COMPLAINT TO THE AUDITOR-GENERAL

PART ONE

Part One of the complaint, dated 25 February 2020, details and documents ongoing capital breaches of the Public Finance Management Act by past and current top officers of LASA, involving many millions of rands, the illegal obstruction of critical legal service delivery, and other major material irregularities, including multiple crimes, committed in a cover-up of pervasive, systemic recruitment corruption in the organisation. Receipt of the complaint was acknowledged on 9 March 2020. On the 30th, the Auditor-General's in-house corporate legal services advocate dealing with the complaint advised that she'd studied it and was preparing a report about it for discussion with the Auditor-General. On 26 April 2020, the Auditor-General's Investigation unit advised that it's taken up the case. See below for the result.

Part One of the complaint is available in:

• PDF: signed and scanned, for reading on computer monitor, printing, and email transmission

• PDF: final draft before signature, for the highest, clearest print resolution

• HTML: for reading on tablets and smartphones

• MS Word: final draft

This is the covering letter.

An Addendum to the complaint on 1 June 2020, showing the complicity of LASA's CFO, IAE, COO, and Board Secretary in the illegalities detailed in the complaint. Covering letter.

A Second Addendum on 29 June 2020 showing the direct criminal complicity of CLE Patrick Hundermark. Covering letter.

On 22 June 2020, twelve criminal charges against former LASA CEO Vidhu Vedalankar.

On 24 March 2021, justifying this with a snowstorm of ludicrously transparent prevarication, distraction and evasion, the AG (actually Ms Kemesha Naidoo) announced her refusal to investigate.

An application to compel is in preparation.

SUPPORTING DOCUMENTS*

The supporting documents to which Part One of the complaint is referenced are contained in:

Bundle 1 (PDF, 15 MB).

Bundle 2 (PDF, 45 MB)

Bundle 3 (PDF, 13 MB)

Compressed for smaller file sizes but lower resolution:

Bundle 1 lo (PDF, 9 MB)

Bundle 2 lo (PDF, 28 MB)

Bundle 3 lo (PDF, 5 MB)

*NOTE: The documents contained in these bundles, some of which are relevant to Part One of the complaint to the Auditor-General, others to Part Two and further Parts to follow, have been collected and assembled in the course of an ongoing 10-year investigation of top-level recruitment corruption and its criminal cover-up at LASA (repeated contradictory perjury; repeated contradictory lying and false reporting to the Justice Portfolio Committee; criminal contraventions of the Public Finance Management Act), many of which documents, duly requested but illegally refused, had to be crowbarred out of LASA by round after round of pre-trial discovery procedure -- including an application to compel discovery, and two additional pre-trial conferences held under judicial supervision at court -- followed by multiple subsequent applications to court to compel compliance with record requests duly made under the Promotion of Access to Information Act ('PAIA'), the first five of which applications, brought in the Magistrate's Court, were all conceded by LASA on the morning of argument. An application is pending to compel full and proper compliance with the settlement agreement signed at court in terms of which LASA undertook to hand over all the documents sued for or duly certify on affidavit any that don't exist -- then neglected to, then positively refused to. Three further PAIA applications are pending in the High Court at Pietermaritzburg, the first of which was argued on 30 August 2019. The judgment, riddled with the most basic mistakes, is on appeal, and Bundle 3 will be augmented with further documents as and when they're disgorged from LASA by order of the court of appeal, and will be used in support of further Parts of the complaint to follow.

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