legal procedures for a broadcasting licence and should be able to compete for those rights with other stations.

Questions raised by committee members:
Mr. Kekana (ANC) stated that the IBA indicated that it has 300 frequencies to distribute to a vast number of community of interest radio stations. A large number of licence applications are by religious communities and a majority of licenses are not in areas that promote the interests of formerly disadvantaged groups. Given this and the limited available resources, attempts are made by the legislation to find a solution. There has been a tendency that community of interest radio stations are selfish in allowing broadcasts of other interest groups. He here referred to the example of Radio Pretoria.

Mr. Marsh (ANC) also noted that with the definition of community of interest groups in the IBA Act it allows for a large number of groupings competing for limited resources.

Ms Vos (IFP) asked whether it would satisfy Radio Islam if the current wording of the Bill was maintained but the IBA be given the mandate to decide on the balance between the community of interest needs against that of geographical requirements in the bidding process for a license.

Mr. Marsh (ANC) commented that frequency should be demand-driven and not based on technological issues. The problem is that community of interest radio stations could be able to extend their signal to the rest of the country in fact then trespassing on the rights of geographical communities. He asked Radio Islam for a solution on how the committee should amend the Bill without dividing the community.

Mr. Dockrat, representative for Radio Islam, responded by saying that the problem is that a strict interpretation of the Bill will result in the closing of many community of interest radio stations. The Bill does not however amend the definition of what a community is but limits and extends the definition to a geographical area. Geographical-area communities should be able to compete with a community of interest radio station for a particular frequency licence. The problem is what numbers will define a geographical area and will the IBA be able to address the problem of deciding what interest group within a specific geographical area will best represent the community within that specific area. The government should take note that South Africa is in essence a religious society and religious communities should be consulted. The Bill should also be seen in the context that it sets for itself as addressing the interests of communities in a diverse South Africa. The proposal of Radio Islam is to maintain the status quo.

The chairman asked for any other comments, none were raised and the meeting adjourned.

Appendix 1: Independent Producers' Organisation

Independent Producers' Organisation

Written submission to the Portfolio Committee on Communications on the Broadcasting Bill [B94-98]

SUBMITTED BY: -

independent producers' organisation of south Africa

The Independent Producers' Organisation of South Africa (IPO) wishes to focus on three issues in the Broadcasting Bill: -

· the structures of free-to-air television;

· local content;

· the South African Broadcasting Production Agency I Advisory Body.

1. THE STRUCTURES OF FREE-TO-AIR TELEVISION

With regard to the structures of free-to-air television, the IPO is concerned at the lack of clarity in both the White Paper on Broadcasting Policy and the Broadcasting Bill about the exact number and structure of public and private free-to-air terrestrial television stations the Government envisages there will be over the next few years. It is a matter of concern that this has not been clearly spelt out in the policy and legislative documents because this leads to a lack of certainty both in the market place as well as the public broadcasting service, the SABC.

For example, the White Paper states that 'it is anticipated that one television channel and four radio stations presently operated by the SABC qualify as commercial services. The first question is why hasn't that one television channel been identified. The White Paper goes on to state that 'the former Bop Broadcasting shall be re-organised under the SABC as a separate for-profit business unit', which will be available free-to-air in Gauteng, and possibly nationally. The second question is whether it is Bop TV that is anticipated to become SABC's one TV station in its commercial arm which will cross-subsidise the public broadcasting arm. If this is the case does this mean that the SABC will still have three public TV channels (SABC 1, 2 and 3) cross-subsidised by its commercial TV channel (Bop TV). This leads to a third question. What if the outcome of the Education Task Term's investigation into the feasibility of a dedicated Education TV Channel, on which the SABC is represented, recommends that the SABC should establish a new Education TV Channel. Would this mean that the SABC would gain a fourth PublicTV station? This would lead to an absurd situation of the SABC having five TV stations to the one private TV channel, MID TV.

This is presumably not the case because the White Paper also states that the separation of the SABC into public and commercial broadcasting arms 'will be a precursor to a later; more complete restructuring of the SABC operational activities, which will review the scope and size of SABC commercial activities and investigate the possible privatisation of, and introduction of private equity to, the SAB C's commercial services. This review will not take place until the impact on the market of the private free-to-air television service can be properly assessed. ' There are two points here. Firstly, Bop TV is being given access to Gauteng without any review of its impact on the viability of MIDI TV. Second, there is talk in Government circles of selling a 30% share in SABC 3 to a private equity partner and of the SABC putting a management contract for Bop TV out to tender. Neither of these actions seem to be subject to any review or regulation and this throws into question the licencing of Midi Television. The Broadcasting Bill is silent on these matters - it merely makes the division between the SABC's public broadcasting services and its public commercial broadcasting services.

The issue of 'the possible privatisation of the SABC's commercial services' itself raises the question of how the cross-subsidisation of the SABC's public TV channels will be effected in the medium-to-long term if the SABC's commercial TV channels are to be sold. From past experience, the proceeds of sales go straight into the National Revenue Fund. This raises the question of the feasibility of the Governments' plan for restructuring the SABC in the long term.

The IPO would like to propose to the Portfolio Committee on Communications that it has a duty to clarify what exactly the private and public TV landscape will look like after the Broadcasting Bill is passed. The IP0 would like to contribute to clarifying the key structures of television by proposing the following way of reorganising public and private television in South Africa:-

· Privatise SABC 3 as soon as possible, subject perhaps to a market review as to the timing and/or phasing in of Strategic Equity Partners.

· Transfer Bop TV to the Department of Education for redeployment as a dedicated National Education and Youth TV channel, with private Strategic Equity Partners.

· Reduce SABC TV to two channels, SABC 1 and 2, but do not reduce their ability to compete for audience share, having regard for their public service mandate and local content regulations.

· Transfer the proceeds from the sale of SABC 3 to the South African Broadcasting Production Agency, which will make funds available for local TV content on all five free-to-air stations.

This will produce the following structure of national free-to-air television:-

· Education and Youth channel

· MIDI TV

· Private SABC 3

In other words, there would be two public TV stations (SABC 1 and 2), one public-private partnership (the Education and Youth channel), and two private TV stations (MIDI TV and the privatised SABC 3).

There is international precedent for specifying the exact number and structure of television channels. Britain has very clearly specified the number of TV stations in the Broadcasting Act of 1990, where it renamed ITV as Channel 3, changed the conditions under which Channel 4 operates and introduced Channel 5. The BBC has two channels to operate under its Charter. In small countries where the number of national terrestrial television stations is likely to be limited, this makes sense.

The IPO recommends that the Portfolio Committee attach a schedule to the Broadcasting Bill specifying the number and structure of national terrestrial TV stations which will operate over the next period.

2. LOCAL CONTENT

The IP0 supports the policy of promoting local television content on South African screens as it is articulated in the White Paper and the Broadcasting Bill. Local content is the lifeblood of the South African Broadcasting System, without which it would lose its character and become a vehicle for American programming. The process of getting local television programmes on our screens is in many ways an unequal struggle. US programming which is made with high production values has already recouped its production costs in its home market and is thus able to undercut local South African programmes in terms of price and production values.

If South African television is to have any chance of improving its quality and competing internationally, then it must continue to receive support from a range of policy, regulatory and educational measures as well as supply-side initiatives. Particular attention should be placed on training a new generation of South African programme makers who can bring the full experience of the diversity of South African life to our screens. The importance of local television to building a South African national identity and consciousness as well as its contribution to economic growth and activity cannot be underestimated.

In this regard, the IPO strongly supports all clauses and sections of the Broadcasting Bill, that deal with local content. These include:-

2 The object of this Act is to establish and develop a broadcasting policy, in order to regulate and control of broadcasting in the Republic and for that purpose to -

(b) safeguard, enrich and strengthen the cultural, political, social and economic fabric of South Africa;

(r) encourage the development of local programming content;

3 (5) The programming provided by the South African Broadcasting

system must -

(b) be varied and offer a range of South African content and analysis from a South African perspective;

(c) should be drawn from local, regional, national and international sources

(e) provide a significant place for programmes produced by the independent production sector.

27 (2) The programming provided by free-to-air broadcasting services must -

(b) provide an appropriate significant amount of South African programming according to the regulations of the Authority;

27 (3) The programming provided by commercial subscription broadcasting services shall be subject to licence conditions determined by the Authority specifically on South African local content and other conditions relating to the licence.

27 (4) The programming provided by free-to-air television broadcasting services must -

(a) include levels of South African drama, documentaries and children's programmes that reflect South African themes, literature and historical events, as prescribed by regulation; and

(b) include significant amounts of programmes acquired from the independent production sector.

27 (5) The Authority may make regulations on the amount of South African programming and other matters which reflect these circumstances, bearing in mind the objects of this Act.

33 (1) The objectives of Multi-Channel delivery systems are to -

(a) give priority to the carriage of South African programming services, and in particular, to the coverage of South African services;

(d) carry originating programming, including local programming, where the Authority considers it appropriate.

The IPO is strongly in favour of the extension of local content regulation to the multi-channel broadcasting delivery systems, in particular direct-to-home Satellite TV. It is unfair that terrestrial television should be regulated for local content while satellite television broadcasts a negligible amount of South African programmes. That state of affairs is simply cultural imperialism. Satellite services which are South African registered companies and uplink nationally must make their contribution to South African local content programming.

On the question of local content, the IP0 proposes two additional clauses to the SABC's objectives:-

8 (q) to broadcast a significant amount of South African music and television, according to the regulations of the Authority;

(r) to include a significant amount of South African television programmes, acquired from the independent production sector, according to the regulations of the Authority.

These clauses will bring the SABC's objectives into line with the existing local television content and South African music regulations as well as the clauses on local content and independent production specified in section 27 of this Broadcasting Bill which governs the objectives for commercial broadcasting licences.

3. THE SOUTH AFRICAN BROADCAST PRODUCTION AGENCY I ADVISORY BODY

It is not clear why the South African Broadcast Production Agency, proposed in the White Paper has been changed into the South African Broadcast Production Advisory Body in the Broadcasting Bill.

It may be that implicit in the concept of a Broadcast Production Agency that 'will be established to support the development of South African content' was the notion that the Agency would have a funding function with regard to local content. The Government may have changed the Agency into an Advisory Body on the basis that there was no money for local content funding.

The IPO has, in this submission, proposed that the proceeds of the sale of SABC 3 be placed in the South African Broadcast Production Agency which would operate a fund to finance local television content on South African screens. To transfer the proceeds of selling SABC 3 to the National Revenue Fund would only serve to impoverish South African TV further. This would be short-sighted of Government because there is a high, often intangible, value to the role which broadcast communications media can play in building social cohesion, fostering a sense of place, national community and pride. Governments and politicians ignore this social value at their peril. Local content on television is the primary means of developing national cohesion in a world of fragmentation.

Accordingly, the IPO recommends that the original concept of the Broadcasting Production Agency articulated in the White Paper be restored to the Broadcasting Bill. In addition to the tasks specified in Chapter IX of the Bill, the IPO recommends that the operation of a fund to support the development of local broadcasting content be added.

The IPO also recommends that the task of drafting 'a plan for local content coverage by broadcasters - for South African Broadcasters to reach a predominant local content in all genres within target period of 10 years' be given to the Broadcast Production Agency. This task was given to the Independent Broadcasting Authority (IBA) in the White Paper but not specified in the Broadcasting Bill. The IPO is of the view that this is a policy matter on which the Broadcasting Production Agency/Advisory Body could advise the Minister.

It is very important to keep the value generated by the sale of SABC TV stations inside the South African broadcasting system. This was the case with the partial privatisation of Telkom where the major portion of the proceeds were dedicated to Telkom's roll out targets. The IPO feels strongly that redirecting funds to a Broadcasting Production Agency for local content would be an innovative and far-sighted approach to building a national television culture for a new South African society.

Appendix 2: Radio Islam

Radio Islam

MEMORANDUM

A. INTRODUCTION

Owing to the unavailability of Goolam Ameer I was requested by Radio Islam to appear before the Parliamentary Portfolio Committee dealing with the Broadcasting Bill on 9 September 1998 to make submissions on behalf of Radio Islam.

On 8 September 1998 I was consulted by Moulana Dhorat and Moulana Variawah Of Radio Islam with a view to receiving from them documentation and information that would enable me to prepare the submissions to be made before the Parliamentary Portfolio Committee.

Since the consultation with representatives of Radio Islam occurred an the afternoon prior to the date of appearance, it was not possible to prepare and submit written submissions to the Committee.

B. PRESENTATION:

The following oral submissions were made on 9 September 1998 before the Parliamentary Portfolio Committee on behalf of Radio Islam:

1. GENERAL OPPOSITION TO ANTICIPATED EFFECT OF THE BILL:

An unequivocal opposition to the relevant sections of the Bill that would have the effect of disallowing the issue of broadcasting service licences to applicants serving a community of interest. In this regard reference was made to Section 1 read with Section 29 and Schedule 12(a) of the proposed Bill.

2. RESTRICTION DOES NOT EQUAL EMPOWERMENT:

A challenge to the assumption that restrictive legislation of the kind proposed in the Bill would have the effect of empowering disadvantaged sectors of the community by granting them access to community broadcasting. In this regard reference was made to statistics indicating that the large majority of applications received by and licences awarded by the IBA were granted to Applicants who served communities of interest. The fact that such communities of interest would now he removed from the list of potential licensees would not logically result in an increase in the number of applicants serving a geographically founded community.

3. WHAT IS A DISADVANTAGED COMMUNITY?

A challenge to the assumption that communities of interest are distinct from and accordingly in opposition to disadvantaged Communities which the Bill seeks to empower. In this regard the Committee was referred to various disadvantaged groups who would also constitute communities of interest. These would include workers, non-christian religions and women.

4. IMPRACTICALITY OF PROPOSED BILL:

It was contended on behalf of Radio Islam that by virtue of the heterogeneous nature of our society, the requirements contained in Section 29, more specifically Section 29(5) would cause more problems than it would solve. Competing interest and the like would effectively render the community broadcaster inefficient.

Specific mention was made of the fact that the proposed Bill does not contain a definition at all of "community". Schedule 12(a) amends the definition of Community Broadcasting Service in the IBA Act but does not deal at all with the definition of community in that Act. If community is to be defined for purposes of the proposed Bill as it is defined in the IBA Act the following should be noted:

1. The IBA Act definition is inclusive rather than exhaustive and reads as follows:

" Community include a geographically founded community or any group of persons or sector of the public having a specific, ascertainable common interest".

The relevance of this definition for the purposes of the proposed Bill is apparent to relation to Section 29(4) of the proposed Bill.

How does an Applicant identify communities in the licensed geographic service area and how does it satisfy itself that all communities in the licensed geographic service area have been identified?

What about identifiable communities within the licensed geographic service area who are apathetic and do not seek air time? How is air time allocation to be determined? Is it a number count or some other formulation?

What seems clear though is that an onerous task is placed on the shoulders of any applicant desirous of applying for a community broadcasting service licence

Related to this is the very real possibility that community broadcasters in an attempt to "reflect the needs of all of the people in the community" will give air time to all but satisfy none.

5. SOUTH AFRICA, A GOD CONSCIOUS SOCIETY:

It was submitted on behalf of Radio Islam that even the white paper recognised the importance of religion to the general South African society. The rights of religions and culture are entrenched in the Constitution

At the level of public policy it is desirable that broadcasters that encourage the rebirth of, the continued existence of, and importance of values and morality in our society be encouraged.

Whilst government on the one hand calls on religious leaders to galvanise their followers to restore values to our ailing society, how can it simultaneously introduce legislation that will curtail these very institutions from achieving this goal?

6. PERCEIVED ATTACK:

It was submitted on behalf of Radio Islam that religious communities view this Bill as an attack on religious freedom and the rights of religious groups to establish themselves in our cultural mosaic

One of the goals contained in the proposed Bill is to encourage unity. This legislation will do anything but that. It will have the effect, if it has already not done so, of alienating religious communities.

If the Act therefore produces a result directly in opposition to its stated intention how wise can the implementation of such an Act be?

7. IS IT REALLY AN ALL OR NOTHING SCENARIO?

It was suggested to the Committee that the Act seems to be premised on incorrect assumption that in order to achieve the objectives of the Act, licences awarded to broadcasters who serve a community of interest must be disallowed entirely. It was submitted that the Bill doesn't consider the least restrictive means of achieving its object. Whilst not ideal, limiting the number of community of interest licences available, might be a better approach.

It was also contended on behalf of Radio Islam that an alternative means to ensuring access to the airwaves might be by reducing the transmitter power for each licence granted thereby increasing the number of licences available.

C. SPECIFIC SUGGESTIONS BY MEMBERS OF THE COMMITTEE:

The following were made by members of the Committee:

1. That Radio Islam submit to them a written amendment to Section 29 incorporating the amendments that would make the legislation acceptable to Radio Islam. My view is that this should not he restricted to Section 29 and perhaps Radio Islam could deal with amendments to all relevant provisions of the Bill, as well as furnish the Committee with a summary of the submissions recorded herein.

2. It was also suggested by one of the members of the Committee that an enquiry be held with a view to dealing specifically with religious communities. The idea seems to be that religious communities and broad casting for religious communities be dealt with separately from other communities, be they geographically founded communities or communities of interest. This would seem to suggest an appreciation of the peculiar and important status enjoyed by religious communities in South Africa.

I endorsed this suggestion but I must point out that there were one or two other members of the Committee who opposed the idea of separating religious communities from other communities.

3. A representative of the Department made specific reference to Section 29 (9) which requires the establishment of a public enquiry that would deal with the implementation of geographically founded community service broadcasting and related issues. One can only assume that such a public enquiry would occur at a date after the promulgation of the Bill and one must question in these circumstances how effective such a public enquiry would in fact be.

4. Assurances were given by members of the Committee that:

a) The proposed legislation is not intended to curtail religious radio stations from operating; and

b) The Portfolio Committee is not a rubber stamp body and viewed submissions made on behalf of interested parties seriously, with a view to enacting legislation that would satisfy all.

It is of course too early to assess what impact (if any) the submissions made on behalf of Radio Islam has had but it is hoped that these submissions together with submissions from other groups, in particular the NAB will have the effect of convincing the Portfolio Committee to suggest to the Minister, that the Bill, if introduced, take cognisance of and thereby protect communities of interest in relation to the issue of community broadcast service Iicences.

One aspect not specifically dealt with by me at the hearing was the issue of "finite resource".

The Act deals with the airwaves as a futile resource. It is interesting that the Department, as well as the Minister himself equates "finite resource" with "scarce resource".

Whilst the difference in meaning between the two might seem small, classifying the airwaves as a "scarce resource" it seems creates the context for restrictive legislation to be accepted.

Since applications for broadcasting licences presently does not exceed the number of licences available to suggest, as the Minister does, that the "resource is scarce" is a distortion of the reality.

Should clarity on any of the points raised in this Memorandum be required I will gladly assist

Wassalaam

YUSUF DOCKRAT

DOCKRAT INCORPORATED ATTORNEYS