IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA CONSTITUTION HILL CCT Case No: /2013 SCA Case No: 1044/2014 WCHC Case No: 10394/2012 In the application between: IVOR CHARLES STRATFORD First Applicant SHEILA MARGARET STRATFORD Second Applicant CLEAN NGOMA Third Applicant ERIC DLOKOLO Fourth Applicant ANDRIES ADONIS Fifth Applicant and INVESTEC BANK LIMITED First Respondent THE MINISTER OF JUSTICE AND CONSTITUTIONAL DEVELOPMENT Second Respondent THE MINISTER OF LABOUR Third Respondent NOTICE OF MOTION: APPLICATION FOR LEAVE TO APPEAL PLEASE TAKE NOTICE THAT Applicants hereby apply to this Honourable Court for an order in the following terms: 1. That Applicants be granted leave to appeal against the order of the Supreme Court of Appeal, dated 26 March 2014, under case number 1044/2014, which 2 refused Applicants leave to appeal against against the whole of the order and judgment handed down on 14 August 2013 by the Honourable Ms Justice Mantame, in the Western Cape Division of the High Court, Cape Town, under case number 10394/2012, followed by the learned Judge's refusal of an application for leave to appeal, on 4 December 2013. 2. That the costs of this application be costs in the appeal. 3. Further and / or alternative relief. PLEASE TAKE NOTICE FURTHER THAT the founding affidavit of ANDRIES ADONIS, as well as the confirmatory affidavits of the other Applicants, attached hereto will be used in support of this application. PLEASE TAKE NOTICE FURTHER THAT Applicants have appointed Attorneys Van Rensburg & Co, 113 Main Road, Bergvliet, 7945 (tel: (021) 713 2100; fax: (021) 713 2116; email: [email protected]), c/o Stabin Gross & Shull, 408 Louis Botha Avenue, Bagleyston, Johannesburg, Gauteng, as the address at which they will accept notice and service of all process and documents in these proceedings. PLEASE TAKE NOTICE FURTHER THAT within ten (10) days from the date upon which this application is lodged, any Respondent may respond hereto in writing indicating whether it opposes the application and if so, the grounds for such opposition. 3 PLEASE TAKE NOTICE FURTHER THAT if no such opposition is lodged, then Applicants will request the Registrar to place the matter before the Chief Justice to be dealt with in terms of rule 11(4). Dated at CAPE TOWN on this 15th day of April 2014. VAN RENSBURG & C0 Per: Attorneys for Applicants 113 Main Road Bergvliet (Ref: LJVR/pk/VRS0737) Tel: (021) 713 2100 Fax: (021) 713 2116 Email: [email protected] c/o Stabin Gross & Shull 408 Louis Botha Avenue Bagleyston JOHANNESBURG TO: THE REGISTRAR Constitutional Court Braamfontein AND TO: EDWARD NATHAN SONNENBERGS Attorneys for First Respondent ENS House, Loop Street Foreshore CAPE TOWN (Ref: L Melis/0329278) AND TO: THE STATE ATTORNEY Attorneys for Second and Third Respondents Fourth Floor 22 Long Street CAPE TOWN .