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Letter from Ms Geraldine Proudler to
the Parliamentary Commissioner for Standards
NEIL HAMILTON MP - GUARDIAN NEWSPAPERS LIMITED
As discussed recently with you and with Mr Pleming
I now enclose the results of the exercise we have carried out
to assist you in identifying all relevant documents in this matter.
I enclose the following:
(i) Index we have prepared for the two files
of core documents you have received which constitute the trial
bundle (4 copies);[16]
(ii) File containing indexes for all other
relevant documents (4 copies).
You will appreciate that after the libel action
came back to life on 31 July with a trial fixed for 1 October,
there was a team of people working on this case full time, principally
in carrying out further enquiries and trying to obtain relevant
documents which we believed to exist. The documents came to us
in various miscellaneous bundles, often with no index or other
record of the contents of the bundles, and this applies particularly
to some of the most significant financial records which we obtained
from the Plaintiffs at a late stage. For each separate set of
documents we have therefore produced an index for you if one was
not already in existence, and these are contained in the enclosed
file. In my view it is important to have this definitive check
list of relevant documents for the following reasons:
1. The trial bundle we have sent you was prepared
by our counsel as a core bundle in haste over the weekend before
the trial was due to start on Tuesday morning, in circumstances
where the Plaintiffs had not produced a trial bundle. This would
inevitably have been added to as the trial progressed, and although
it contains essential documents, it is by no means comprehensive.
It also relates principally to Mr Hamilton and Mr Greer, as Plaintiffs
in the action, and not to other MPs who are the subject of your
inquiry;
2. I have no idea what documents have been provided
to you by Mr Hamilton, and I suspect that these may not be comprehensive.
My reason for saying this is that Mr Hamilton has not yet collected
from our office any of the copy sets of documents which he has
told us should be made available for collection, and Mr Greer's
solicitors have collected specified principal documents without
carrying out a comprehensive check and without the benefit of
an index for the documents they have retrieved. It is not clear
to me therefore whether a comprehensive exercise has been carried
out in preparing the documents which have been presented to you
by Mr Hamilton.
The index at the front of the enclosed file lists
as enclosures to the file a separate index for each set of documents
in existence. Dealing with each of these categories in turn the
position is as follows:
1-5 These are all Government documents
which ought to have been made available to you by the Treasury
Solicitor;
6. This is Central Office material which
is unlikely to have been supplied to you from any other source;
7 & 8 These are in my view the most
crucial documents relating to payments to MPs. They were disclosed
by Mr Greer at a late stage before the trial, and in some cases
were identified by us by trawling through accountants' working
papers which were made available to us for inspection. As far
as I am aware the enclosed index for each of these sets of documents
is the only comprehensive index of them which exists. The significance
of some of these will be apparent from the descriptions in the
index. I also point out that enclosure eight identifies supporting
documents in relation to the Schedule of General Election expenses
which is included in the trial bundle at page 197. These documents
should be available to you from Mr Greer. You will see when you
receive these documents that they do not account for all of the
money shown as incoming in that schedule, and this is one of the
crucial areas of our further discovery applications at the time
the case settled;
9-11 These list the Plaintiffs' documents
which were formally disclosed to us, other than on the piecemeal
bases I have described;
12-18 These identify the Defendants' documents.
You will see that the number of documents in
existence in relation to this litigation is very considerable,
and it was for this reason that I thought you might find it helpful
to have a meeting to discuss the principal documents. I hope
that the enclosures to this letter will however enable you to
assess the documents which have been provided to you to date,
and the extent to which there may be gaps in these documents.
Should you find it helpful to have a meeting in relation to documents,
I will return to the office after Christmas on 6 January. I will
write to you again this week about the submissions relating to
individual MPs.
Geraldine Proudler 17 December 1996
16 Not printed. Back
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