THIS was not the impression that Mr Irving had, as he easily found important gaps in her Discovery, and on occasion had to go before Master Trench in interlocutary proceedings on his own summons and demand that she be forced to comply.
   When one particularly serious example of her (or her lawyers) concealing documents came to light, Mr Irving applied under the Rules of the Supreme Court for an Order that she now swear an affidavit on the completeness of her Discovery -- i.e. that she was not concealing anything else. In rare cases, if a defendant is found to be concealing items, her entire defence will be struck out.
   Mr Irving's belief is that it was the London lawyers who were concealing the more damaging items, for example Document 500, not Lipstadt; because in this case the item concerned was produced within one or two days; had it been still in Georgia, it would have taken longer.