Brown said she has been given evidence that Molefe and Eskom lied about his early retirement.
She said that Eskom's own minutes reflected that he had indeed resigned.
Molefe and Eskom claim they both mistakenly believed he was entitled to early retirement at 50.
When they realised this was not the case, they agreed that the best option was for Molefe to return to work.
In a detailed affidavit, Brown insisted that she always believed Molefe had resigned and even issued a media statement to that effect. Neither Eskom nor Molefe sought to correct her on this during the next five months.
Brown further said that it beggared belief that Molefe would not have known the conditions for early retirement.
She said he should not be given his position back given the suspicious way in which he was reinstated and the State Capture claims against him.