AFFIDAVIT OF MARCIA SOLOMON

I, Marcia Solomon, of 4 Backley Gardens, Anthony Road, Woodside, SE25 5HR make oath and say as follows:

1. I was the secretary to Mr Nelson Mendes, the Head of Finance from February 1997 until February 1999.

2. During this period I was in a position to see numerous financial documents of the Manufacturing Science and Finance ("MSF") union.

3 . In 1997 I saw a copy of a cheque from MSF's bankers, the Unity Trust Bank ("UTBI”), made payable to Mr Roger Lyons (the General Secretary of MSF) for over £29,000. The account name was typed in small letters at the bottom of the cheque. This was either "MSF Daxo" or "MSF Guildhall". 1 saw a copy of a second cheque made payable to the Head of Finance, Mr Nelson Mendes, in the sum of £5,000. Again the account name was stated on the cheques as either "MSF Daxo" or "MSF Guildhall". They were UTB cheques,

4. These two accounts mentioned ("MSF Daxo" and "MSF Guildhall") appeared on our financial records known as Pool Statements, in 1997. Every week we received these Pool Statements from UTB. These would show the balance of accounts of each of the branches within the union. It would therefore appear that these accounts are branch bank accounts. However, under Rule 42(r) of the MSF Rules branches have to submit their Annual Financial Returns ("AFR's") to MSF Central Office otherwise money is "sliced" (ie taken) from their accounts. Neither "MSF Daxo" nor "MSF Guildhall" have submitted their AFR's but they have never had their money sliced. I am also aware that neither MSF Daxo nor MSF Guildhall were on the membership system. I do not believe they had any members.

5. These two accounts were referred to as "shell accounts" internally within MSF. The total in each of these two accounts in 1997 amounted to £130,000, 1 believe there are a number of other similar accounts. I am aware that bank accounts can be closed, merged or transferred over and over again in order to "lose" money. I have closed lots of bank accounts and transferred money on instruction from Mr Mendes.

6. I saw the money dwindle in the MSF Daxo and MSF Guildhall accounts in 1997. In particular I saw a deduction of over £29,000 from the "MSF Daxo" or "MSF Guildhall" bank account on the Pool Statement, after Mr Lyons had received his cheque,

7. I have on numerous occasions, throughout the course of my employment in Finance, been told to destroy financial records by Mr Mendes.

8. I can recall the documents relating to Mr. Lyons’ loan from MSF. I was told tear up copies of these documents so there would be no trace. Mr Mendes went to see Mr Lyons and he (Mr Mendes) asked me to type a letter concerning the £4,000 loan made to Mr Lyons by MSF. I typed the letter, which referred to a loan, rather than a "sub" or advance on wages or any other term, I was told by Mr Mendes not to put any documents on the file and was told to tear up any copies. I can remember the wording of the Memorandum in fairly detailed terms. It was from Nelson Mendes to Mehmet Mehmet, copy to Pam George in Payroll, Re: Roger Lyons, strictly private and confidential, could you please transfer by BACS on 10th April 1997 £4,000 as loan towards the above named.

9. I brought the fact that I was aware of the above to the attention of Mr Mendes, in September 1997. He appeared very worried when I told him this. Since that time there has been a breakdown in relations between Mr Mendes and I. Between 30th June 1998 and 27th August 1998 1 was absent due to an accident at work, On my return to work I worked with Mr Colin Adkins and Mr Brian Harris, although I was still officially employed in the Finance Department.

10. I have now been moved from the Finance Department. I have heard that Mr Lyons wants to "get me". This has been very stressful for me but I am confident that I am telling the complete and unadulterated truth. If there were to be a proper investigation by an independent accountant I am sure further matters would be discovered.

11. I have heard rumours within MSF that H. W. Fishers (MSF's Accountants) have been in to check our finances and that Mr Lyons and Mr Mendes have nothing to fear. I know that Fishers have not been into the union to check the finances.

12. In September 1997 I tried to bring these matters to the attention of Mr Mendes who was my line manager. He was dismissive of my concerns and simply stated that I was his confidential secretary. I make this affidavit not with any intention of harming MSF but with the intention of protecting it and bringing to the attention of the those who control the situation relating to the finances.

13. I reserve my right to add to and expand upon this statement at a later date.

Sworn at E. Edwards Son & Noice, 292-294 Plashet Grove, East Ham, London E6 1DQ on 5 March 1999

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