New Forest East



Dear Sir

Our Client: Dr Julian Lewis MP

We act for Dr Julian Lewis MP.

As you will be aware, on 1 March 2009 the News of the World published a story headed "Tory secrecy campaigner's £60k payout" which falsely alleged, amongst other things, that our client hardly ever visits his constituency home and uses arrangements to protect his security – as someone with a long history of fighting extremists – as cover for "milking" his Parliamentary allowances for personal gain.

However, the article contains one very specific and accurate matter of fact: that, in June 2004, our client changed the designation of his main residence from his flat in London to his house in [New Forest East].  We enclose a copy of the article for ease of reference.

We are instructed that you have so far made 16 requests to Parliament under the Freedom of Information (FOI) Act, 12 of which relate directly to our client and/or his staff.  One of your requests was for disclosure of whether his constituency home or his London home is designated as his main home, and "whether or not there has been any declaration of change" in this designation "during the past five years". The Parliamentary Officer responsible for requests under the FOI Act replied to you by e-mail on 11 July 2008, as follows:

"for the purposes of the Additional Costs Allowance the main home is in the constituency. Before June 2004 the main home for the purposes of the Allowance was the London residence".

Your request to be given the address of his second home was refused at the same time.

We are instructed that no request for disclosure about our client's homes has been made by anyone else, and that this fact concerning the date of the change of designation (which was entirely within the House of Commons rules) has been disclosed to no other FOI requester.  It therefore follows that you must have given this information to the News of the World to encourage the publication of the damaging and misleading story referred to above.

Your conduct in this matter follows a pattern of behaviour which our client can only interpret as being highly mischievous and hostile towards him. You are well aware, from our client's exchanges of correspondence with you between October 2008 and February 2009, that he has repeatedly given you opportunities to explain your behaviour towards him and his staff. Most of your activities have been carried out behind his back, including what our client considers to be the disgraceful attempt to have him criminally investigated by the Hampshire Police which you immediately leaked to the Lymington Times. Fortunately, you were rebuffed in the strongest terms by the then Chief Constable.

From our client's point of view, your dealings with the News of the World are the latest example of this underhanded activity.

In the circumstances, our client has asked me to give you one opportunity to confirm or deny in writing (i) whether or not you were in contact with the News of the World before the article about our client appeared, and (ii) in particular, whether you were the source of the information in the article about the change of designation of our client's homes in June 2004 and/or the false allegation that he is "hardly" present at what has for over 10 years been his genuine home in the constituency.

Our client believes that the internal evidence in this false story demonstrates that you were the initiator of it. This letter is being sent to give you the opportunity (i) to deny any role in the concoction of the News of the World report and (ii) to explain how else the newspaper could have obtained knowledge of the change of designation in June 2004, which was disclosed by the House of Commons only to you.

Our client intends presently to mention these matters publicly, and is offering you this chance to put forward your explanation of events, before he proceeds.

He has also previously asked you to answer nine questions arising directly from your earlier conduct towards him. We are instructed you have declined to answer any of these perfectly legitimate questions on the grounds that you allegedly feel intimidated by them.  Our client's questions are, of course, not intended in any way to intimidate you but are designed to provide you with a full opportunity to respond and to correct any alleged inaccuracies of fact before he comments publicly about your behaviour.

It is, therefore, appropriate that you should now answer our client's nine questions, copies of which are enclosed, as well as to answer the additional questions about your apparent dealings with the News of the World in advance of its 1 March story.

If we do not hear from you by 25 March 2009 our client will proceed as indicated, and people will be able to draw their own conclusions from your continued and persistent silence.

Yours faithfully

Gisby Harrison

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Dear Mr Harrison [sic],

I find the actions of Dr Lewis in instructing you to send me your letter dated 12th March 2009 quite extraordinary, as it raises no apparent legal issues. I can only conclude Dr Lewis intends to intimidate.

I have previously informed Dr Lewis on a number of occasions, in writing, that I find his actions intimidating. I also find it incredible Dr Lewis considers he has the right to tell me how I should feel about his actions.

I will place this latest letter with the growing pile of other letters, emails and a message left on my answer phone, which I have received from Dr Lewis over a period of almost nine months.

I note from your letter that Dr Lewis intends to make a public statement. It would be disappointing, if he were again to use the cloak of parliamentary privilege, to perpetuate erroneous facts.

Yours sincerely

Terry Scriven

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Dear Sir

Our Client:  Dr Julian Lewis MP

We refer to your letter dated 20 March 2009.

Our client regards your letter as no answer at all to our letter of 12 March 2009.  By repeating your claim to be intimidated, you have sought to avoid answering a straightforward question about your dealings with the News of the World, a tactic you have used on previous occasions. Your statement that you are adding our letter to a "growing pile of other letters" overlooks the fact that no such pile would exist but for what our client perceives as your malicious activities against our client coupled with your persistent evasions of all questions put to you about such underhanded behaviour.

Our letter concerned a very serious matter, namely the publication in a national newspaper of a damaging and misleading story about our client, which story appeared from internal evidence to have been initiated by you. You have refused to take the opportunity which we have given you to deny that you were behind the story.

Our client finds it ironic that you have made repeated complaints and filed multiple Freedom of Information requests about him, and his staff, to which you expect answers; yet, when given the opportunity to answer legitimate questions about your own actions in respect of him, you shelter under the claim of being "intimidated". The person who really has been subjected to intimidation and harassment is our client, as a direct result of your surreptitious use of hostile journalists on the Sunday Telegraph and especially the News of the World, and (as previously mentioned) your failed attempt to have him criminally investigated by the Chief Constable of Hampshire.

In the course of your campaign of surreptitious smears, you have deliberately and seriously compromised the security of our client’s home addresses.

Our client will take whatever action he deems appropriate to put on the record your malicious behaviour and your evasion of reasonable and proper questions. One of those questions was to ask you to list any matters of fact in the speech he made in Parliament about your behaviour, which you have once again claimed to be "erroneous". Kindly state, without further evasion, what the claimed inaccuracies are: we are instructed that you have repeatedly been invited to do this, but have always refused.

As a second issue, our client’s attention has been drawn to an article you have written and posted on the New Forest Liberal Democrats website under the heading "In My View – We Have the Right to Know".  We enclose a copy of your article.

This reveals that you have now written behind his back to the Director General of the Security Service and the Chief of the Secret Intelligence Service, amongst others, demanding information which you must be aware these organisations would never supply. The purpose of such behaviour would therefore appear to be to generate further press smears and cause annoyance to our client.

Your online article also states that during the past year our client has refused to make his expenditure of taxpayers’ money public by linking it to his campaign to keep the addresses of MPs secret.

As you must know, it is completely false for you to state that there is any link between our client’s campaign to maintain the confidentiality of MPs' addresses and the issue [of] the publication of Parliamentary allowances claimed by our client.

Our client’s position on publication of expenditure from Parliamentary allowances has been clear and consistent throughout.  We have seen statements by him in both the Lymington Times (26 April 2008) and the Southern Daily Echo (18 July 2008) confirming that full details of his use of his allowances will be published at the same time and in the same format as those of all other MPs. We have no doubt that you have seen these statements too.

Your allegation, that our client has used his campaign for protection of the confidentiality of MPs’ addresses as a means to cover up his expenditure of public money, could not be further from the truth. As you have seen fit to make this allegation publicly, our client is entitled to an explanation of the basis on which you made it.

Finally, we wish to know how you reconcile your persistent focusing of media attention on our client’s home addresses with the contents of your e-mail to Dave Yates, Chief Executive of New Forest District Council, dated 11 July 2008, in which you stated: "I fully understand the reasons for Julian wishing to keep his private address confidential ... I am sure both Julian and I understand the need for security". You also stated, in an e-mail to Councillor Diana Brooks dated 18 July 2008: "I support [Julian Lewis] totally in keeping the addresses of MPs, Prospective MPs and indeed Councillors [sic] addresses private and out of the public domain".

Given such statements, your role in initiating newspaper stories seriously compromising our client’s home addresses is totally indefensible. This is why we offer you a final opportunity to deny that you were the source of coverage in the News of the World on 1 March and, if you do deny it, to explain how the story contained an item of factual information which the House of Commons had disclosed to no-one else but you.

Yours faithfully

Gisby Harrison


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Dear Mr Jackson

In respect of the demands and accusations contained in the letter dated 25th March, which your client has instructed you to send to me, I have nothing to add to my comments of the 20th March.

However, I do wish to comment on Dr Lewis’s observations about my article 'The right to know'. In a number of letters to a local paper, which have concerned Julian Lewis's parliamentary allowances he has linked, in the same letters, comments about his campaign to keep private the addresses of MPs. Accepting that Dr Lewis could be sensitive on these issues and misconstrue this I took immediate steps on receipt of your letter.

Yours sincerely

Terry Scriven

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Dear Sir

Our Client:  Dr Julian Lewis MP

We have received your letter dated 30 March 2009.

We note that you have removed from your website article the false claim that our client "has refused to make his expenditure of tax payers' (sic) money public by linking it to his campaign to keep the addresses of MPs secret".  We have no doubt you did this out of recognition that your allegation was potentially defamatory of our client and not out of any 'sensitivity' relating to our client.

He is, however, extremely sensitive on such questions as his reputation being smeared in the News of the World, his being reported behind his back to the police and his having the security of his home addresses compromised by you.

As you have repeatedly refused to take the opportunity to deny instigating the News of the World story, or to explain how the story contained information disclosed to you and you alone, you should take this letter as formal notice that our client will be – as previously notified – disclosing to the public your surreptitious responsibility for this smear.

It would have been a very simple matter for you to state that you had nothing to do with the story.  The fact that you have conspicuously failed to do so makes the conclusion all the more unavoidable that you are responsible for it.

Yours faithfully

Gisby Harrison

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