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Please note that text in red denotes my comments

From solicitors Tughan & Co. to solicitors Madden & Finucane dated October 2nd 1995.

Re: Freddie Andrews (Junior)

Dear Sirs,

We would refer to your letter of 27th ultimo.

Unfortunately you have not explained the interest of Eileen Wright save to describe her as a sister of Freddie Andrews (Junior) and we would be glad if you would clarify the position.

We regret we have not been aware of Press speculation etc. relating to the affairs of Mr. Andrews and we would be glad if you would make available a copy of each relevant document.

You are not entitled to discovery of documents prior to proceedings. However we would be prepared to consider early disclosure of any relevant document which is in our possession, custody, power and control on receipt of an open letter setting out clearly each allegation to be presented by Eileen Wright. You will recognise that no document can be classified as relevant until the issues between the parties have been presented.

Yours faithfully,

TUGHAN & CO.



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