First version of statement served in exchange on 19th October 1989, amended version served on 13th November 1989, re-amended on 16th February 1990.
1. My name is Nicola Cuville Bion. I work at Oxford University Press, Walton Street, Oxford, OX2 6DP. I started working at Oxford University Press in 1978 as an Assistant Publications Officer - General Books Division. At various times, I have been Assistant Editor - Academic and General Division, Editor and Commissioning Editor. My current position is Commissioning Editor in the Trade Reference and General Hardbacks Department.
2. The Memorandum of 16 July 1985 is a Delegates' Note. It was written before the internal meeting held on 17 July 1985 at which the Plaintiff's book was rejected by Richard Charkin. Delegates' Notes are sometimes written before the internal editorial meeting because of time constraints. The notes have to be given to the Secretary to the Delegates' secretary some time before each Delegates Meeting. In relation to this particular note, the due date was 18 July 1985. It was written on 16 July 1985, but the book was rejected on 17 July 1985.
3. This note would not have gone to the Secretary's sccretary because the book was rejected at the meeting held on 17 July. The fact that this particular note is a top copy indicates to me that it was not forwarded to the Secretary's secretary because I believe at that time, office procedure was that the top copy was given to the Secretary's secretary.
4. The Plaintiff sent in a second draft of his work. I read the second draft and also sent it to Alan Ryan. A number of my colleagues also glanced at it. I wrote a letter to the Plaintiff (dated 9 May 1986) telling him that Oxford University Press would not publish his book. I based that decision on both my own and Alan Ryan's opinions. Alan Ryan felt that it should not be published. I felt that the second draft was not sufficiently better than the first draft. The author had had six months to improve the work, but it still was not working. Also, the state of the market at that time was such that it was becoming more and more difficult for this kind of book to be successful. I therefore rejected the book.
DATED the 19th day of October 1989
Nicola Cuville Bion
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