D J Freeman
43 Fetter Lane
London EC4A 1JU.
12 September 2000
Thank you for your letter
of the 11 September. First,
please accept my apologies, as my letter of the 7 September appears to be a copy
of my ‘opening’ draft. I will
not trouble you with the amended copy, though one, excluded, point is worthy of
It concerns your client’s claims that I have only
offered to supply my evidence ‘on terms’.
For the benefit of the record/truth, in a further effort to ensure that I
have exhausted every possible means of enabling Shell, to explore the
possibility of it behaving responsibly to the victims of its 1968 nuclear
dumping, I offered, on more than one occasion, to/through Richard Wiseman
(Shell’s legal head) ‘off the record’ talks i.e. talks/evidence with
absolutely no conditions attached! I
trust we shall now hear no more of your clients ‘claims’ regarding my
unacceptable evidence ‘terms’.
You will recall that in my
letter of the 7 September I wrote:
‘Does your client dispute any of the nuclear
research programmes, as set out in paragraphs 51-79, were carried out by Shell?
Despite this request
you have, once again, declined to supply answers.
However, if Shell stands by its declarations as per its 7 February 1994, Narrative:
Thornton was not involved in "atomic research" (page 1).’
did not house a "nuclear facility"…. Thornton
did not and never has housed a pile or reactor. (page
‘(c) We do not understand what you mean by
"atomic research for military purposes". We have already explained that Thornton was not involved in
any atomic research (page 2).’
Then Shell will want, no
need to confirm that it disputes it carried out the secret military nuclear
research programmes, that it ‘housed’ a nuclear reactor/testing cell- as set
out in paragraphs 51-79 of my draft claim.
I believe that in view of the consequences for countless thousands and
incidentally Shell, you will see that a ‘We note the contents’ reply will be
deemed most unsuitable and irresponsible. Furthermore,
in the absence of Shell’s specific rejection that it had a nuclear
reactor/testing cell and it carried out the military, and other, nuclear
research programmes-as set out in paragraphs 51-79 (for self-evidently any
organisation that did not would offer immediate rejection), that your client
accepts the facts as stated in paragraphs 51-79 of my draft Statement of Claim.