CLIFFORD CHANCE, Blackfriars House, 19 New Bridge Street, London EC4V 6BY
TELEX 887847 LEGIS G FAX 071-489-0046 DX 606 LONDON
Amsterdam Brussels Frankfurt Hong Kong London Madrid Moscow New York Paris Singapore Tokyo United Arab Emirates Warsaw
Associated offices Bahrain Saudi Arabia

ref. KEA/O0452/001/MTS

Mr Andrew Malcolm
xx Southover Street
Brighton
Sussex
BN2 2UD

Without prejudice save as to costs

Dear Sir

Thank you for your fax of yesterday.

We agree to your proposed form of words for paragraph 7 of the Order. We shall notify Henry Hardy, Alan Ryan and Richard Charkin on behalf of the Press of the terms of paragraph 7, and request that they not publish or solicit for publication derogatory statements, letters or articles about you or about the merits and quality of Making Names.

Thank you for your confirmation that you are not aware of any reason why the terms of settlement may enter the public domain through no fault of either party, or that the proposed terms of settlement have already entered or are about to enter the public domain, in reliance on which our clients now confirm their agreement that all outstanding issues have been covered.

We presently hold a faxed copy of a letter from Linnells and expect to receive some communication from Morrell Peel and Gamlen today [the subpoenaed witnesses' solicitors].

Yours faithfully,

Clifford Chance

The Press and Andrew Malcolm have agreed to settle their outstanding claims, but are bound by mutual undertakings of confidentiality as to the terms of the settlement. However, since it is binding upon you, you should be aware that one of the settlement terms reads as follows:

"The Defendants agree that they, their servants and agents, or any of them, will not publish or solicit the publication of any derogatory statements, letters or articles about the Plaintiff or about the merits and quality of the Plaintiff's work Making Names."

A list of the names of the partners and their professional qualifications is open to inspection at the above office. The partners are either solicitors or registered foreign lawyers regulated by The Law Society under the Financial Services Act 1986

Click for the next item in this correspondence (the final Consent Order) or for the correspondence index.

Return to the Malcolm vs. Oxford I (1984-92) Index, or to the Malcolm vs. Oxford II (2001-02) Index.

Go to Malcolm's Statement of Claim, to the Case History, to the Affidavits: Ivon Asquith (1), Asquith (2), Henry Hardy, William Shaw (solicitor) (1), Sir Roger Elliott (1), Margaret Goodall, to the Witness Statements: Elliott, Hardy, Richard Charkin, Nicola Bion, Goodall, to the courtroom testimony of the Oxford Six, 14/3/1990: Elliott, Goodall, Bion, Asquith, Charkin, Hardy, to the testimony of Andrew Malcolm 13/3/1990, to the Chancery Court Judgment, to the Appeal Court Judgment, to the Damages assessment, to the Settlement agreement.

Return to the Malcolm vs. Oxford I (1984-92) Index, to the Malcolm vs. Oxford II (2001-02) Index, to the blurb for Making Names, to its reviews, to The Remedy, or to the SITE INDEX.