CLIFFORD CHANCE
Should your
affidavits in reply, dealing with the Joint Declarations. office decide not to intervene in the Habeas Corpus proceedings, the Hong Kong Government may still seek the assistance of your office and ask that your office file an affidavit dealing with the Joint Declaration, bearing in mind that the U.K., rather than Hong Kong, is a party to the Joint Declaration.
Mr John Morris of your office, Hong Kong Department, has already been in touch with the Hong Kong Government in relation to the Habeas Corpus application. He is fully acquainted with some of the issues raised in Mr Osman's Affirmation and has been involved in the preparation of a draft Affidavit dealing with some of the points. He may be able to provide you with useful background information.
In the consideration of this request your assistance, it may be helpful to you to liaise with the Treasury Solicitors Department (Mr Jonathan Ziegel), Claire Montgomery, Clive Nicholls Q.C. and the Crown Prosecution Service.
We gather from our Hong Kong office that a confidential memorandum recording David Edwards' view is currently being prepared and a copy will be forwarded to you as soon as it is received by us. We have also been informed that our Hong Kong office is preparing draft Affidavits dealing with the matters which are in the public domain. Copies of these will also be forwarded to you.
If you would like to discuss this further, please do not hesitate to contact Carolyn Martin of this office.
Yours faithfully
Clifford Chance
CLIFFORD CHANCE
CC: Shelagh Brookes, Chief Legal Officer