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IN THE HIGH COURT OF JUSTICE No. 257 of 2002
RE DAVID JOHN CAWDELL IRVING
WITNESS STATEMENT OF KEVIN BAYS
I, Kevin Bays, solicitor and partner in the firm of Davenport Lyons of 1 Old Burlington Street, London, W.1 say as follows:-
1. I was the partner having the conduct of this matter on behalf of Penguin Books Limited ("Penguin") throughout the trial of the libel action between David Irving and Penguin.
2. I have personal knowledge of the subject matter of the retainer between my firm and Penguin, and I can confirm that the liability for the costs incurred by Penguin is that of Penguin, that all accounts for fees and disbursements have been rendered to Penguin, and that in the event of non-payment, I would hold Penguin liable to account for such fees.
3. In practice, the VAT exclusive sums in relation to bills was (sic) transferred directly to my firm by Penguin's insurers, and the VAT element of such bills was paid by Penguin.
4. I believe the facts stated in this witness statement to be true.
[signed] Kevin Bays
Dated 21 May 2002
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