I HENRY HARDY of 22 Norham Road, Oxford MAKE OATH and say as follows:-

1. I am employed by the Defendants as senior Editor of the Political and Social Studies Department of Oxford University Press. At the time the Plaintiff's work "Making Names" was being considered for publication in 1985, I was employed as Senior Editor of the General Books Department of Oxford University Press. I depose to the truth of the facts stated in this Affidavit from matters within my own knowledge.

2. Neither I nor the Defendants have any notes or memoranda made by me of, for or about my telephone conversations with the Plaintiff or with Alan Ryan or with Galen Strawson about the Plaintiff's work entitled "Making Names", save for those documents referred to in the Defendants' List of Documents exhibited to Ivon Asquith's (1st) Affidavit sworn on 3 August 1988, The said telephone conversations did take place over three years ago; however, to the best of my knowledge and recollection no additional documents have ever existed.

[At the Trial Hardy later admitted that, after all, he had prepared detailed notes for our contractual conversation of 20/5/85. He could not, of course, remember what had happened to them. - A. M.]

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3. I have perused my personnel file maintained by the Defendants and I can confirm that it does not contain any documents arising from or connected with my discussions with the Plaintiff or my activities in connection with the Plaintiff's work "Making Names", save for those documents referred to in the Defendants' List of Documents exhibited to Ivon Asquith's Affidavit sworn on 3 August 1985.

4. I regard the contents of my personnel file to be confidential and I object to the Plaintiff's proposed order requiring my employers to produce my personnel file to the Plaintiff's Solicitor for his inspection and copying. Furthermore, I do not consider that the production of my personnel file to this Honourable Court has any bearing upon these proceedings as all documents which could have any conceivable relevance to this action have already been disclosed in the Defendants' List of Documents

This Affidavit is filed on behalf of the Defendants, 20th January 1989.

Go to Hardy's next contribution or to the next item in the Witnesses (yellow, blue) files.

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.