PARTNERS John Upcher LLB Robert MaeKay LLB Joan Roberts BA LLM Stephen Knight LLB Michael O'Farrell LLB John Bennett LLB Timothy Bugg BA LLB Alison Quinn BA LLB

CONSUL.TANT Valentine Smith LLB 8Com FCPA

Notary Public

ASSOCIATES Andrew walker LLB Robert WebsUtr BCom LLB Sarah Daly BA LLB Ewan Stewart LLB Juanita O'Keefe BA LLB Craig Bowman BCom LLB o.rnon Sy~ BA LLB Gretel Chen BA LLB SUNO Larsen BA LLM Stephen 'Mcka LLB

22 February, 2002

The Hutchins School P0Box254

Dobson, Mitchell & Allport BARRISTERS & SOLICITORS

Established 1834

OUR REFERENCE:

S9 HARRINGTON STREET

HOBART

TASMANIA

RCM:667379:sp YOUR ReP'eReNCE:

SANDY BAY TAS 7006

Dear Sir,

Thank you for your fax of 22 February 2002.

GP08ox20 HOBART Tumanla 7001

DX 112 Hobart

Telephone: (03) 8220 8220 FKSlmle: (03) 8223 8833

ABN 88 989 504 094

Afloat 30 Brisbane Street Launceston Tumanla 7250

E-malllnfo@doma.com..u

The statement you sent me was in fact one of two alternate qualified apologies drafted in 1996

following discussions and correspondence withr oAj s then solicitors. It was determined in May 1997

that a qualified apology should not be sent.

These has never been much of a risk tha IAOA will commence legal proceedings against the School .

The relevant events occurred many years ago and it is unlikely tha OA would be able to find a way to

avoid the relevant time limits for commencing proceedings. The real issue has always been whether

~will "go public" with his allegations and whether or not any form of apology from the School will

resolve the problem or exacerbate it by providing some evidence which ·u use to support his

allegations.

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-2-

In esset.L-..~ me problem has always been how to handle the matter if it becomes public. I note when

first instructed in March 1996 I suggested that the School seek advice from a media consultant or

similar person about the matter and Mr O'Farrell repeated the suggestion in his letter of 18 April 2000

(a copy of which is enclosed*).

It seems to me the position is still the same as when Mr O'Farrell wrote on 18 April 2000 and his

advice is still appropriate. Mr O'Farrell suggested certain steps be taken in the event that the Mercury

contacted the School with a view to publishing a story about ~ It was apparent from your letter

of2 February 2000 to us that the Mercury had been given information, including correspondence

between the School and Mr~ The Mercury nonetheless decided not to run the story. Whether or

not the Mercury takes a similar view now is obviously impossible to predict, although matters of this

nature are obviously highly topical, given the recent controversy surrounding the Governor-General.

These matters, in my view, confirm the need for the School to take advice from a media consultant, if

it has not already done so, as soon as possible so that the School is in the best position to limit any

adverse publicity which may result if the Mercury decides to publish.

Please do not hesitate to contact me if you wish to discuss the matter.

Yours faithfully, DOBSON TCHELL & ALLPORT

R MACKAY Direct Line:­Direct Emai~

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