DAVENPORT LYONS

Your Ref: PSL/H.AR/IR009/30525

Our Ref: BR/CRW

 

Amhurst Brown Colombotti

DX NO: 412

London

And By Fax No: 020 7830 8297 02 January 2003

Dear Sirs

David Irving -v- Penguin Books Limited

We acknowledge receipt of your letter of 23 December 2002 together with your client's papers in support of his Application.

On what basis have you listed this matter for 30 minutes?

David Irving comments: THEIR argument is of course tantamount to the Menendez brothers throwing themselves on the mercy of the court by claiming they are orphans (having brutally shot both their parents to death).    Penguin's representatives, Davenport Lyons, having fraudulently obtained my bankruptcy, by lying to Judge Gray, now state that as a bankrupt I should be denied permission to seek to get it overturned. Related file: The Lipstadt Trial

We do not feel your client is capable of making this Application. Your client is a bankrupt and the nature of the Application is not one which falls outside of the ambit of the insolvency legislation and not does it relate to a claim for damages to the person.

Given this, and your client's previous attempts to win the same arguments, we must reserve our client's position to seek a Wasted Costs Order.

In your client's witness statement of 23 December 2002 reference is made to the transcript of your client's Bankruptcy Appeal hearing. May we please have a copy of the original unamended transcript as well as the transcript that was then revised by your client's Counsel. We look forward to receiving copies by return.

Yours faithfully

Davenport Lyons