Moran Affidavit 13 November 2018

Let me remind you what truth is…it is an account of what has actually happened with as little filter and editorialising as possible, and it is fact that this was sent to me today by Lavelle Solicitors and I feel sure will also arrive by registered post in the next couple of days. I have blanked out the private address as a courtesy but tried to leave the pdf otherwise unaltered in any way.

Moran Affidavit 13 November 2018

Moran Originating Motion 13 November 2018

Overview of Irish Defamation Law

Sworn Testimony February 2014

I have an application in for legal aid and will be in the Dublin Circuit Court on the due date to request an adjournment while that is processed. It would seem that I may have more than one defence available to me but I would rather reserve judgement until after I have spoken to a solicitor.

I do not have a choice…I could not live with denying the truth even with a gun to my head.

In the name of honesty, I must state that among these papers is conclusive proof that Rachel Moran studied for a degree in DCU. (Had such proof been provided earlier I would have instantly accept that and ceased to doubt it.) I was going to reproduce the stats but the format makes it impossible for me to do so without revealing information that is irrelevant and private so I would ask you to accept my word that Rachel Moran studied at DCU with a journalism major and my occasionally expressed impression that she had not was mistaken.

Gaye Dalton

20 November 2018