Request for records relating to legal expenses paid in relation to any litigation relating to the academic qualifications of Ellen Zandile Tshabalala.

Copies of any and all records, or parts of records, relating to legal expenses paid by the SABC for any litigation (including contemplated litigation) brought in any Court regarding:

A. Allegations of fraudulent and/or negligent misrepresentation by Ellen Zandile Tshabalala of her academic qualifications
B. Allegations of perjury made against Ellen Zandile Tshabalala in relation to statements made in affidavits and/or attestations concerning the whereabouts of proof of her academic qualifications including certificates

Setting out, with respect to both item “A” and item “B” above, the following:

1. The total amount paid (or parts of amounts paid, where only that information is available) whether paid to lawyers, Counsel or any witness or other adviser, to defend or conduct that litigation;
2. The total amount paid (or parts of amounts paid, where only that information is available) as a result of:
• a costs order made by a Court, and/or
• an out of court settlement,
for the legal costs of any party or potential party to that litigation;
3. Any internal costs and/or time spent by in-house lawyers or officers, to defend or conduct that litigation; and
4. In respect of items 1 to 3 above, where applicable: record(s) setting out which litigation (i.e. case name and/or number) the costs/amounts relate to.