In order to persuade the above Honourable Court that I should be released on bail, I provide the following additional facts and information in terms of Section 60 of the Act.
I do not know the identity of any witness upon whom the State will rely in order to attempt to prove a case against me. In any event, I have no intention to interfere with any witnesses as I have no cause to do so and I undertake not to do so.
I maintain good relationships with people and I bear no grudges against anyone.
As previously stated, I have no previous convictions and I have not been released on bail pending any charges.
I am not disposed to violence.
I respectfully submit that the facts set out above support my contention that I do not constitute a flight risk.
I have two South African passports, the one is full. I need my passport to compete overseas but I am willing to surrender the passports to the investigating officer should it be a condition of bail. I am not in possession of any other travel documents and undertake not to apply for such documentation pending the finalisation of these proceedings.
After the shooting I did not attempt to flee. Rather, I accepted Stander would contact the police, and I remained at the scene.
I will be able to raise an appropriate amount to post as bail.
I have no knowledge of any evidentiary material which may exist with regard to the allegations levelled against me. In any event, I believe that whatever such evidence may be, it is in the possession of the police; it is safely secured and I do not have access thereto. I undertake not to interfere with any further investigations.
I am not sure which witnesses the State will rely upon in order to attempt to prove its case against me. Nonetheless, I undertake not to communicate with any witness, whoever he or she may be, and any other persons whose names may appear on a list of "State witnesses", to be provided by the State.
My continued incarceration can only prejudice me and creates no benefit to the State.
I respectfully submit that should I be released on bail, my release shall not disturb the public order or undermine the proper functioning of the criminal justice system.
I will comply with such conditions as the above Honourable Court may wish to impose.
I accordingly submit that the interests of justice, considerations of prejudice and the balancing of respective interests favour my release on bail.