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Marcus Rutherford

D J Freeman

43 Fetter Lane

London EC4A 1JU.

15 September 2000 

Your ref   MWR/PAS/011311999

Dear Mr Rutherford, 

Thank you for your letter of the 13 September.  You claim that I am perfectly well aware of Shell’s position concerning my ‘allegations’.  Furthermore, you go on to complain that I am simply repeating the (same) allegations.  With respect, your assertions are incorrect.  A simple re-reading of my letters will show the flawed nature of your ‘red herrings’. 

I find your claim that I ‘am perfectly aware of Shell’s position’,  perplexing.  May I ask how, when, who or where Shell or anyone else has ever disclosed to me Shell’s position regarding paragraphs 51-79 of my draft Statement of Claim?  Consequently, please substantiate or withdraw.  In light of your expected failure to forward details of Shell’s disclosure of its said position, I once again ask:  

Does Shell stands by its declarations as per its 7 February 1994, Narrative:  

‘(a) Shell Thornton was not involved in "atomic research" (page 1).’

‘(b) Thornton did not house a "nuclear facility"….  Thornton did not and never has housed a pile or reactor.  (page 2).’

‘(c) We do not understand what you mean by "atomic research for military purposes".  We have already explained that Thornton was not involved in any atomic research (page 2).’ 

I would be most grateful if you would now supply direct straightforward answers, instead of needless prevarication.  However, I repeat, in the absence of Shell’s specific rejection that it had a nuclear reactor/testing cell and that it carried out the military, and other, nuclear research programmes-as set out in paragraphs 51-79 (for self-evidently any organisation that did not have a nuclear reactor/testing cell would offer immediate straightforward rejection), then it is entirely reasonable to conclude that your client accepts the facts as stated in paragraphs 51-79 of my draft Statement of Claim.   

Yours sincerely, 



John Dyer.