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[2022] ZAFSHC 296
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Tshabalala v Road Accident Fund (2557/2021) [2022] ZAFSHC 296 (1 November 2022)
SAFLII
Note:
Certain
personal/private details of parties or witnesses have been
redacted from this document in compliance with the law
and
SAFLII
Policy
IN
THE HIGH COURT OF SOUTH AFRICA
FREE
STATE PROVINCIAL DIVISION
Case
No: 2557/2021
Reportable:
YES/NO
Of
Interest to other Judges: YES/NO
Circulate
to Magistrates: YES/NO
In
the matter between:
TERENCE
SANDILE TSHABALALA
Plaintiff
A
nd
THE
ROAD ACCIDENT
FUND
Defendant
Coram:
Opperman,
J
Heard:
28
October 2022. The application was disposed of without hearing oral
argument and on the Heads of Argument filed on record on behalf
of
the parties. This was by agreement between the parties and on order
of the court.
Delivered:
The
judgment was handed down electronically by circulation to the
parties’ legal representatives by email and release to SAFLII
on 1 November 2022. The date and time for hand-down is deemed to be 1
November 2022 at 15h00
Summary:
Quantum
-
loss of
income
JUDGMENT
COMMON
CAUSE
[1]
The parties are agreed that:
1.
On 8 October 2016 the plaintiff was as
passenger involved in a motor vehicle collision and sustained a
number of injuries as a result
thereof, most importantly,
quadriplegia. The matter was set down for adjudication of
quantum.
2.
The injuries and
sequelae
have rendered the plaintiff
unemployable and following the injuries, he suffers a complete loss
of earnings.
3.
The defendant admitted liability and is
liable to pay 100% of the plaintiff’s proven or agreed damages
on the merits. Merits
were conceded in favour of the plaintiff during
2017.
4.
During March 2018, and at the time when
the plaintiff was still representing himself, he settled his claim
for general damages in
the amount of R2 000 000.00 (two million
rand). He also accepted an (unlimited) undertaking, as envisaged in
section 17(4)(a) of
Act 56 of 1996, for future medical expenses.
Since 2018 a number of payments have been made,
inter
alia,
monthly payments towards the
expenses relating to the plaintiff’s caregiver.
5.
The only dispute is the amount to be
awarded for the plaintiff’s loss of income. The plaintiff and
the defendant have agreed
that the defendant accepts the contents of
the expert reports of the plaintiff; it stands undisputed.
6.
The parties further agreed that the
actuarial report compiled by Wim Loots and dated 17 October 2022,
forms the basis of the calculations
for determination of the loss of
earnings. Thus, the only aspect in dispute between the parties
relates to the contingency applied
by the plaintiff’s Actuary
in respect of the pre-morbid future loss of income calculation.
7.
The parties agreed to the amounts as set
out under paragraph 12 of the actuarial report dated 17 October 2022;
being that the total
past loss amounting to R338 189.00 (where
5% contingency has been applied) and which calculation has been
accepted by both
parties and agreed upon. The disability grant to be
deducted in the amount of R116 960.00 is also agreed to.
8.
The parties further agreed that the
amount to be used for the future loss calculation is R3 001 364.00
being the amount from
which the deduction is to be made once the
court determined the contingency to be applied.
9.
This court is thus only called upon
to determine the contingency to be applied to the pre-morbid future
loss of income calculation
in respect of the plaintiff’s claim.
10.
The parties agreed that the reports
contained in Bundle 5 – ‘Plaintiff’s Medico-Legal
Reports’ be received
as exhibits in the proceedings:
1.
Dr Makau – General Practitioner
2.
Dr Scher – Orthopaedic Surgeon
3.
Dr T. Townsend – Neurologist
4.
T. Da Costa – Clinical
Psychologist
5.
S. Fletcher – Occupational
Therapist
6.
L. Leibowitz – Industrial
Psychologist
7.
W. Loots – Actuary (updated
report, dated 17 October 2022)
[2]
In monetary value the plaintiff alleges that he suffers a loss of
earnings in the
amount of R2 622 319.00 also having had regard to the
monthly disability grant (‘state welfare benefits’) which
he
has been receiving since July 2017.
[3]
The calculations by the plaintiff’s Actuary will be the
starting point for the
adjudication as to the contingencies to be
applied to both the past- and future loss of earnings.
DISPUTE
[4]
The above culminates in the singular dispute of a contingency on the
following basis:
1.
The plaintiff: Less contingencies of
“5%/20%”. The R116 960.00 (disability grant) must be
deducted from the total and
brings the amount claimed to R2 622
319.80.
2.
The defendant: Less contingencies
“5%/45%”. R1 988 938.80 – R116 960.00 (disability
grant) = R1 871 978.80. The
court is therefore requested by the
defendant to award an amount of R1 871 978.80 in respect of
plaintiff’s claim for loss
of earnings.
THE
LAW
[5]
It is trite that it is vital that the evidence pinioned by an expert
is solid. “Solid”
supposes veracity of the facts of the
particular case, expertise on the issue and an opinion that makes
legal sense based on the
facts combined with the expertise. In
casu,
neither the Industrial Psychologist that instructed the Actuary, nor
the Actuary can be faulted on their postulations and calculations.
[6]
In
Southern
Insurance Association v Baily NO
1984 (1) SA 98
(A) that was supported in
Adv
Johan Malherbe Kilian N.O Plaintiff in his capacity as Curator Ad
Litem to Jansen Van Rensburg: Andre Abraham Petrus Le Grange
v Road
Accident Fund, The High Court of South Africa (Gauteng Division,
Pretoria)
Case No. 34116/2016 Judgement 15/9/2016 Gauteng Division, Pretoria it
was held that:
[1]
Any enquiry into damages for loss of earning
capacity is of its nature speculative, because it involves a
prediction as to the future, without the benefit of crystal balls,
soothsayers, augurs or oracles. All that the court can do is
to make
estimates, which is often a very rough estimate, of the present value
of loss. It has open to it, two possible approaches:
One is for the
judge to make a round estimate of an amount which seems to him to be
fair and reasonable. That is entirely a matter
of guesswork, a blind
plunge into the unknown. The other is to try to make an assessment,
by way of mathematical calculations,
on the basis of assumptions
resting on the evidence. The validity of this approach depends of
course upon the soundness of the
assumptions, and these may vary from
the strongly probable to the speculative.
[2]
It is manifest that either approach involves guesswork to a greater
or lesser extent. When it
comes to scanning the uncertain future, the
Court is virtually pondering the imponderable, but must do the best
it can, on the
material available even if the result may not
inappropriately be described as an informed guess, for no better
system has yet been
devised for assessing general damages for future
loss.
[6]
I must however emphasise that
because of the speculative nature of the enquiry, when parties
elect
to approach the court on a stated case and lump sum of money is
claimed, as in the present case, R6 653 636.00 from the public
coffers, it is incumbent on the parties to place before the court
sufficient evidence in the form of admissions and other admitted
format.
[7]
The issue of contingencies is complicated. Speculation abounds. This
causes the courts
to, inevitably, have a wide discretion. The
discretion is curtailed by the application of law on the conspectus
of facts.
[8]
Contingencies are by mere definition a control mechanism to adjust
the loss to the
circumstances of the case to achieve a just and
equitable outcome. What is reasonable and fair within the subjection
of the presiding
officer. These are some factors that have evolved in
case law as depicted by counsel for the plaintiff:
1.
It is trite that the determination of
allowances for contingencies involves, by its very nature, a process
of subjective impression
or estimation rather than an objective
calculation.
2.
The question of the contingencies
deductions to be applied, as is the issue of the calculation of the
quantum of a future amount,
such as loss of earning capacity, are
often difficult matters.
3.
The court has a wide discretion based
upon a consideration of all the relevant facts and circumstances.
4.
Contingencies of whatever nature
generally serve as a control mechanism to adjust the loss to the
circumstances of the individual
case in order to achieve justice and
fairness to the parties.
5.
The provision for contingencies falls
squarely within the subjective discretion of the trial judge as to
what is reasonable and
fair.
6.
In coming to a contingency calculation
there are no fixed rules and direct evidence cannot be given by an
Actuary. Actuarial evidence
only serves as a guide to the Court.
7.
Contingency deductions imply that
provision is made for the prospective loss at the time of assessment
of damages that might in
any event possibly have occurred
independently of the accident in question.
8.
The usual effect of an adjustment based
on contingencies is that the amount of damages are reduced by a
percentage which may vary
from 5% and 50%.
9.
However, contingencies should logically
not always reduce damages, since it should also be possible to
consider positive contingencies
which may increase the damages.
10.
Henochsberg J concluded that in any
estimate of the person’s loss of earning capacity allowance
must be made for all contingencies
including the vicissitudes of life
and certain deductions must be made from the gross income to allow
for unemployment benefits,
insurance and so on.
11.
This configuration would include –
a possibility that a Plaintiff’s working life may have been
less than 65 years; a
possibility of his death before he reaches the
age of 65 years; the likelihood of him suffering an illness of long
duration; unemployment;
inflation and deflation; alterations on the
cost of living allowance; an accident whilst participating in sport
such as hockey
or cricket or at any other time which would affect his
earning capacity; and any other contingency that may affect his
earning
capacity.
12.
Contingencies have been described as a
normal consequences and circumstances of life, which beset every
human being and which directly
affect the amount that a Plaintiff
would have earned.
13.
According to Dr. Koch in his book, the
Quantum Yearbook, it is stated that when assessing damages for loss
of earnings or support
it is usual for deductions to be made for
general contingencies for which no explicit allowance has been made
in the Actuary’s
calculation.
14.
The deduction is in the prerogative of
the Court. General contingencies cover a wide range of considerations
which may vary from
case to case and may include: taxation,
early death, loss of employment, promotion prospect, divorce etc.
15.
In substantiation of the aforementioned,
Dr. Koch refers to some guideline in respect of contingencies:
“Normal contingencies”:
as deductions of 5% for
past loss and 15% for future loss, “a sliding scale”:
half % per year to retirement age,
i.e., 25% for a child, 20% for a
youth and 10% in the middle age and deferential contingencies are
commonly applied that is to
say 1% apply to earnings but for the
accident a different percentage earnings having regard to the
accident.
16.
The assessment of contingencies is
largely arbitrary and depends on the court’s impression of the
case. The contingencies
allow for general hazards of life such as
periods of unemployment, possible loss of earnings due to illness and
risk of future
retrenchments.
17.
There are guidelines to assist the
court. Generally, the younger a claimant, and the longer the
remaining working life of a claimant,
there is more likely the
possibility of an unforeseen event impacting on the assumed
trajectory of his or her remaining career.
18.
Over time, our courts have accepted that
the extent of the period over which a plaintiff’s income has to
be established has
a direct influence on the extent to which
contingencies have to be accounted for. Put differently, the longer
period over which
unforeseen contingencies can have an influence over
the accuracy of the amount adjudged to be the probable income of the
plaintiff,
the higher the contingencies that have to be applied.
19.
In past cases, the Supreme Court of
Appeal has found the appropriate pre-morbid contingency for a young
man of 26 years was 20%
which would decrease on a sliding scale as
the claimant got older. Although dependant on the specific
circumstances of each case,
it serves as a convenient starting point.
[9]
There are no fixed rules. The evidence of experts and actuaries
serves as guidance
to the courts.
[10]
The case of
National Justice Compania Naviera S.A v Prudential
Assurance Co Ltd
1993 (2) Lloyds Reports 68-81 set out the duty
and role of an expert.
1.
Expert evidence presented to the court
should be, and should be seen to be, the independent product
of the
expert uninfluenced as to form or content by the exigencies of
litigation.
2.
An expert witness should provide independent
assistance to the court by way of objective, unbiased opinion
in
relation to matters within his expertise. An expert witness should
never assume the role of an advocate.
3.
An expert witness should state the facts or
assumptions upon which his opinion is based. He should not
omit to
consider material facts which could detract from his concluded
opinion.
4.
An expert witness should make it clear when
a particular question or issue falls outside his expertise.
5.
If an expert opinion is not properly
researched because he considers that insufficient data is available,
then this must be stated with an indication that the opinion is no
more than a provisional one. In the case of where an expert
witness
who has prepared a report could not assert that the report contained
the truth, the whole truth and nothing but the truth
without some
qualification, that qualification should be stated in the report.
[11]
In
Schneider NO & Others v AA & Another
2010 (5) 203
WCC Davis, J stated at paragraph 211J-212B:
In
short, an expert comes to court to give the court the benefit of his
or her expertise. Agreed, an expert is called by a particular
party,
presumably because the conclusions of the expert, using his or her
expertise, are in favour of the line of argument of the
particular
party. But that does not absolve the expert from providing the court
with as objective and unbiased an opinion, based
on his or her
expertise, as far as possible. An expert should not be a hired gun
who dispenses his or her expertise for the purpose
of a particular
case. An expert does not assume the role of an advocate, nor gives
evidence which goes beyond the logic which is
dictated by the
scientific knowledge which that expert claims to possess.
[12]
In
RAF v Zulu
[2011] ZASCA 223
the court dealt with the
approach to expert evidence that has to be adopted by the courts. The
court reaffirmed the principles
set out in
Michael v Linksfield
Clinic (Pty) Ltd
2001 (3) SA 1188
(SCA) that:
[14]
What is required in the evaluation of such evidence is to determine
whether and to what extent
their opinions advanced are founded on
logical reasoning.
[13]
The common theme is that courts must jealously protect their role and
powers. Courts are the
ultimate arbiters in any court proceedings.
The facts that caused the expert opinions in this case are vital. It
was supplied by
the plaintiff and corroborated by experts and
surrounding evidence. It is logic and sound.
ADJUCATION
[14]
The monetary difference in the views of the parties to be R750
340.20; the percentage contingency
25%. The parties are too far apart
in their postulations and submissions if the facts are regarded. The
evidence of the Industrial
Psychologist applied on the reigning law
and on the facts brings the matter to a more just and equitable
outcome.
[15]
Lee Leibowitz, the Industrial Psychologist, with veracity interpreted
and reflected the condition
of the plaintiff. The plaintiff is
confined to a wheelchair (the plaintiff is a quadriplegic), unable to
sit unsupported, has limited
movement in his hands and wrists,
suffers loss of sensation to touch over the front of the upper chest
distally, down the trunk
and lower limbs and upper back downwards,
suffers leg spasms and has no control over his bladder. An indwelling
catheter was inserted.
He has no control over his anal sphincter and
needs to wear nappies and he suffers from prevailing constipation
with the added
consequences.
[16]
He suffers from severe frustration due to his physical limitations
and sometimes experiences
the feeling that it would have been better
if he died in the accident. This is aggravated by disturbed sleep
patterns, being short
tempered and irritable; and worry and anxiety
about his future.
[17]
Leibowitz continues to describe the pre-accident and post accident
employment and earnings postulations
to be:
A:
Pre-Accident
1.
In anticipating the level to which an
individual may have advanced in his/her occupation, several aspects
play a role. Important
aspects include the familial background,
developmental and medical history, the individual’s
socio-economic circumstances,
overall functioning (i.e., cognitive,
psychological, physical etc.) educational achievements, vocational
history, job performance
and career aspirations, as well as various
external factors such as labour market conditions, the availability
of promotional opportunities,
employment policies, etc.
2.
With regards his education, plaintiff
exited the schooling system in December 2012, after having
successfully completed his Grade
12 year. His National Senior
Certificate reflects that he met minimum requirements for admission
to higher certificate studies.
3.
In terms of further skills development,
plaintiff did not further his tertiary studies or complete any
training. Upon direct questioning,
plaintiff indicated that he does
not have a driver’s license.
4.
From an occupational perspective,
plaintiff has held employment doing instore promotions for Auto Reach
during school holidays.
In 2015 he worked as a casual/shelf packer at
Cash ‘n Carry in 2015 for five to eight months. As per the
affidavit referred
to in section 7 of this report, plaintiff was
earning R2 500.00 per month for his efforts in this capacity. He
reportedly left
this position at around the end of November 2015. He
was thus unemployed at the time of the accident.
5.
The plaintiff was 25 years old at the
time of the accident. He asserted that he was in good health
pre-morbidly and that he would
not have had any limitations meeting
the requirements of any position for which he was suited.
6.
When asked about his career aspirations,
plaintiff reported that “he loved playing soccer" and that
he had played for
a soccer club since high school till the date of
the accident. He indicated that his “dream” would have
been to be
a professional player. He however acknowledged that he had
never derived any income from his soccer interests. Upon further
probing,
he explained that at the time of the accident he was
searching for employment as he needed an income and that he would
have accepted
any entry level work with the aim of developing skills
in the workplace.
7.
Having considered plaintiff’s
background, his level of education and the limited work experience
Leibowitz is of the opinion
that he would have had to rely on his
physical abilities and psychological wellbeing to remain competitive
and earn a living. It
is further considered that he would have
remained competitive for positions for which he had the requisite
skills, abilities and
experience. Whilst Leibowitz acknowledges
plaintiff’s love of sport, it is however considered that very
few people manage
to progress to a professional level. As such
Leibowitz is of the view that but for the accident the following
would have ensued:
7.1
Given that plaintiff was unemployed at the time of the accident, he
may have accepted work as a casual worker such as
he had previously
held in 2015. It is however considered that in time (although
timeframes are difficult to accurately predict)
he would have secured
more stable work. His earnings would have depended on various
factors, such as his job context.
7.2
Broadly speaking, it is acknowledged
that although plaintiff had completed Grade 12, given labour market
conditions he may initially
have had to accept work where he would
have earned at least in line with the National Minimum Wage. Had he
secured full-time work,
his earnings may have been at the R4 229.55
per month/R50 745.60 per annum levels in 2021 terms.
7.3
Given plaintiff’s relatively young
age at the time of the accident (he was only 25), and that he had
obtained a Grade 12,
it would only be fair to allow for progression.
It may be considered that given the opportunity, with time,
experience, and the
acquisition of additional skills (which may have
been obtained through attending additional courses, workplace
interventions/undergoing
on the job training, etc.), plaintiff would
have been able to progress within semi-skilled environments to reach
R193 000.00 per
annum levels by age 45- 50.
7.4
Thereafter, his earnings may have
increased annually in line with inflation, until retirement at age
65.
B: Post-Accident
1.
The plaintiff was involved in an
accident on the 10 August 2016, in which he sustained injury.
2.
He reportedly remained unemployed since
the date of the accident.
3.
Leibowitz took note of the opinions of
the experts on record.
4.
Having taken cognisance of the experts’
collective findings, it is Leibowitz’s opinion that plaintiff
has been rendered
exceptionally vulnerable and unemployable as a
result of the injuries he sustained in the accident and the
sequelae
thereof.
5.
In essence, plaintiff sustained serious
orthopaedic injuries as outlined by Dr Scher. Dr Scher explained that
consequent to the
cervical spinal cord damage plaintiff has been left
virtually totally incapacitated, wheelchair bound and dependent on
daily care
for the rest of his life. In his opinion, post-accident he
has been rendered unemployable.
6.
In addition, Dr Townsend, Neurologist
was of the opinion that he sustained a mild traumatic brain injury.
Her neurological outcome
diagnosis was that plaintiff has
posttraumatic cervical myelopathy ASIA-A C8 and posttraumatic mood
disorder. In her opinion plaintiff
is rendered unemployable in the
open labour market as a result of his spinal cord injury and
neurological deficits.
7.
Ms Da Costa, Clinical Psychologist,
indicates that post-accident plaintiff presents with deficits
including severe depression, and
severe anxiety/panic. Ms Da Costa is
of the view that he will not likely be able to return to pre-accident
levels of mental functioning
if the physical pain and cognitive
deficits either continues at the current level or intensifies. In her
opinion, plaintiff will
remain unemployed.
8.
Ms Fletcher, Occupational Therapist,
reports that plaintiff identified several physical/functional
limitations as well as visual
perceptive skill deficits. She also
concludes that plaintiff is unemployable in the open labour market.
9.
In light of the above, Leibowitz
concludes that as a result of the injuries sustained in the accident
and the
sequelae
thereof, plaintiff is considered unemployable and will suffer a total
loss of earnings.
[18]
The defendant did not adduce any evidence to bolster their view.
Counsel for the defendant drew
the court’s attention to the
following:
1.
Plaintiff did not further his studies
and Grade 12 is his highest qualification. He did not complete any
further training.
2.
He did not hold a driver’s
licence.
3.
His employment with both Auto Reach and
Bibi Cash ‘n Carry, was uncorroborated in any manner and in
both instances, it was
temporary work.
4.
He voluntarily ended his employment
there and one is left to wonder why, in the general economic climate
of the country, he had
done so.
5.
He was unemployed at the time of the
collision.
6.
He completed Grade 12 in 2012, and from
January 2013 to October 2016 (3 years and 10 months) he was (on
uncorroborated information)
employed for at best 8 months of the 46
months (only 17% of the time).
7.
If accepted that he did in fact obtain
temporary employment with Bibi Cash ‘n Carry, and then merely
terminated same, one
may conclude that he lacks dedication and
commitment towards his employment and may in fact have not progressed
to the semi-skilled
level of employment, or by the age, as postulated
by Leibowitz.
8.
South Africa has a high unemployment
rate, even under graduates. It also suffers of low economic growth.
This can lead to a significant
delay in entry and career breaks. The
fact that plaintiff was, at the time of the collision, searching for
employment serves to
confirm the scarcity thereof, and him possibly
only obtaining employment much later than January 2017. There is
always the possibility
that plaintiff may have been unemployed for
extended periods of time and there is even a possibility that he
would have remained
unemployed in the absence of the accident.
9.
A much higher contingency deduction for
future income is more in keeping with the probabilities of the case.
10.
There is a possibility that plaintiff
could have retired earlier than postulated by Leibowitz (being at the
age of 65 years) and
it is noted from tax regulation that a person
can retire from age 55 and government grant starts at age 60.
11.
The calculations done from 1 January
2017 onwards (Leibowitz postulated a 3 months period to seek and
obtain employment, from date
of accident), is done at R4 229.55 per
month. Counsel for the defendant submitted that a calculation
starting at R2 500.00
per month, would be more realistic and in
keeping with plaintiff’s (alleged) employment history.
CONCLUSION
[19]
A contingency of 5%/32,5% meets the facts and the law of the case to
cause fairness and equity.
The matter will be referred back to the
Actuary to conclude the calculation on this basis.
[20]
ORDER
With
due cognisance of the fact that the plaintiff has concluded a written
Contingency Fee Agreement with his Attorneys the following
order is
made:
1.
The defendant is 100% liable for the plaintiff’s proven
damages.
2.
The plaintiff’s claim for past and future loss of earning
capacity must
be referred to Wim Loots Actuaries to be calculated,
within 20 days of the date of this order, in accordance with the
actuarial
report dated 17 October 2022 (Reference WLAC13663.1) and
applying the contingency deductions of
5%/32,5%.
3.
Upon receipt of the actuarial calculation the parties are to approach
court to
make the actuarial calculation of the plaintiff’s
claim for past and future loss of earning capacity an order of court.
4.
Payment will be made directly to the trust account of the plaintiff’s
attorneys
of record, the details are as follows:
Holder:
Mokoduo Erasmus Davidson Attorneys Trust Account
Bank
and Branch: First National Bank (FNB), Rosebank
Account
number: [....]
Code:
253305
Ref:
T827
5.
Interest
a tempore-morae
shall be calculated in accordance
with the
Prescribed Rate of Interest Act 55 of 1975
, read with
section 17(3)(a)
of the
Road Accident Fund Act 56 of 1996
, one
hundred and eighty (180) days from the date of this order.
6.
The defendant is to pay the plaintiff’s agreed or taxed High
Court costs
as between party and party, such costs not limited to,
but to include:
6.1.
Costs attendant upon the obtaining of payment of the capital amount;
6.2.
The preparation and qualifying fees of the experts consequent upon
obtaining the plaintiff’s reports and
addendum reports
inter
alia
by: -
6.2.1.
Dr Makua (General Practitioner);
6.2.2.
Dr Scher (Orthopaedic Surgeon);
6.2.3.
Burger Inc (Radiologist);
6.2.4.
Dr Taniel Townsend (Neurologist);
6.2.5.
Talita da Costa (Clinical Psychologist);
6.2.6.
S Fletcher (Occupational Therapist);
6.2.7.
L Leibowitz (Industrial Psychologist); and
6.2.8.
Wim Loots (Actuary).
6.3.
The plaintiff’s reasonable travel and accommodation costs to
attend appointments.
7.
The costs of counsel up until 28 October 2022.
8.
The party and party costs, as agreed or taxed, shall be paid by the
defendant
directly into the trust account of Mokoduo Erasmus Davidson
Attorneys for the benefit of the plaintiff
M.
OPPERMAN, J
Appearances
For
plaintiff:
ADVOCATE
ILZE SANDER
079
890 2166
Olivier.ilze@yahoo.com
Instructed
by: MED
Attorneys
Office
G03, Regus Business Centre
Ground
Floor, Unipark Building
Vodacom
Lane, Nobel Street
Brandwag
BLOEMFONTEIN
051
101 2329
086
697 5499
nicolle@medlaw.co.za
Ref:
ND/no/T827
For
defendant:
MS.
J GOUWS
Instructed
by: State
Attorneys, Free State
Bloemfontein
c/o
The Road Accident Fund
johandig@raf.co.za
Claim
no. 502/12448705/07/3
Link
no: 4068507