a modest offer to settle — Mr.

The 00) to a charity for the limbless, and an apology.

On October 10, 1999 he made to Penguin and Lipstadt a properly drafted Part 36 offer to settle couched in even more reasonable terms (below). Claim 1996 – I – No. 1113IN THE HIGH COURT(QUEEN’S BENCH DIVISION) BETWEENDAVID JOHN CAWDELL IRVINGClaimantand PENGUIN BOOKS LIMITEDFirst DefendantDEBORAH E.

LIPSTADTSecond Defendant PART 36 OFFER BY CLAIMANT The Claimant hereby offers to settle his libel claim for the gross amount of £500 (which will be donated to a charity to be nominated by the Claimant).

This offer is to remain open for acceptance for 21 days from the date it is made and may be accepted after that only if the parties agree the liability for costs or the court gives permission.The following information is supplied in clarification of this offer:-it is intended to settle the whole of the Claimant’s claimit is intended also to settle any counterclaim against the Claimant that might otherwise be assertedit is not intended to affect any rights over or against anyone else that the

Defendants may wish to assert, by Part 20 claim or otherwiseit is not intended to affect any rights that any other pers

on may wish to assert against the Defendantsthe offer, above, is inclusive of interestif the offer is accepted without needing the permission of the court, the Claimant will be entitled to his costs of the proceedings up to the date of the Defendant’s serving notice of acceptance as provided in CPR 36.13(1).

Dated [October 10, 1999]Signed Sept 1998: Mr Irving offered secretly to settle with Penguin Books if they donated $800 to a charity Oct 2004: Popular myth dispelled Richard Santana believes that Mr Irving wanted to make a killing from the Lipstadt trial