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of 84, Charlotte Street, London, W.1.
STATES AS FOLLOWS:
[circa October 1932]
I am an Artist and Authoress.
I have in fact only written one book which has been published and which is he book in question in this action, namely "Laughing Torso".
I have written another book which has not yet been published, which is a continuation of "Laughing Torso", and which has been delayed pending the result of this action.
I have been an artist since I was 16, and I have held five Exhibitions of my paintings in England, and two in Paris.
That I anticipated doing a great deal of work as an authoress, but these proceedings have in fact stopped me from continuing this work.
The book was written in 1931, and practically the whole of the matters relating to the Plaintiff were supplied to me by the plaintiff himself. I have known the Plaintiff since 1912.
Crowley is an adventurer, and has participated in many exploits, particularly as a mountain climber. He has climbed many high mountains and is believed to be well known at the Alpine Club.
During the time I have known him I have met him on numerous occasions and I have often spoke to him about his exploits.
That everything in my book was written from recollection.
At the time that the book was written I believe that the Plaintiff was in Germany.
That the particular story relating to the celebrated Artist's model was told to me by the plaintiff himself in Paris, in the year 1921 or 1922. At the same time he also told me about a temple he had at Cefalu in Sicily, and he described the various incidents which took place there, and which are more particularly set out in my book. His idea, so far as I can understand, was to produce magical effects at the Temple, and to get people interested to go and stay there. That in fact one person of whom I have knowledge, has been to the Temple, namely miss Betty May, and she can describe most of the incidents which took place there, and she wrote a book called "Tiger Woman", in which she described some of the things that took place at the Temple. As a matter of fact her husband died there.
That from June 8th to June 26th I held an exhibition of my watercolour drawings, including the original drawings for my book "Laughing Torso", at the Zwemmer Gallaries, 26 Litchfield Street, Charing Cross Road, and the Plaintiff arrived at the Exhibition on or about the 25th June. He saw and read one of the copies of my book, of which there were several copies scattered about on the table at the Exhibition.
That at the back of the book there was an Index stating the name of the persons who were referred to in the book. By glancing at the Index a person could easily obtain the number of the page or pages in which such reference had been made, and thereby see the contents.
That I produce a book containing the signatures of the various well-known people that attended at my Exhibition, and in this book appears the signature of the Plaintiff.
That on the following night I saw the Plaintiff in the Fitzroy Tavern, where there were quite a number of London artists. The Plaintiff said that the story relating to the celebrated artist's model was quite all right but that it was not the woman to whom he referred. He treated the matter as a joke and was rather pleased about it.
That I made a note in my Diary as to this interview.
As a matter of fact the Plaintiff seemed pleased about the references to himself. The Plaintiff was then living in a restaurant in Charlotte Street, and I used to see him practically every day with a Mrs. Busch [Bertha Busch], a woman with whom he was living, until these proceedings were commenced.
That Miss Clemence Hassell is a friend of mine, whom I introduced to the plaintiff. I understand from her that he borrowed from her a copy of my book, and annoyed her very much by writing all over it and making various notes.
That it is absurd to suggest that the 8th September is the first occasion on which the Plaintiff saw the book, "Laughing Torso". As I have already stated, it was available for him to see it at the Exhibition, and, as a matter of fact, one of the objects of this Exhibition was to introduce this new publication, and since the Exhibition up to the 8th September I had discussed the matters referring to Plaintiff in the book, with the Plaintiff on numerous occasions, and at no time did he make any complaint to me with regard to its contents.
On or about the 14th September 1932 the Plaintiff invited me to come with him and Mrs Busch to the Café Royal, and I attended with them there, where we had supper and a glass of wine etc. I left them about midnight. On the following afternoon I received a telephonic message from Messrs Constable & Co Ltd, the publishers, to the effect that they had received a Writ of Summons in this action. Naturally I was amazed and I went to see them about it, and on the following day I was served with a copy of the writ.
Up to that time the Plaintiff had made no suggestion whatsoever that he had any complaint to make in connection with the matters relating to himself in my book.
That on several occasions since the Plaintiff had been at the Fitzroy Tavern, and he has tried to get into conversation with me, but I refused to have anything to do with him.
That I have also received messages from time to time, purporting to come from the Plaintiff to the effect that I ought to go to get rid of my solicitors as they would only do me down, and further that if I would only be friendly there would be money for both of us.
That the Plaintiff to my knowledge is a man who pretends to practice magic, and he lives by obtaining money mostly from women by undesirable means.
As long as I have known the plaintiff he has been quite immoral, and is always living with one woman or another.
In the letter dated the 10th November 1931 which he sent to me he wanted me to obtain a contract from the publisher to enable him to publish his life story, and the subject matter of the story was to have been his various love affairs in Berlin. His conversation with me has always been lewd, indecent and immoral.
That on occasions I have been to the Eiffel Tower restaurant where Plaintiff and his wife, who is now insane, were staying.
That when I met him in Paris I saw him at the Hotel de Blois, Rue Vaime, Montparnesse.
At his flat he had immoral paintings and pictures, and I observed on one occasion that he had a very obscene plaster casting.
Some of the pictures in his room were the enlargement of sexual organs, and were utterly disgusting.
That accounts of Plaintiff's immoral and blasphemous career have been [remainder is missing]
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