I SIR ROGER ELLIOTT of 11 Crick Road, Oxford, MAKE OATH and say as follows:-

1. I am Secretary to the Delegates and the Chief Executive of Oxford University Press and I am authorised to make this Affidavit on behalf of the Defendants. Except where otherwise stated, all facts and matters deposed to are within my own knowledge.

2. I make this Affidavit in answer to matters raised in the Plaintiff's sixth Affidavit sworn on 15 October 1990.

3. In the fifth paragraph of his Affidavit the Plaintiff states that on 12 October 1990 he received an anonymous package through the post enclosing a bundle of papers purporting to be lists of general books submitted to OUP Delegates' meetings during the period May to July 1985.

4. I have checked the records that are kept* of papers submitted to the Delegates' meetings and I can confirm that the documents comprising pages 7-10 of the Plaintiff's Exhibit AM7 appear to be true copies of documents submitted to the Delegates in 1984 and 1985. All of these documents are lists of previously published books in respect of which OUP held or had acquired rights for re-publication as Oxford paperbacks. These lists were submitted to the Delegates for information purposes only and do not contain any titles for which authority for publication was being sought from the Delegates.

5. The document at page 6 of the Plaintiff's Exhibit AM7 is quite different from the others. It purports to be a list of hardback general book titles, for which authority of the Delegates would be required before publication could take place. Such lists were not prepared for submission to Delegates' meetings in 1985. The procedure for obtaining the Delegates' approval for publication of such titles in 1985, by the use of separate Delegates' notes for each title, was described by me in my testimony at the High Court on 14 March 1990. I confirm that the document at page 6 of the Plaintiff's Exhibit AM7 does not appear in any of the papers submitted to the Delegates of Oxford University Press and I am convinced that this document is a forgery.

This Affidavit sworn at Walton Street in the City of Oxford and filed on behalf of the Defendants, 16th October 1990.

* This is the best joke of all, given that in his first affidavit of 9th July 1989, which sparked this whole wild goose chase, he stated that: "there is not now and to my knowledge there has not at any time been in the First Defendant's possession, custody or power any other document listing titles of general publications tabled at the meeting of the Delegates of The Oxford University Press held on 23 July 1985 or otherwise indicating what general publication titles were approved at that meeting."