Document is Donald Paterson's affidavit.

"On the 30th day of June 1934 at the request of the defendant Lady Russell I visited her school at Beacon Hill Petersfield in the county of Hampshire to inspect the health of the children there and the general condition of the school." Patterson paints a very nice picture of Beacon Hill School.

"Among the many children I examined were John Russell aged twelve years and the plaintiff [Kate Russell] aged ten years. They were both splendid specimens, obviously very well cared for and in my opinion quite fit."

Donald states that he is a physician to out-patients at the Hospital for Sick Children, and a physician for children's diseases at Westminster Hospital, and during his visit at Beacon Hill he saw no indications that the children were being poorly treated.