IN THE HIGH COURT OF JUSTICE CHANCERY DIVISION
Case No: HC01C03415
PREAMBLE This statement about Ryan's university incomes and duties was filed as a last-minute response to my statement, and in particular to my evidence (from Ryan's website) of his lecture and supervision programmes. - A. M.
I, ASHLEY PAUL STONE of 3 Worcester Street, Oxford OX1 2PZ will say as follows:
1. I am an assistant solicitor employed by Manches, the solicitors for the Defendants. I have the conduct of this matter under the supervision of the partners in the firm. I make this statement from my own knowledge or from information provided to me by persons indicated below.
2. I make this witness statement in order to correct an inaccuracy contained in the witness statement of David Robert Holmes sworn in this matter on 9th October 2001.
3. In his witness statement, Mr Holmes states, with regard to the relationship between Dr Alan Ryan and the Defendants, that: "Dr Ryan is... not paid by the Defendants in any capacity".
4. In the exhibits to his witness statement dated 4th January 2002 (received by my firm on 7th January 2002) the Claimant attaches a copy of Dr Ryan's programme of classes for Michaelmas 2001. The Claimant appears to raise the possibility that Dr Ryan is paid in connection with these classes by the University of Oxford.
5. While the issue of remuneration was naturally raised with Dr Ryan during the preparation of the Defendants' application, I have obtained his further comments with regard to the matter specifically raised by the Claimant.
6. In this regard, I am informed by Dr Ryan that he did receive small payments amounting to £171 from the University of Oxford for the financial year up to 5th April 2001, for a small amount of examining work and the supervision of two or three graduate students' work. Further, he will be paid approximately £20 by the University for each of seven lectures he gave in the Michaelmas term of 2001. In the last academic year he was not paid for the series of lectures that he gave and he is not always paid for these lectures. However, when he is paid for any work he carries out, he is paid for each piece of work separately on a piece work basis.
7. I am informed by Dr Ryan that he is also invited to give lectures, on a similar basis, by other universities such as University College London and Cambridge University.
8. I am further informed by Dr Ryan that he is under no obligation to undertake any supervisions, lectures and examinations for the University of Oxford if he does not wish to and that the University is under no obligation to offer him the opportunity to do this kind of work or to pay him for this work. That matter has also been confirmed to me by Mrs Frances Barnwell, a Solicitor and Assistant Registrar of the Defendants.
9. I apologise to the Court for the inaccuracy in Mr Holmes' witness statement. I am informed by Dr Ryan that, when he was asked by me and by Mr Holmes about payment by the University, he did not consider that the small payments referred to above were of any significance and understood the question to be directed to whether or not he received any University salary.
10. I make this corrective statement on behalf of Mr Holmes as he is currently abroad. Mr Holmes will naturally file a statement of his own should the Court so direct.
11. I believe that the facts stated in this Witness Statement are true.
Signed Ashley Paul Stone
Dated this 10th day of January 2002