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Updated: May 21, 2023

Zunaid Moti

For Attention: Sam Sole

By Email

15 May 2023

Dear Sam,


1. Thank you for allowing me the opportunity to answer your questions pertaining to me personally, as well as the Moti Group of Companies (“the Moti Group”). My answers will be sent to you by my attorneys Ulrich Roux and Associates’ (“URA”).

2. At the outset, I wish to take this opportunity to inform you of the fact that we are doing our own investigation regarding the clear bias you display daily, and plan to publish our findings. The reason for this is that as a journalist, many parties will take you into their confidence, however they have the right to know if and when they are being misled. To this end, I have posed questions to you / Amabhungane in Part B of this letter and require your response thereto by no later than 12h00 on Wednesday 17 May 2023.


3. At the risk of repeating myself, and out of an abundance of caution, I will reiterate my concerns and comments previously submitted to yourselves.

4. I draw your attention to the response addressed by URA to you on 12 April 2023, and the correspondence addressed by URA to your attorneys, Webber Wentzel on 13 April 2023, both of which specifically recorded that the documents you purported to rely on, as the basis for the questionnaire, were documents that had been stolen by an erstwhile employee of the Moti Group, one Mr. Clinton van Niekerk (“van Niekerk”).

5. Van Niekerk, who only had lawful access to very limited documentation during his employment with the Moti Group and for the purposes of his employment, had no right to retain, download, copy or divulge any of the documents or information of the Moti Group and criminal charges have been laid against him for inter alia, theft, contravention of the Protection of Personal Information Act, 4 of 2013 and contravention of the Electronic Communications and Transactions Act, 25 of 2002.

6. Because you have pointedly and deliberately chosen not to identify all of the documents you received which emanated from van Niekerk (“the stolen documents”) I am unable to ascertain what documents you have had access to and whether van Niekerk was entitled to access to them in the first place. In many instances the stolen documents may have been part of a series or sequence of documents. Snapshots of events and occurrences appearing from incomplete documents will always only tell part of the story.

7. Following your last publication, it is now clear that some of the documents you published are forgeries. The creation of forged documents by van Niekerk (with or without your assistance) amounts to fraud.

8. It is noteworthy that neither you nor your attorneys addressed the allegations of van Niekerk’s theft in any of your communications with URA. Evidently you not only condone van Niekerk’s unlawful conduct in misappropriating the stolen documents, but you also align yourself with, and are in fact comfortable, in knowingly perpetuating unlawful conduct. Insofar as the matter is currently being investigated by the SAPS, I have instructed URA to once again inform the SAPS of your involvement for purposes of potential further investigations and/or charges.

9. Van Niekerk received financial gain for sharing confidential documents with third parties, and this precludes him from being considered a legitimate whistle-blower according to the Protected Disclosures Act. Taking into consideration the manner and timing in which van Niekerk extracted the information (which has been confirmed by independent IT experts), there is a very real possibility that you either approached him to do so, or you engaged with him shortly after he terminated his employment for purposes of soliciting this information / documentation.

10. The agreements you have provided as annexures to your questions clearly demonstrate that you are in possession of some documents emanating from the Moti Group server downloaded by van Niekerk. I say this because you in fact failed to remove the metadata on the documents which proves the source of some of these documents and proves that you are complicit to this crime. This is akin to leaving your business card at a bank robbery. We will publish these findings and your involvement in the crime committed by van Niekerk.

11. Whilst you claim to be acting for the “public good”, your conduct to date is demonstrative of bias and sensationalism with a clear pre-determined narrative, which is evident from the manner in which certain of your questions have been framed.

12. Your organization’s clear bias against me and the Moti Group is also evident from your previous reporting. Your aim appears to be less investigative reporting, and more sensationalist “click-bait” reporting. Your conduct and line of reporting is neither fair nor impartial, and any reliance on purported “public interest” or “freedom of press” is disavowed for the reasons mentioned.

13. I insist that your article will include my entire statement above (and not only parts thereof to suit your narrative) and that you advise your readers that your sources are tainted in the extreme. Given that I now have proof of the source of some of the documents through analysis of their metadata, I am considering steps to protect my rights and my lawful obligations.

14. I also caution you against advancing a false narrative and ultimately creating the impression that the Moti Group or I are party to any untoward transactions.

15. In addition, I insist that when publishing your findings, you record the following to ensure that the public at large has all of the relevant information available for its consumption:

15.1. your source is van Niekerk who is an erstwhile employee who stole Moti Group confidential documentation to derive a financial gain;

15.2. under the circumstances, the stolen documents in your possession may not be accurate and could possibly have been altered; and

15.3. that you are also in possession of forged documents with the sole aim to advance your false narrative.


16. As I indicated above, we are conducting our own journalistic investigation with numerous other parties and informants regarding your conduct, which we plan to publish. This is in the interest of the public at large. Accordingly, we wish to give you fair opportunity to answer the below questions by this Wednesday at 12h00, as we are in possession of a significant amount of information that should be brought to the attention of the public:

16.1. What is the nature of your relationship with Adriaan Basson (“Basson”)? I am told that you and Basson are part of an “old boys” club and have a personal relationship which commenced some time ago.

16.2. What financial arrangements does Amabhungane have with News24, and does Amabhungane receive financial gain out of this relationship?

16.3. If the answer to 16.2 is affirmative, are all compliance and regulatory matters related to the relationship duly met since News24 forms part of a listed group of companies, or is this overlooked due to your personal relationship with Basson?

16.4. Are you employed by, or do you receive any benefit from News24, in any capacity?

16.5. Are you funded by overseas sponsors as was reported by IOL on 16 August 2022 in the article titled “Manufacturing Consent: How the United States has penetrated South African media”? If so, please provide more details in this regard and an explanation as to whom creates the narrative for Amabhungane? Do your sponsors utilize your organization to advance their own agendas, and if so, what are these agendas?

16.6. Do you conduct proper “know your client” checks on your sponsors, and satisfy yourself through proper due diligence processes of their dealings both locally and abroad?

16.7. Were you personally involved with the former Apartheid regime, and at what levels and in what capacity did you work with the police, military and intelligence?

16.8. Why don’t you write any pieces on George Soros? Or do you exempt your sponsors from negative publicity, or have a policy preventing you from writing negative stories related to them?

16.9. Do you believe that, as a journalist, you have the right based on “public interest” to steal information or documents?

16.10. What is the nature of your relationship with Frikkie Lutzkie (“Lutzkie”)?

16.11. Have you received any funding (or bribes) from Lutzkie?

16.12. If you are in fact working with Lutzkie (to advance his scheme of extortion against me), are you aware of his dubious past, the many criminal allegations against him, and the fact that he is a convicted criminal? Why don’t you publish these stories related to him?

16.13. How did you gain access to some of the Moti Group’s stolen documents? Through Lutzkie, van Niekerk, or both of them?

16.14. Was it Lutzkie who gave you the false information that I had opened a case against you and that your arrest was imminent?

16.15. Do you concede that in fact the information provided to you, by Lutzkie or another source, was false, and that in fact I have not commenced with any criminal complaint against you or Amabhungane?

16.16. What is the nature of your relationship with The Sentry, or are you merely their mouthpiece in South Africa?

16.17. What is the nature of your gripe with Paul O’Sullivan? We are of the view that it is merely because he is investigating criminals that you are involved with.

16.18. Do you believe it is fair to publish stories without properly verifying the credibility of your sources or the authenticity of the documents on which you rely?

16.19. As communicated by your attorneys to URA, why do you store your documents on an offshore server? Is this to avoid the need to comply with South African data and privacy laws?

16.20. If you have nothing to hide, and if you believe your sources are legitimate, why have you not provided us with all of the documentation purportedly relating to Moti Group and I in your possession?

16.21. Now that you have knowledge that some of the documents in your possession are forgeries, do you still intend publishing same prior to me having had sight of all of them?

I look forward to receiving your reply, and the assurances I have sought above. I do reserve the right to publish this letter should I wish to do so.

I hope that you have a fantastic day.

Yours Faithfully,


Sent Electronically, therefore unsigned



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