I, NIGEL BARRY ADAMS of Bishopsgate House, 5/7 Folgate Street, London, El 6BX, Solicitor of the Supreme Court, STATE as follows:

1. I am the Principal of Nigel Adams & Co. My firm has just been appointed to act for the Claimant. I have conduct of this action. Unless otherwise stated, what I say is true according to my knowledge. Where I have relied on documents or information from others, I confirm that what I have stated is true to the best of my information and belief.
2.I make this Statement in support of the applications set out in the Appellant's Notice which this Statement accompanies, seeking the orders   referred to in Part A, Section 10 on page 6.
3.The Appellant (as was widely reported in the press) represented himself at trial without benefit of solicitors or Counsel. The Appellant then instructed solicitors and Counsel to represent him shortly before the hearing of the Defendants' application for an interim costs payment of £500,000, heard before the trial judge, the Honourable Mr Justice Gray, on 5th May 2000. The Learned Judge ordered payment of £150,000 within 42 days.
4. The trial lasted 33 days, including 1 day for the judgement. Although I have not yet seen the transcript, I understand from the Appellant it is well in excess of 4,000 pages long. I am informed by the Appellant the written judgement handed down by the trial judge is 330 pages long.
5. The case is factually complex. From initial discussions with the Appellant it is clear he believes there are a number of grounds of appeal. Leading Counsel (a suitable Leader is being sought) and Junior Counsel will require the Appellant's detailed comments and instructions. Counsel will need to consider the relevant parts of nearly 4,000 - 5,000 pages of transcript and the 135 lever arch files of pleadings, submissions and evidence.
6. In terms of weight of material and time required to consider this and prepare grounds of appeal and supporting arguments and documents, this appeal, it is respectfully suggested, must rank at the top end of the scale. It is obviously in the interests of all concerned, including the Respondents   as well as the Court of Appeal itself, that the Appellant's legal representatives should ensure that only those grounds of appeal which have a reasonable chance of success are advanced.
7. Both the trial and the appeal involve matters of considerable public importance.
8. The Appellant instructed Goldsmiths to act as his solicitors on the hearing of the interim costs application on 5th May 2000. That firm was also to act in the appeal against judgement itself. Shortly after being instructed, Goldsmiths decided that because of the personal views of one of their partners, they were unable to continue to act. I have discussed the matter briefly with Goldsmiths and I should stress that their decision was not prompted either by professional embarrassment or as a result of the Appellant failing to honour any of his obligations to such firm.
9. The Appellant has therefore lost valuable time through no fault of his own. In all the circumstances it is submitted that it is in the interests of justice that the Orders sought by the Appellant be granted.
STATEMENT OF TRUTH
I believe that the facts stated in this statement are true.

Signed: NIGEL BAR ADAMS
Dated: 16th May 2000

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