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John G. O'Donnell, B.A.
St. Michael Street
35 Moleswoth Street
10th July 1999
My client, The MacCarthy Mór, Prince of Desmond, has asked me to confirm in writing the following facts known to me as his Legal Agent.
1. By letter dated October 20th, 1997, my client was obliged to complain directly to Mr. Fergus Gillespie, Deputy Chief Herald of Ireland, of certain defamatory statements concerning him, his titles and rights, being circulated by an Italian Citizen citing, as his authority, an unnamed member of the Staff at the Genealogical Office in Dublin. A copy of this letter is on file in my Office.
2. That by letter dated October 31st, 1997 Mr. Fergus Gillespie confirmed receipt of that letter and stated that he would bring the matters complained of to the attention of the Chief Herald of Ireland. A copy of this letter is on file in my Office.
3. That by letter dated November 10th, 1997, my client communicated to the Chief Herald of Ireland the fact that he had been obliged to commence Legal Proceedings in Italy directly related to the remarks he had complained of on October 31st, 1997. He further sought an interview, accompanied by Senior Counsel, with the Chief Herald. No reply was received to this letter, nor any interview granted. A copy of this letter, and the supporting document, is on file in my office.
4. On January 7th, 1998 my client was obliged to complain by letter to Mr. Fergus Gillespie of certain remarks of a defamatory nature, concerning the former, and made by the latter, during a luncheon conversation with a Roman Catholic Priest. By letter of that date my client threatened to institute Legal Proceedings against the aforesaid Mr. Gillespie for Aggravated Defamation. A copy of this letter of complaint is on file in my Office.
5. By letter dated January 13th, 1998 Mr. Fergus Gillespie made a written apology for the remarks made by him to the aforesaid Roman Catholic Priest. A copy of this letter of apology is on file in my Office.
6. By letter dated January 15th, 1998 (two days after Mr. Fergus Gillespie's written apology), but received by our client on February 7th, 1998, the current Chief Herald, in a letter addressed to our client as "Mr. Terence McCarthy" (despite the fact that he was then, and is now, recognised as MacCarthy Mór by that Office), informed our client that a rival claimant to his title had emerged. A copy of this letter is on file in my Office.
7. By letter dated February 7th, 1998 my client acknowledged receipt of the Chief Herald's letter, answered it in full, and made direct complaint of being addressed as "Mr. Terence McCarthy." A copy of this letter is on file in my Office.
8. By letter dated February 12th, 1998 the Chief Herald confirmed receipt of the above mentioned letter of February 7th. He sent his reply by REGISTERED POST addressing it to Mr. Terence McCarthy, thereby obliging my client to sign for receipt thereof, ignoring his reasonable complaint of this unwarranted and deliberate (having been previously complained of) manner of address. This letter is on file in my Office.
9. By letter dated June 5th, 1998, I was obliged to complain to the Chief Herald of the circulation of certain defamatory remarks concerning my client which claimed that his pedigree was fabricated and that he was to be stripped thereof. Three sworn Affidavits confirming such attacks on my client are on record in this Office.
10. On July 22nd, 1998, more than one month after the public circulation of the report that my client's pedigree was fabricated and that he was to be stripped of his title, I received a letter from the Chief Herald seeking further evidence of my client's entitlement. This letter is on file in my Office.
11. By letter dated October 20th, 1998, I replied to the above mentioned letter of July 22nd, 1998. This was a detailed reply of sixty-one pages supported by fifty-one documents, including copies of original eighteenth-century documents proving my client's connection with the Srugrena Sept, and a pedigree prepared on October 30th, 1905 for his grandfather by Sir Arthur Vicars, Ulster King of Arms. No reply has been received to date from the Chief Herald, nor any further documentation required. In addition I have, this week, forwarded to the Chief Herald a document dated July 2nd, 1906, insisting that our client's grandfather visit Paris at once.
Throughout this case my client has been forced to complain of "leaks" which did not emanate from him, or this Office. He has been deliberately misaddressed by the Chief Herald's Office, and was kept in ignorance of Mr. Barry Trant McCarthy's claim for at least eight months. The Chief Herald has copied correspondence addressed to our client to Mr. Barry Trant McCarthy, but never reciprocated by copying letters by him to that gentleman, to us. By letter dated October 20th, 1998 I made a complaint of this Action to the Chief Herald. No apology was forthcoming.
John G. O'Donnell
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