34. PW3 was then referred to Petitioner’s exhibit “CK12”, which is a list of names of polling agents for the Petitioner and in response he confirmed that his name was the second on the list. He added that the Petitioner only had 17 polling agents. He also alluded to the fact that he did not have a specific polling station. When questioned on whether the Petitioner’s team was disorganized or not, PW3 hesitated to answer the question and simply stated that the Petitioner’s agents were denied access to the polling stations. 35. In cross examination by Mr. Musoka, he reiterated his evidence concerning what he observed on election day. He also reiterated that where he found people voting on behalf of the illiterate was at Kasonge. He confirmed that he was aware that ECZ is mandated to help the aged, illiterate and the blind when voting but maintained that not all being assisted were aged or blind. PW3 added that he was not in a position to lodge any complaint it was the Petitioner who could complain. He also conceded that he did not object to what he saw at the polling station. 36. PW4 was Mr. Norman Simwala, aged 29 years of Helen Kaunda in Lusaka, a freelance electrical technician. He attested that he was the Petitioner’s right-hand man and personal assistant. His further testimony was that as members of the Petitioner’s team, what they noticed was that a neighbour, one George Bunda a teacher at Ponga Primary School, would receive gifts from the 1st Respondent and it appeared that the people who came to intimidate had to go through Mr. Bunda and later they J18

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