The Conduct of Lord Moonie, Lord Snape, Lord Truscott and Lord Taylor of Blackburn - Privileges Committee Contents



  1. I am 79 years of age and have spent the last 30 such years as a member of this noble House. I make this declaration in order to refute, on my personal honour and my oath, any allegation that I have deliberately and knowingly breached the code of conduct. My character has gone without blemish and my record in attending the House over 30 years is exemplary and there has been no previous attempt to impugn my good name. I am advised that the Sub-Committee should take these matters of character in account in my favour, both as making it unlikely that I would fail to act on my personal honour and as supporting the credibility of this declaration.

  2. I am not going to blow my own trumpet, I have done enough of that in private, as is apparent from the Sunday Times transcript. I am a loquacious old man with an advanced degree of self satisfaction but one who is easily confused, and who rambles on, not always to the point. But I have done the state some service and have done nothing to justify a wealthy newspaper playing a monstrous trick upon me and then condemning me throughout the nation for it and selling extracts from my private conversation to broadcasters around the world. The Sub-Committee on Privileges is my only protection—I do not have Max Mosley's money, or the time left to me in this life, to bring privacy and libel actions against the Murdoch press, however much I might wish to do so. Part of me just wishes to dispel this awful black cloud that they have hung over me by leaving the Lords and enjoying what time I have left. Nevertheless, I am determined to refute the allegations that I have ever been corrupt or let down my fellow members or deliberately disgraced the House. I have done nothing wrong—indeed I have done nothing, other than airily banter with agents provocateur and I would have done nothing had their conspiracy to destroy me proceeded any further. I am neither a saint nor a lawyer: I am a former educationalist who is sometimes out of his depth and who made a mistake in not explaining the difference between a parliamentary and non parliamentary consultancy, but I have never acted with the intention of breaching the code of conduct or doing anything unethical.

  3. I have worked in local government and education most of my life and I was made a life peer by Mr Jim Callaghan in 1978 after the Taylor Report on Education. I informally but frequently advised Mrs Thatcher when she was Secretary of State for Education, and when she took over the reins of government she invited me to introduce my report in the Lords. When I entered the upper house all those years ago I told the PM that I would make a full time job of it. I have devoted the rest of my working life to being a working peer—this is my day job, unlike so many of my colleagues who maintain their occupation in business or law or other employment from which they draw substantial salaries. It has been small comfort in the last month that I have been described as one of the most regular attendees (148 days last year) although this is usually a prelude to sniping at my expenses. It has been an honour to serve regularly in the house for 30 years. I listen and sometimes participate in debates, especially on educational subjects, and do my best to advance the public interest wherever I can.

  4. But I have had to earn a living. Many people—especially journalists—do not understand that service in the Lords, unlike the Commons, is unpaid. The Sub-Committee will know that there is nothing wrong with a peer taking consultancies and I have of course done so. Initially I did this with an education business and then with BAE, helping it change its modus operandi in Malaysia, avoiding corrupt payments and establishing technical colleges there and offering scholarships to staff to study at British universities. It is an irony that those parts of the transcripts in which I condemn bribery and corruption and talk about helping BAE adopt an alternative approach are never mentioned. It is clear from what I say that I abhor corruption and will have no part in it.

  5. A theme of my consultancies from the beginning was that they had some connection with my area, the North West, and in particular had operations that generated jobs in the North West. This has always been my obsessive interest. When the Sunday Times spiders spun their web of deceit, their first inducement to me was to help bring several hundred jobs to the North West. I am sure that the journalist initially said this in a telephone call—one reason I wanted to have him cross-examined. But in any event, it was the message I took away from his description of his client's intentions. He knew exactly how to get me interested—and I make no apology for being interested. The North West is my area and I have been humbled and privileged to help its people. I have never taken more than about seven consultancies so that they bring me enough to live comfortably, without interfering with my main work of attending in the House. I should add that I have always been an enthusiastic supporter of parliamentarians declaring their pecuniary interests. In 1996 when the register first came in, it was voluntary—and I was one of the first to register. When it became compulsory as part of the Nolan reforms, I have always registered every interest and in timely fashion. I have erred only once by not disclosing an interest in the course of a debate—and I made an apology for that a few days later, as soon as my oversight was pointed out. I have never put down an amendment to a bill on behalf of a client, or arranged for a client to have favourable treatment from any minister or civil servant as will be verified by Hansard and by civil service records. I have certainly advised clients from time to time about which minister they should try to see or how they should lobby or how to structure a campaign in a way that appeals to parliamentarians, but I have never acted, in relation to a company that has paid me, without disclosing any financial interest that existed.

  6. In about 1988 I met Janet Robinson, an astute and careful woman and an ex-government scientist who looks after me in every business sense. She deals with all my consultancies, ensures that they are declared (her signature is on the Register) and does all my correspondence and bookkeeping. She is, in effect, my business partner and I would never conclude any agreement without her involvement from the outset. I rely upon her for negotiating my interests and advising me in every business thing I do, particularly in making and concluding consultancy agreements. It is perhaps the most absurd thing in the charge the Sub-Committee levels against me that I am accused of negotiating an agreement—I can barely negotiate a corridor and I invariably arrange for Janet to do any real negotiating or contracting. She serves me as a barrister's clerk serves a barrister and she negotiates the terms of the contract, which I later sign in reliance upon her advice. Everyone we know, knows that I would not make any agreement or even contemplate making an agreement before Janet has been brought in. This was never, in my mind, a serious negotiation, as I shall explain. If it got past the preliminary stage—the stage at which I was really trying to decide whether I would even entertain an offer from these people—then I would have called Janet in to do the negotiations.

  7. At the time this awful business arose, I was contemplating retirement when I turned 80 later this year. But shortly before Christmas I had a call from a seemingly educated and pleasant man who said that he was a partner in a big Brussels based PR company, MJ Associates. I had never heard of this particular company but I had no reason to doubt his confident statement that he was looking for a consultant. I made it clear from the outset that I was willing to help some businesses for free, but that I was only available for work I thought worthwhile. This all came out of the blue and the one thing that interested me—in December 2008, as we slid into a depression and the press was full of stories about job cuts, was the prospect of helping someone, against the odds, to start a new business and employ people. I invited him to take tea with me in the Lords. Why not, and where else?

  8. Now we move into transcript territory. My lawyers tell me that if this were a hearing in a court or a disciplinary tribunal, the transcripts might well not be admitted in evidence against me, because they were plainly obtained by the unlawful actions of an agent provocateur. I am therefore—and contrary to the promise to members in paragraph 25—being treated unfairly by having my nose rubbed in a transcript that would in other fair jurisdictions be excluded as a result of its coming into existence through a massive deception and invasion of privacy. That deception was not, it is true, by a state agency, but by Rupert Murdoch and his minions, and in this case Rupert Murdoch carries more clout than most state agents. This scoundrel Jonathan Calvert—and his accomplices spent lengthy time and much money on concocting a false story for the purpose of duping me. They cleverly, over two meetings, tried every trick in the book to interest me and then to attempt to make me agree to do something wrong. Their entry into parliament for this deceptive purpose with an unlawful surveillance device was a breach of the rules: they did not declare their recording device but smuggled it in by some means about which the Sub-Committee is remarkably incurious. They must have fooled or bribed or outwitted the security guards and the surveillance machines and brought the device into the tea room and the luncheon room, places where I had every reason to expect privacy. My lawyers can explain if permitted (although the Sub-Committee has so far not admitted representations by counsel) why this behaviour is a breach of privacy and a breach of Article 8 of the European Convention. No doubt it would be justified in the public interest if it produced evidence that I had committed a serious crime, but nothing of this sort was a prospect and indeed the tapes verify that I committed nothing. There was no justification for the journalists to deprive me of my Article 8 right and there is no justification for this committee to approve their conduct by accepting the transcripts in evidence. The only way in which the Sub-Committee can mark its displeasure is to refuse to accept them.

  9. That is not only an argument of law but of morality. If the right to privacy means anything, it means being able to converse in a tea room of parliament—or a tea room anywhere—without being made the victim of an elaborate deception and having your conversation secretly recorded. To my astonishment the Sub-Committee has thus far had no qualms at all about accepting this evidence, and has not even taken the necessary steps to permit my counsel to challenge it, and by so doing has shown utter contempt for members' rights to privacy. If that attitude is shared by the privileges committee, then let me say only this. There will soon be rooms in this House filled with "undercover reporters" intent on getting scoops. If the Sunday Times gets away with it, why not? In fact, why not go further and bug the tea rooms and lunch rooms and committee rooms—it is only one further step. There will be no end to it and the Houses of Parliament will become places for tabloids to use secret surveillance devices to pick up gossip and conversations and so on. And that development will be your fault, because in your anxiety, or your fear, to support the Murdoch press, you fail to take a stand for civil liberty and against secret surveillance in this House. Of course, if the Sunday Times can get away with it, so can the police and the security services and members of the Sub-Committee will apparently have no objection to that either. By failing to exclude these surreptitiously obtained transcripts, the Sub-Committee has already sold the pass. Indeed, it has asked to invigilate me on these transcripts in detail, in a procedure that, I am advised, is in breach of my rights under Article 6 as well as Article 8 of the Europe Convention. I cannot enforce these rights in the High Court, because this is a parliamentary procedure, although I may well be able to go directly to Strasbourg and argue that my rights have been infringed. That is for the future.

  10. There is, as the Sub-Committee will understand even if journalists do not, no prohibition whatsoever on peers taking on consultancy work. Whether or not there should be such a prohibition is a matter of opinion: obviously in light of the unpaid nature of membership of the House of Lords it would mean that only the wealthy would be able to take on full time work in the House. The Code of Conduct explicitly recognises our rights to take such work and requires that it be registered. It must follow from this that there is nothing at all inappropriate in a peer considering an offer of work made to him or exploring, in some detail, what that work might entail. Inviting persons who purport to be in a position to engage a peer for legitimate consultancy work to meetings in the tea and luncheon room of the House is unexceptional: it is done all the time. Ever since I became a member of the House in 1978, colleagues have used the meeting and dining faculties of the House to entertain guests with whom they are in some direct or indirect financial relationship. This has never been frowned upon.

  11. I spoke to this journalist on 17th December and the next day. We had a brief cup of coffee—the transcript lasts 20 pages. He seemed, at first blush, to be a friendly and pleasant person who was genuinely concerned to help a legitimate client contribute to the UK economy. I took him at his word and was comprehensively gulled by the scoundrel. I can now see how he was all the time setting me up. He begins with the loaded question (at page 3) "You already work for several people?" I then explained that I only worked for the people that I wanted to work for—those who in my view wanted me to help them towards something worthwhile for the country. I probed him and he lied pursuant to his dishonest script about working in Brussels and having a client who wanted to set up a retail outlet. These blandishments were carefully rehearsed—see the top of page 4. I wanted initially to understand whether this project was at all worthwhile and pressed him on what the retail outlets were for and he went back to his script and told me that they would be employing people here to sell clothes. So far, so unexceptional.

  12. Then, at page 5, we see the poison trickle out. A financial relationship is dangled and the charlatan says "what we would be looking at for you to do ... for you to speak in the chamber on our behalf, ask parliamentary questions, amend certain bits of the legislation and ... to meet ministers". The response is "inaudible" but I believe I spluttered in my coffee at these outrageous suggestions. I was immediately put on my guard—this nice, educated and decent man was either very ignorant or very bent. My immediate response was to ask him "how did you get my name?" It was the inappropriateness of the suggestions put to me that made me begin to question his bona fides. He calmed me down with a flattering answer and I went off on a long disquisition about my previous experience, getting carried away at times over the next few pages but emphasising—and this was the point of my lengthy expostulation—that I would not be party and had never been party to doing anything inappropriate. This was the point of my reference to my Malaysian experience on page 7—that I would not be party to "giving backhanders to ministers" but had helped BAE out of this mire of corruption by suggesting legitimate ways in which they could help the people.

  13. I berated the disguised journalist for his naivety both as a matter of principle and as a matter of practicality, pointing out, because I thought this guy would be more persuaded by an argument based on practicality rather than morality, the ineffectiveness of having people speak for you in the chamber. The point I was making is really one of blinding simplicity: you will get a better hearing from a minister if you get your message across to him in an informal situation—eg "over a pie and a pint" rather than in a formal meeting when he or she is surrounded by civil servants. I probably got carried away a bit with my examples but I was not on oath or under any duty to speak precisely: I was in a private conversation with a man of exasperating naivety, and trying to bring home to him how his conception of parliament was mistaken. I was trying to make the obvious point that in relation to individual corporate matters, it was pointless to expect speeches in the chamber to have any effect. This is my honest opinion. Because some of his requests seemed to me unethical, I laid down very clearly my own standards—that I was "a straight, honest operator" because "I believe in telling the truth... my credibility means a great deal to me because at my age I am not going to lose my credibility just for a few pounds... so I will not do anything that I think is dodgy or crossing that line".

  14. It must be remembered that I thought I was speaking to a partner in a big PR company, and I wanted to make it plain at the outset, crystal clear in fact, that I would not do anything unethical or tell his client other than the truth, however disappointing for his clients my honesty might be. I might break the truth to him gently or in a roundabout way, but I would not flinch from telling him the truth, in the entirely hypothetical event that I would agree to act as consultant. I made it clear (page 10) "I am not seeking work. It is my intention of finishing" and I used the phrase "it was because you just whetted my appetite to see what it was all about", I have been condemned particularly for using this phrase, "whet my appetite", but in context all it meant was that when he first contacted me he attracted my interest by stating that they wanted my help in generating 500 new jobs, many of them in the North West. It had nothing to do with money, as I made perfectly clear.

  15. The disguised journalist soothed my concerns "it's you helping us out with any problems that come up in the process of setting up this retail chain" and I then rattled on. The example I gave about ID cards obviously relates to a matter of some detail on which I had been advising a client, but I certainly had not "got it delayed" in terms of any statute or statutory amendment. My descriptions of what should be done at the top of page 11 refer to "you" i.e. the company that employs me as a consultant, and not something that I would do personally. When I say "what <au1,2>you do is you talk to the parliamentary team... <au1,2>you point to them the difficulties that the retailer will be having... <au1,2>you get them to amend it that way," I was referring to the perfectly proper procedure that companies adopt if they want changes in legislation: i.e. they go to the people responsible and make their submissions. As consultant I may advise them on how to make their pitch and whom to go to see—but it is the company's pitch and not mine. I do not play any part in the amendments process. I was telling them "what <au1,2>you do is you meet the minister, <au1,2>you meet the various people." I was not suggesting that I would do this for any company. I would help identify decision makers; certainly that is the role of a consultant.

  16. I admit that at this point I began to blow my own trumpet and I see that I fantasised about chairing "various cabinet meetings" which of course is nonsense. I did give them what I think is quite a good example of the kind of person who makes decisions by referring to Garry Mohammed's role—and this was all in the context of trying to get across to this foolish and naive man that experts in the public service are the persons to talk to about the commercial implications of particular legislation, and this was not a matter that would normally take up the time of the House. I was really uncertain about this man, he seemed at one level so decent, but on another level so ignorant. But he was purporting to represent a client with important job prospects for the UK. That is why I said (at page 12) "I'm interested... and this is only an introductory kind of meeting today." He had hooked me, in the sense of getting me interested in a legitimate and worthwhile project but I was being careful and making it clear that we were not negotiating seriously or at all: we were merely introducing ourselves.

  17. I said in no uncertain terms that he was entirely wrong in certain things and I meant "wrong" in a moral sense. He then backtracked and apologised for his naivety. I said in my straight -talking way that he was ignorant and he started to talk about money but in an attempt to turn away from this premature discussion I pointed out that money was not the question: "it's just whether I want to do it or not, that's the thing. And you've got to whet my appetite to get me to come on board." It has been one of the most vexing and depressing things about the obloquy I have suffered as a result of this dishonest enterprise that the Sunday Times has presented this statement and publicised and sold extracts from their recording on the basis that by "whet my appetite" I meant "offer me a large sum of money." This, as my previous use of "whet my appetite" explains, was related to offering others employment in the North West—that was my appetite—not offering me money. This is just one example of where this secret recording has been so damaging and so unfair.

  18. I go on to make it very clear that I have not begun to negotiate anything. I pointed out that I needed much more detail to see whether I could help them or whether I would be wasting my time, which "gets less the older I get." Furthermore, in an important section at the end of page 13, I tell the man that I want more details about him to decide "how legitimate you are and so on." As we are winding up, the journalist tries to snare me with questions about arranging meetings with ministers and I humour him but essentially the meeting had finished on an utterly inconclusive note, i.e. that I would check them out and consider whether I could do anything worthwhile for them. I am humouring him ("yep, yep, yep") but essentially telling them that as a consultant I might do research and tell them what their chances were of being successful with their proposal. At page 16 I make it clear that in giving this opinion "I will not charge you for it." In other words, I would give them initial help free of charge, if I thought them legitimate and their proposal in the public interest. At page 17, I tell them in terms that "I don't get involved in details... I will give you general advice" based on my 50 years of working with government departments. I really do get some satisfaction about using the experience I have acquired, and I feel good about "helping young people like you". If only I had known the truth!

  19. I am disturbed that the Sub-Committee has focused on parts of this transcript which have been taken out of context and do not convey the reality of this meeting, which I never conceived would be treated as a negotiation. I really think that the emphasis at page 13 ("more details about you—how legitimate you are"), which was the initial end of the coffee taking phase, gives the lie to this allegation. I further draw attention to the transcript at the bottom of page 17 and top of page 18 where we are walking to the exit and I emphasised to this imposter that "I promise you nothing. That's number one and I am absolutely, completely honest with you and I will tell you "yes" or "no" on any scheme that you produce as to whether I think you should run. You or your client will make you own mind up after that... I'm a great believer in honesty because if I have got decisions to make I can only make them if I have the true picture." In other words, I would need much more information to decide whether a) this fellow and his firm were legitimate, b) this fellow's client was legitimate, and c) whether the client was even worth helping, and if I decided to do so I would, free gratis and for nothing, tell him the truth about his project. It is interesting to see that right at the very end, page 20, it was left for him to get in touch if he wanted to, and in one of his few truthful observations his concluding remark is "it's up to us to convince you, obviously." He was reflecting what was my understanding and intention, and what he had clearly picked up from my demeanour and body language (not possible to discern from a transcript), and the general tone of the meeting, namely that it was obvious that I was not at this point prepared even to consider a negotiation until I knew a lot more about him, his company and his client.

  20. I am also concerned to draw the attention of the Sub-Committee to the fact that the original transcript supplied by the Sunday Times appears to have deliberately omitted several of the many exculpatory statements I made during the course of the two meetings with these journalists. By way of example, I draw your attention to page 8 of the Sunday Times transcript, which purports to document the end of the first meeting I had with Jonathan Calvert. Rather than transcribe the contents of the conversation at this point, which is clearly audible on the recording that was passed to me, the entry on the transcript reads: "Conversation continues as Lord Taylor takes Calvert to the peer's entrance where they part." None of this conversation is written down. Comments I made during this part of the encounter, and which are documented from page 15 onwards of the Hansard transcript that we subsequently received, include the unequivocal statement I made that what I would do for a company who engaged my services was to "do all the research and tell you what chances you've got of being successful." I went on to say to Mr Calvert that, if I decided to take on the consultancy that was being offered, that because "I don't get involved in detail" what I would do would be to "give [MJA] the general advice...and give [MJA] some idea of the way things will go." No effort was made to record my subsequent comment that "I promise you nothing. That's number one." I went on to reiterate in the firmest of tones that my role, if I accepted what was being offered, would be to advise on the likely success of a proposed scheme, and that in doing so I would be "absolutely completely honest with you...You or your client will make your own mind up after that." Such deliberate omissions lead me inexorably to the conclusion that the intention, quite clearly, of the transcript that the Sunday Times provided, was to set me up even more than they had already done.

  21. I would like to have been a "fly on the wall" back at the Sunday Times office in Wapping when they played this tape. They must have been disappointed that their vast expense in setting up this sting operation had, in my case, not produced any result. I had not been attracted by their offers of money, I had not been persuaded that the exercise was worth my while or was in the public interest. I had no intention to follow up their approach—it would be down to them. I imagine that they considered whether their game was worth the candle. They had baited the hook but having sniffed it, I was swimming away. It must have been a narrow decision as to whether to follow up. But I guess that having spent so much time and money on setting up the trap, they wanted to persevere. For that reason they produced a more lengthy document, utterly dishonest in conception and in its terms, but cleverly designed to persuade me that there was a real matter on which I could, in the public interest, offer my expertise. They say it was sent on 12th January. It was picked up by Janet, who said to me that there was something odd about it and that obviously although I could act as a consultant and give them advice, I could not intervene in Parliament for them. She said we should make no decisions. I did not read the text closely or to the end, I am afraid—all I understood was that there were things that I might help them about but that Janet said I should be suspicious of them and what they might really want, and make no immediate decisions. I did not focus on or understand any of the details about BRS and I certainly did not discuss the subject at the meeting on the 15th. I did not even check whether the House had custody of the Bill (I have now established that it did not).

  22. Early in the New Year, Janet tried to find out more about this PR company. Her researcher reported that there was very little information available about them on the web and out of interest I telephoned the number of the card that had been given to me on December 17th. I was told that the managing director was out but would call me back. This was further evidence of how elaborate the Sunday Times pretence was. My research did however establish that there was a conglomerate called Wong Hing in China. The man (Calvert, pretending to be Thompson) did call back and went on with a cunning explanation that most of their work was in Europe and that was why so little information was available. My technological knowledge is limited and I am afraid that I accepted this dishonest explanation which reassured me enough to accept his invitation to another meeting at which he expressed the wish to bring a colleague who coincidentally bore my name—Taylor. I agreed, but invited them to have lunch with me as it is more difficult for me to get about and I prefer to spend my day in the House. The explanation had been carefully constructed, possibly with the assistance of lawyers or political consultants, which again demonstrates the length which they were prepared to go and the money that they had invested in trying to entrap me. There is no doubt that they had a commercial motivation: they have not only sold extracts from the secret tape they made of me to broadcasters, but they have promoted the circulation of their newspaper on the back of this so called "scoop".

  23. I wish to point out, in relation to this second meeting, that at no stage did they lure me into breaching Code 4(c) which provides that members of the House:

    "must never accept any financial inducement as an incentive or reward for exercising parliamentary influence".

  At no stage in these introductory discussions did I accept any financial inducement, as a reward, or incentive for exercising parliament influence or for anything else. Neither meeting was, on my part, a serious discussion about any agreement, much less an "acceptance".

  24. The second meeting began with the woman, who seemed at first to be a decent and competent executive, producing the usual spate of lies to put me off my guard. However, I had given some thought in the preceding weeks to this approach, and was not reassured by their unconvincing explanation as to why they did not promote themselves. I should say that at this meeting I had at the back of my mind an episode some years ago when I became the intended victim of a confidence trickster who persuaded me to book the Cholmondeley Room for what he claimed was a charity, but the police called me two days before to tell me of his previous convictions and that he was currently under investigation by the Fraud Squad. I cancelled immediately, but with some embarrassment. I therefore had suspicions that these people may not have been what they seemed.

  25. I did tell the woman that my behaviour was "unorthodox" but that of course is not the same as unethical. I made it clear that her partner was naive and did not understand the way parliament or the civil service worked. I went off at various stages on a bit of a roll about my background and experience. I have thought about my tendency to sound off in this way and my assistant Janet has discussed it with me. I have to accept that I am a somewhat lonely old man without regular companionship, and that I may well have used this occasion as an opportunity to discourse to company, and simply to talk very loosely, perhaps envisioning myself as the powerful politician I might once have liked to be. In this sense I allowed an element of fantasy to enter into what I assumed was an entirely private occasion, over a meal for which, of course, I was paying. It may be that I was, in my own mind, using these two people as sounding boards for my own benefit. I boasted about myself extensively and somewhat exaggerated my abilities and political powers and my closeness to ministers and senior civil servants.

  26. Nonetheless I made it clear that I would not dream of doing anything wrong and again tried to explain why it was necessary for their client to approach civil servants and ministers directly rather than hire spokespeople to make speeches in the House. I remained sceptical about these two but was again reassured by their reference (page 9) to Trevor Hemmings, a close acquaintance who shares an interest in dyslexia. This was another devious and despicable lie, but it took me in to the extent that I was prepared to suspend my judgement a little longer. At the beginning of this meeting, I was genuinely in two minds and my suspicion is reflected in a number of aspects of the conversation. At this point, as they played their Trevor Hemmings trick, I was lulled into a sense of reassurance. I relaxed and began virtually to soliloquise about the way in which companies should interact with local councils. I repeated much of what I had said at the first meeting to the woman, who was rather charming and I'm afraid played on my age and susceptibility. I told her about assessing chances of planning success and gave her the lecture—it's quite true, of course—about politicians being more open minded "over a pie and a pint" rather than when surrounded by their "Sir Humphreys" who are planning to persuade the minister of the prejudgment they have already made. I was not of course suggesting that I was open to receiving payment for influencing ministers over a pie and pint in the dining room. This was never my intention. There is nothing sinister about my advising them to meet ministers informally rather than formally—it is simply the truth that all lobbyists understand—it, is merely a reflection of the way in which, civil servants, when present, manage to control ministers and inhibit their imagination.

  27. I point to my determination (at page 15) to get across to these people that "I am very very aware of the credibility that I achieved in over 50 years... I am not going to put myself in an embarrassing situation or do anything that I think is illegal or use my position in any way for monetary gain. After all these years I am not going to do that. I will work within the rules." So far, so obviously good—I am getting across to people whom I do not really trust that there is no way in which I will accept money to do anything illegal or unethical. I go on to say "but rules are meant to be bent sometimes" which has been the other quote for me that has been endlessly replayed on radio and television and in newspaper headlines. Again, it is taken entirely out of context. The saying that "rules are meant to be bent sometimes" is an old Northern saying and is probably common in many other geographical areas. In fact, I am told that the hero of the book "To Kill a Mockingbird", Atticus Finch, who is fiction's most ethical and admired lawyer, instructs his daughter with exactly this phrase "rules are meant to be bent sometimes" to cater for justice in special situations. That is precisely the way I used the phrase. In context and not in isolation. This is all part of a passage in which I insist that I will never be party to breaking the rules that the Sub-Committee has wrongly accused me of breaking. I make it clear that I am not going to accept money as an incentive or reward for doing anything improper.

  28. At page 16: I make it clear that everything is hypothetical and we are not negotiating any agreement:

    "I promise you nothing and will make no promises... if I decide to work for you of course".

  The man, no doubt disappointed that his trick hasn't worked, says "you still haven't..." and I make clear "because we (I am thinking of Janet) haven't decided yet. And it is not just a question, my dear friend, of you inviting me to join you it is whether I want to or not." They still try to tease me into making some other statement that can be taken out of context and broadcast but I am wary and offer them lunch.

  29. The prospect of a free lunch obviously excites the agents provocateur: the greedy woman orders halibut prawns and beef and several glasses of wine and we engage in minor chitchat. I pay—they don't. But I am still bothered about what they are really up to and who they really are. Their persistent questions about my contacts and their desire to meet various people are starting to make me more suspicious. They stroke my ego and ask about my favourite holiday places and so on—no doubt to put me off my guard. The woman proceeds to lie about their so-called firm and all the staff they have in London. In fact it was this lie (at page 34) which revived my suspicions, because I had been told that they were not detectable on the internet. I do recall repeating my story about BAE, to reinforce the position that I was not in favour of anything corrupt. The man at page 38 tries to come to a crunch but I am not prepared to make any agreements— "first of all, I'd like to know who I'm working with" and I didn't believe that these people had a company operational in London. I let them know that I was interested in sorting out problems and that I was not satisfied that they were being open and honest with me and at page 40 I tell them that "you might even be a reporter from one of the newspapers in disguise." Many a true word is spoken in jest.

  30. They raise the question of their website, no doubt to see whether that is bothering me. I detect some holes in the woman's story, and ask some questions about her while she visits the lavatory. These concerns read me to try to push them into giving me information upon which I can make up my mind whether to have anything further to do with them. At page 50 I come back to the nagging question in my mind as to how they ever decided to come to me. That is when I decided to push them—I had in my mind that the only way to bring this business to a conclusion was to pretend that we had done a deal and then see what they said. I really thought that their messing me around had some ulterior object. So I thought I would bring them to the crunch, pretend we had an agreement and see what they did. That is why I pretended at page 51: "we've agreed that we're doing the deal... when do we officially start? When do you want to start? Just name a figure. We've said 10 are you happy about that?" This elicited a statement from the woman that the client didn't worry about cost and the man wanted to know all about a lunch with Peter Mandelson.

  31. I called their bluff by telling them that the agreement would be notarised by Janet who would put it in the Declaration of Interests "so that it's open and above board." At this point they seemed to lose interest—for my part, I at this point had heard enough and I asked for their card to get something concrete from them as I was not satisfied. I was not prepared to act for a company that they could not persuade me was going to be worthwhile and they were certainly ignorant and hinting at having me do things that would have put me in breach of the Code. They became very evasive when I asked about their corporate operations in the UK arid about their parent company. I do know a little about public relations and by this point they struck me as poseurs. We had an inconsequential conversation about education—I really was not interested in dotting any "i"s or crossing any "t"s about any deal or any relationship. We did not have one, and I know that had they continued their conspiracy, we never would. I would not have acted for them and their client, at least until I was given further information about them. I happily chatted about their children's education, and when the woman said "you must let us take you somewhere" I said hastily "no I never go out, actually." I really did not want to see them again. I played along with their polite requests to "bounce ideas off you" but I maintained my suspicions and we chatted about the advantages of Eurostar. I made no arrangements to see them again—the last twenty minutes of the meeting rather fizzled out.

  32. Nevertheless, my suspicions and, I must admit, my curiosity remained after the meeting. I was not prepared to enter into any relationship with these people, but I did feel the need to know what they were about—and why they had come to me in particular. I was conscious of the previous attempt years before to involve me in a sting and I began to wonder what was behind this obviously expensive and carefully thought out effort. Was I really going to be of assistance in progressing this enterprise, or were they playing me for a sucker who might lend his name to a money laundering front for drugs (I vaguely remembered a case involving someone called Howard Marx whose range of frock shops were a front for drugs).

  33. Perhaps it was not the best decision I have ever made, but I chose to follow up the meeting with a call to Mr Calvert. Despite the appalling invasion of privacy involved this call was, inevitably, also recorded by the Sunday Times and I have very recently been sent a copy of their transcript (which comes in the "Extra recordings" document). In light of the scandalously edited Sunday Times transcripts of the undercover recordings in the House of Lords I have no reason to trust this one. Nevertheless, it is all I have received so I will give it the undeserved benefit of the doubt. When making the call to Calvert I thought that if I gave him the impression that I was taking his proposal seriously and carrying it through, he would be forced to either come clean with his deception or produce his client and finally establish his legitimacy. I told him that I had arranged a meeting with Yvette Cooper for the following week. I also tested him by asking him for further information, both on the Business Rates Supplement Bill (the name of which I couldn't even remember) and on his own company. I wanted to see what he could come up with. I also tried to put a little pressure on by reminding him on page 7 about the money he had agreed to pay, and asking him whether he was sure about it. On page 8 I attempted to flush out the client by asking to meet him.

  34. I was somewhat surprised to receive a full and impressive business brief from Calvert just a few days later. It seemed so genuine that I thought to myself that I had perhaps misjudged these people. Little did I know the remarkable lengths the Sunday Times were prepared to go to in their attempts to dupe me. Since my previous efforts had produced no certain result, I decided that I would `up the ante' further to finally bring this matter to a head and see whether they took fright or flight. I therefore left a message claiming to have discussed their case with Peter Mandelson and Baroness Andrews and that I would be meeting Yvette Cooper and local authority teams. I did this so that they would think (wrongly, of course) that I really had moved and that they would have to either abandon their efforts or produce their client and establish his legitimacy. I said that I would be meeting Cooper later that day. I said this to pretend that their names and their client's name was being fed into a political and bureaucratic process.

  35. Shortly afterwards—indeed, within a day or so, my trick worked to the extent that another reporter from the Sunday Times telephoned to tell me that it had been "an undercover job". He accused me of agreeing to work for them for £10,000 per month and to have actually done so by meeting Mandelson and Cooper. I think this must be the basis of the charge against me under 4(c) of the Code of Conduct.

  36. Of course, it is all ridiculously wrong. I never met Mandelson or Andrews and I was pleased to tell the Sunday Times that I had not done so and was playing their reporters along. I made it clear that "I've signed nothing or agreed nothing. I've approached no one at all about it... I was conning two reporters." I made it clear to the Sunday Times that "I've not taken a penny and would never take a penny" and that "it is improper of them to come under false pretences." The Sunday Times of course did not publish these comments. I made it clear that my comments about meeting ministers and senior civil servants were in the context of going through the appropriate channels and the usual channels. Again this explanation was not published.

  37. I turn now to the charge that has been devised by the Sub-Committee, acting (as my lawyers have pointed out) both as prosecutor and judge. Obviously I am unhappy with this position, I am accused of negotiating with a supposed lobbying company "MJA" with a view to becoming a parliamentary consultant to MJA which was acting for a supposed Hong Kong client in return for a fee to "exercise parliamentary influence" to secure an amendment to the Business Rates Supplement Bill, which would confer a two year exemption for new businesses from the provision in that bill allowing local authorities to impose an additional 2% charge on the business rate on properties over £50,000 in value, which agreement would have constituted a breach of paragraph 4(c) of the Code of Conduct; and thereby fail to act "on his personal honour" in breach of paragraph 4(b) of that code. I have a number of points to make about this charge:

    (i) In the first place it appears to be devised to accuse me of committing an offence which is not in fact encompassed by the Code of Conduct. The Code of Conduct is very clear. It says that a peer "must never accept any financial inducement as an incentive or reward for exercising parliamentary influence". It is very plain from these transcripts that I never did accept a financial inducement and I never did exercise parliamentary influence on behalf of this supposed company. That should be the end of the matter. However the Sub-Committee, straining itself to find a basis for condemning me, has decided to use paragraph 4(b) as a means of incriminating "negotiation". My lawyers tell me that this is unacceptable and further evidence of the unfairness of the Sub-Committee. I am sorry to hear that. I am not guilty of a breach under 4(b) and I have always acted on my personal honour. I did not "negotiate" for this financial deal.

    (ii) The absurdity of this charge is plain from the detail. Where in these 80 pages of transcript do I ever speak about "conferring a two year exemption for new businesses from the provision in the Rate Supplement Bill allowing local authorities to impose an additional 2% charge on the business rate on properties over £50,000 in value"? It is nonsensical to suggest that this was ever discussed let alone that I ever agreed to support this proposition. It was certainly set out in the cleverly devised five page memorandum, but "the Hansard transcript" which is the subject of the charge (namely the first two meetings) was before I ever received that. The Hansard transcript in fact discloses that nothing was said about any "additional 2% charge on the business rate on properties over £50,000 in value" and I invite the Sub-Committee, which has drawn up this charge and is proceeding to judge me on it, to point out any page of the Hansard transcript that refers to this 2% charge on the business rate on properties over £50,000 in value. I am old and my eyes are not the best but I have read this wretched transcript time and again and I find no reference to any amendment that would confer a two year exemption for new businesses from the provision in the Business Rate Supplement Sill etc etc.

  38. I have already explained that these were private conversations conducted in good spirit over tea and lunch and that I am an elderly man who is prone to speak at some length and on occasions boastfully and may get carried away and exaggerate from time to time. I imagine most people do in private conversations and I wonder how many members of the Sub-Committee could read without blushing a transcript of all their conversations that had been secretly recorded. However what I insist is that these conversations were entirely preliminary: they were not, as far as I was concerned, serious negotiations, let alone an agreement or acceptance for the purposes of Code 4(c). They were merely an exploration on my part of an unusual, possibly wrong but also possibly valuable approach by people purporting to be from a large Brussels PR company with a client who was proposing to launch a job creation business. I had absolutely no intention, at any time of the Hansard transcript or later to enter into an agreement or to create legal relations with people whom I had not yet checked out.

  39. The committee has asked various questions arising from their interpretation of parts of the tape. Let me make clear now the following:

    (i) I have never invited any minister to the peer's dining room for a meal or to talk to me in the peer's guest room, when acting on behalf of any client or in any context where I may expect a financial reward from such invitation or meeting.

    (ii) I have obviously chaired the committee that led to the Taylor report and I have discussed educational matters with Mrs Thatcher both when she was a minister and when she was Prime Minister. Obviously I have not chaired Royal Commissions and any suggestion that I did was a slip of the tongue. I was once the National President of the Education Authorities of the United Kingdom and none of the myriad of opportunities I have taken to advise in relation to education was other than in the public interest.

    (iii) I have indeed spoken to members of the Labour Party when they were in opposition about their role in a future government. This has included general discussion and advice about the respective role of ministers and civil servants. These discussions were not clandestine and were entirely appropriate in the light of my many years of experience at Westminster. I did speak about this to Tony Blair although I think the context in which I mentioned this was a boastful and somewhat exaggerated one. I was embellishing my qualifications and history of parliamentary service.

    (iv) I have worked with Experian since 1999, keeping it informed of any developments that may be of interest to their business and advising on the appropriate people to speak to in government and civil service. However, most of the work for Experian is entirely unconnected with parliament and I do not see this as a parliamentary consultancy. Any success they have had over the years in amending draft legislation has been a result of direct interaction between the company executives and the legislatures I have never myself secured or attempted to secure any amendment to any bill "quietly behind the scenes" or otherwise. The reference to Capricorn "experience" in the Hansard transcript is an error. Experian Ltd is a company that provides information on the financial status of businesses and individuals and my relationship as a consultant to this company has always been declared in the Register of Lords Interests. I have never spoken in the House on any matter concerning Experian Ltd and I have had no need to declare my interest in the House.

    (v) I have never secured any amendments by persuading "the parliamentary team, the draftsmen and so on" to amend a draft bill on behalf of my clients. I have never approached legislatures directly. I have occasionally advised clients on the appropriate people they should approach themselves directly and sometimes advised on when and whether it would be appropriate to make such an approach. As I have pointed out above, the transcript records me saying "you do it quietly behind the scenes" and "you" talk to the parliamentary team" and "you point out to them the difficulties". I was doing no more than giving a flavour of what a company can itself do quite properly, if it has concerns about forthcoming legislation. My words have clearly been misunderstood.

    (vi) I have never, obviously, chaired a cabinet meeting because I have never been in cabinet. This reference was an exaggeration—a momentary flight of fancy—in the course of a genial conversation. I am however well aware of how cabinet works, as you would expect given my long period of service, and I am well aware who are "the decision makers" in government departments. This is surely uncontroversial. While I might share elements of my knowledge and experience with a client, or anyone else who might ask me and listen to my answer, I would never put any decision maker in a compromising position or act against the public interest.

    (vii) The Code of Conduct does not prohibit members being paid as consultants and does not put a limit on consultancy fees. As I have been a member of the House of Lords since I was 49 years old, well before my retirement age, I have needed to work as a consultant to earn income and the rules have always permitted me to do so. My consultancies have been declared and recorded on the register of interests as required by the Code of Conduct, and voluntarily before the Code of Conduct. I have once received a sum as large as £100,000 per annum for consultancy work, which was intensive and had nothing at all to do with parliament. In any event many of the services are provided free of charge or to charities at my own expense if the project on which they are working "whets my appetite".

    (viii) It is certainly the case, and I fully accept, that the language I used in this private conversation recorded by the Sunday Times suggests that I might be able to arrange meetings with Yvette Cooper and Jack Straw, but that was not my intention—I said this in order to flush out the real reason why they were approaching me and to bring them to the point. The meetings with the ministers were a fabrication on my part in order "to up the ante" and either scare them off if they were tricksters or draw them out if they were not—they were clearly withholding something. And it would essentially produce the real owner of this strange company for me to meet. In the context of my scepticism about MJA, and in this private conversation before any relationship had been entered into, let alone money changing hands, my false statement was in no way a breach of the Code of Conduct. I have to say that I do not consider that approaching ministers, having explained that I am working with a certain company, having declared my interest and suggesting that the company has some reasonable points to make and would like to meet the minister could be other than proper. However, I have myself never approached a junior or a senior minister or a civil servant and asked them to meet with a client. I have of course indicated to clients with which appropriate ministers they might make contact.

    (ix) I have Janet Robinson, who is full time, and I have a part time researcher, who does not usually work in the House of Lords. Any additional research is carried out for me by the companies themselves.

    (x) I have worked at Westminster for many years and obviously have contacts and discussions with various members of governments and civil servants. I have not however approached such figures on behalf of a client as a result of any financial incentive. I have sometimes approached them for reasons of public interest.

    (xi) I have spent many years in the House of Lords but before that my work in education led me to have various good relationships with members of that department. I have had the opportunity to speak to civil servants about the content and legislation particularly in the education area and I have commented when I thought it right as a matter of public interest. I have never, however approached civil servants about the content of legislation on behalf of a client. I have advised clients from time to time on the appropriate department to address its concerns.

    (xii) I have always worked within the rules, although I am a great believer in interpreting them with commonsense rather than legalistically. I think everyone agrees that there can be exceptional cases and that over proscriptive rules can do more harm than good. I have not broken the rules or, to my knowledge, bent them. I have pointed out already that the context in which this reference appears in the transcript: the phrase is proceeded by my statement that I will absolutely not put myself in an embarrassing situation or do anything that is illegal or use my position for monetary gain. I made it very clear to Calvert at our first meeting that "I am not going to lose my credibility for a few pounds".

    (xiii) I accept (again) that my statement about select committees and Royal Commissions was an exaggeration in a private conversation after I had become somewhat carried away with my tame and attentive audience.

    (xiv) I do indeed have a strong relationship with several government departments, albeit not with "most of them". This is a minor exaggeration.

    (xv) There was no detailed discussion of the Business Rates Supplement Bill and it was only referred to in passing. I had not decided to work with MJA and I was planning to do further checks on their authenticity and reputability. Obviously, in the hypothetical event that these checks were positive, I would have been willing to direct them to the appropriate government department so they could present their concerns about the legislation in question. This would have been perfectly proper and within the rules of the House. I would never have contemplated talking to the policy team myself or seeking to amend legislation "behind the scenes"—this is something that I have never done and certainly not something that I would begin to do at the age of 80.

    (xvi) I deny that any deal had been finalised with MJA. No money exchanged hands and nothing was ever done by me on MJA's behalf. They mentioned £10,000 and at one point I pretended that the deal was done and said more or less let's get on with it: they backtracked; it was part of my test of whether they were genuine. I really wanted to find out what they were about—they seemed to be good people but so naive about what was and what was not permissible that their motives were hard to ascertain. I guess I am a fairly open and straightforward north countryman who imagines that others are honest. I was still determined to check their authenticity and repute and I might have been prepared in that hypothetical case to work with them. However this stage was never reached. The Hansard transcript records no more than preliminary discussions at which there was never on my part any attempt to enter into legal relations.

  40. I wish sincerely to apologise to all my fellow peers for what turns out to be my gullibility and indeed stupidity. But I assert that I have never acted against my personal honour or deliberately in breach of the Code of Conduct: I am confident in my own conscience that I have at all times followed the rules and directions of the House and put the public interest first, and that has certainly been the case in my 31 years as a member. I should add that I have been the victim of a notorious entrapment: that I have been made a laughing stock up and down the country by the Sunday Times exploitation, for their own financial reward, of their secretly and unlawfully conducted taping. I have been branded as corrupt and my reputation has been wrongly destroyed. I do not have the time left to me or indeed the financial backing to bring actions for libel and or breach of privacy: I am reliant on my colleagues to defend me. I am deeply sorry for the foolish exaggerations.

  41. I would like to say two things, finally, to the Sub-Committee. Firstly that I hope that you recognise that I have been the victim of a vendetta by a powerful force in this country which has stripped me of my privacy and used my own loose language, out of context, to destroy my reputation. I have been made to feel like Malvolio at the end of "Twelfth Night"—exposed to the world as a knave and a fool, although now with some insight into the faults which made me an easy prey to these dishonest sensationalists. I have suffered greatly in the past weeks both in mental anguish (which has affected my health) and financially: my days as a consultant are over and I have had to expend a hefty five figure sum on retaining lawyers to deal with all the fallout from the media enquiries generated by the Sunday Times. That newspaper, in pursuance of its vendetta has several times threatened to publish completely false "follow up" stories, and my solicitors have had to deal extensively with these enquiries, to show the stories to be false. Other newspapers have done the same thing, circling over me like vultures. I have myself partly to blame, of course, but they would not have come after me if I had not been a member of the House and if my privacy had not been invaded in the first place.

  42. But more importantly I do most humbly and sincerely wish to apologise to all my fellow peers, because in the cause of pillaring me, the press have cast aspersions on utterly blameless colleagues and on the House and its work in general. I have explained, and I reassert, that I have had no intention to breach the code and I am actually innocent of the charge that the sub-committee has formulated. But I am guilty of boasting and exaggerating and with hindsight I realise I should have handled my suspicions about these people in a completely different way. My worst mistake, I think, was in not making clear to them at the outset the difference between being a consultant and being a parliamentary consultant, and clearly explaining to them what a peer was allowed to do for them in each capacity, if ever a financial relationship were to be negotiated. That said, I can only repeat on my oath that I have never accepted, and would certainly not in this case have accepted, a financial inducement for attempting to alter or affect parliamentary legislation.

  AND I make this solemn declaration conscientiously believing the same to be true and by virtue of the provisions of the Statutory Declarations Act 1835.

Declared this 23 day of March 2009

at Tuckers Solicitor's

39 Warren Street, London

before me: F.S. Baard.




  1. I have worked with Lord Taylor of Blackburn CBE since November 1990 as his assistant and the person who deals will all of the business side of his affairs, from negotiating terms in relation to any retained advisor roles that he has undertaken, to ensuring that his declarations are compliant with the rules of the House both in their terms and spirit and managing any fees that he is paid for consultancy work. I also run his diary, do research, prepare and file quarterly VAT Accounts and prepare his annual tax returns for the Accountant.

  2. I have had the opportunity of reading the Statutory Declaration of Lord Taylor and am able to say that so far as matters are within my own knowledge, that they are accurate. In particular, our division of labour as set out in paragraph 6 is correct, as are the reservations which Lord Taylor mentions that he had about the agents provocateur from the Sunday Times. It is fair to say that I myself had misgivings about their approach to Lord Taylor, but there was nothing solid that I could put my finger on—just one of those occasions when something doesn't seem quite right. Certainly the approach, as it purported to be, from a lobbying company, was not something which Lord Taylor has ever undertaken in the past. He has always steered clear of working for lobbyists. I had discussed my unease about the approach with Lord Taylor on several occasions after contact was first made, and before the Sunday Times revealed themselves. As will be seen from the Register of Members Interests, all of his consultancies have been directly with the companies concerned, and not via intermediaries.

  3. As a result of a request from Lord Taylor, my son, who undertakes research and technical work on behalf of Lord Taylor, investigated the fictitious PR company and Wong Hing (their supposed client). A quick Google search reveals that there is in China, apparently based in Ningbo, a real and substantial conglomerate of that name. Lord Taylor could not remember the name of the individual who was said to be behind the company and nothing was revealed about the mysterious "Emerald Corporation" which, according to the journalist's tale, was based in Hong Kong but backed by a large regional conglomerate.

  4. One point I should make expressly clear is that at no time did Lord Taylor ask me to entertain negotiations—as would have been his invariable practice—nor did Lord Taylor ask me to enter into arrangements with either the company, any principal or indeed the PR agency "MJA Associates." This corresponds exactly to Lord Taylor's position that he had not agreed to undertake any work for any party in connection with this approach. Neither did he ask me to notarise any agreement, or to prepare a declaration of interest, as he usually would if an arrangement was going to be progressed further. Clearly the bluffing described at paragraph 31 of Lord Taylor's statement was just that.

  5. I should also draw to the Sub-Committee's attention the fact that Lord Taylor does not use the internet and therefore his emails actually come to me in Kent. This arrangement means that all emails in this matter sent to Lord Taylor from "MJA" came to me at home, rather than directly to Lord Taylor. As you can imagine, this set-up leads to attendant delays in Lord Taylor seeing his emails. While of course, the emails in question here would eventually have been seen by Lord Taylor, I cannot say with any certainty when. Lord Taylor had expressed a desire to remind himself and refresh his memory about the people he was meeting, but may not have had the opportunity to do so by the time of the meeting.

  6. When I first started working with Lord Taylor I suspected that he might be suffering from a mild form of dyslexia, although he has never admitted as much to me—I suspect he has been too proud. With this in mind, in order to be sure that he understands fully any important communications, it has always been my practice to read the documents to him out loud, in addition to forwarding hardcopies.

  7. An email was sent by "MJA" to Lord Taylor arriving with me on 12 January, after the first meeting. It was not picked up by Lord Taylor until the morning of the second meeting, the 15 January. The second email, which enclosed a briefing note on the Business Rates Supplement Bill, arrived after Lord Taylor had had the second meeting with the undercover journalists. If matters had progressed, the emails would have been read to him, but as we never reached that stage this did not happen. Importantly, I never read the briefing note to Lord Taylor.

  8. There is one other matter that I wish to raise, which is that the two emails sent to Lord Taylor by the Sunday Times did not all stay in my inbox. I noticed that two emails, I think I can best put it, "evaporated" in that they were not deleted by me but they ceased to be in the in-box after a period of time and so I could not forward them. I raised this recently with Mr. Stephens who advised me that he has a client that uses such technology and he was aware that this was technologically possible.

  AND I make this solemn declaration conscientiously believing the same to be true and by virtue of the provisions of the Statutory Declarations Act 1835.

Declared this 23 day of March 2009

at Tuckers Solicitor's

39 Warren Street, London

before me: F.S. Baard.


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