D J Freeman
43 Fetter Lane
London EC4A 1JU.
15 September 2000
Your ref MWR/PAS/011311999
Thank you for your
letter of the 13 September. You
claim that I am perfectly well aware of Shell’s position concerning my
‘allegations’. Furthermore, you
go on to complain that I am simply repeating the (same) allegations.
With respect, your assertions are incorrect. A simple re-reading of my letters will show the flawed nature
of your ‘red herrings’.
I find your claim that I ‘am
perfectly aware of Shell’s position’, perplexing.
May I ask how, when, who or where Shell or anyone else has ever disclosed
to me Shell’s position regarding paragraphs 51-79 of my draft Statement of
Claim? Consequently, please
substantiate or withdraw. In light of your expected failure to forward details of
Shell’s disclosure of its said position, I once again ask:
Does Shell stands by
its declarations as per its 7 February 1994,
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).’
I would be most grateful
if you would now supply direct straightforward answers, instead of needless
prevarication. However, I repeat,
in the absence of Shell’s specific rejection that it had a nuclear
reactor/testing cell and that 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 have a nuclear reactor/testing cell would offer
immediate straightforward rejection), then it is entirely reasonable to conclude
that your client accepts the facts as stated in paragraphs 51-79 of my draft
Statement of Claim.