R. B. 1
.:MARK, LL.B.
Miss P. D. T. SOPER
G. J. HADEN, LL.B.
D. J. 8. HALLMARK
Our Bel. DJSH/JS
We shall havve
to decline this
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محمد
SOLICITORS COMMISSIONERS FOR OATHS
4 & 5 SANSOME PLACE WORCESTER. WR1 1UQ
Your Ref.
Telephone:
WORCESTER 92946 (9lines)
1.T.D. 0905
6th July, 1978.
The Rt. Hon. Barbara Castle M.P.,
The House of Commons,
London SW1 AOAA.
Dear Mrs. Castle,
Pursuant to our conference with the Foreign Secretary at the Foreign Office on the 20th June, 1978 I have considered the bundle of confidential papers made available to you in your room at the House of Commons.
You will recall that I was authorised to make full notes of the contents of these documents but not to take a copy. I would ask you to seek permission for me to have a copy.
Having studied the documents in the short time available I am obliged to recall my appreciation for your representations to the Foreign Secretary to secure these documents.
Asyou know my opinion is that the interests of Rita Nightingale are best served at the present time by ascertaining whether or not her instructions that she was an unsuspecting carrier of heroin is capable of corroboration. I take the view that evidence on her behalf that she was involved with experienced members of a drug syndicate is such relevant corroboration.
It can be argued that experienced members of an illicit drug syndicate would involve outsiders as little as possible. Criminal courts may even be persuaded to take judicial note of such argument without formal evidence to support. This argument is emphasised when the drug dealers are Chinese and male and the outsider is European and female.
My thesis on behalf of Rita Nightingale is to emphasise the features of the Hong Kong connections and circumstances suggesting an international syndicate. These facts may not establish innocence or total lack of knowledge by Rita Nightingale. However if facts tend to show that her evidence is entitled to be believed it will be argued on her behalf that the prosecution have failed to prove beyond reasonable doubt that she "intondod" to possess heroin, and further that Rita has produced ovidonon
to support her donial of guilt.
Continued...
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