London, Saturday, April 3, 1999
Since I received the reply from Mr Graham dated March 31 to which I referred in my letter of April 3 I have received no further response to my complaint.
Unless I receive from you by close of business on Thursday next, April 22, a letter with substantive proposals to redress my complaint, I shall take the usual steps to commence action for deceit and defamation under the new procedures and otherwise to reserve to my position. I am at the High Court on Friday bringing an interlocutory action against Penguin Books. My fax number here is 0171 409 7048.
I have now obtained a copy of the programme complained of. I put you on notice that under the new rules of discovery I shall apply for specific discovery of your office's correspondence to establish whether and when you took steps, as I requested, to ensure that the unedited tapes were not wiped.