- d) When the witness was asked how he knew that the salaries of the guards were the same or should be the same as the salaries and conditions of the Israel Police officers, including the Border Police, he replied: "This is information from the Prisons Ordinance. Since I enlisted, a prison guard is like a policeman... I don't remember in which section (it says "A.S."), even in the courses we took and in all the lectures on wages they emphasized it"; e) The fact that police officers, including Border Police officers in operational positions, with the exception of administrative positions, who serve in the Occupied Territories receive from September 1984 an additional shekel paid for their service in the Occupied Territories, is known by the witness from the fact that he worked in the Occupied Territories, "and I knew it all the time... I worked with them in the same area in the Occupied Territories and heard it from them. I also saw it on their slip"; To the question of which coupons he saw it, the witness replied that in the pay slips of "policemen in the security sector. I can't remember there. I have been retired for about three years", and he saw this in 1984; f) when, in the continuation of his cross-examination, the witness was asked when the Blue Police had begun to receive the supplement, he initially replied that it was in September 1984 and that the Border Police officers had received the supplement a few months earlier. When, in the continuation of his cross-examination, the witness was asked: "If I tell you that the blue police started receiving a check supplement only in 1986, what would you say"; his answer was: "I don't know what to say. It could be." Later he added, "I'm sure I heard it was from 1984," and to the question: "That means that all your information about when the police got is only from what you heard," the witness answered in the affirmative; 7) Regarding the administrative police, the witness replied that it seemed to him that they had begun to receive the supplement in 1988.
- h) When the witness was referred to paragraph 5 of his affidavit and asked whether the condition of service in the Occupied Territories was the only condition for receiving an additional check, he replied that as far as he knew, yes. "I know that those who worked in Israel didn't get it, and only those who worked in the territories got it"; i) In the continuation of his cross-examination, the witness was referred to the section of his affidavit and to the question of how he knew what the considerations were behind the IPS Commissioner's decision to pay the additional check to the prison guards from February 1988. "I know firsthand that I worked in the territories... I know it because I got it. The police minister also said at the time that he would fight for the prison guards to receive the increase like the policemen." Later, the witness admitted that he was not present at the meeting at which it was decided to give the guards an extra shekel; 10) When the witness was asked whether it was true that from the beginning of the intifada there had been problems in traveling from the prisons to the prisons in the territories where they worked, he replied that the danger existed even before that, since there were stone-throwing at the time; 11) When the witness was asked about the distance between the prisons in the Occupied Territories and the Green Line, he replied that the distance was about 40 minutes' drive. Regarding the location of the guard during working hours, he clarified that the guard was within the prison premises. To the defendant