Day 250 - 15 May 96 - Page 57


     
     1        particular leaflet, I would like you to put it to the
     2        witness so that I know that that is the case.
     3
     4   MS. STEEL:   To me it looks like the A5 version of the -- well,
     5        actually there were versions by London Greenpeace and by
     6        Hackney and Islington Animal Rights and by any number of
     7        different organisations, but it looks like an A5 "What's
     8        Wrong with McDonald's" leaflet, some of which do -----
     9
    10   MR. JUSTICE BELL:  I am sorry, I think there is a
    11        misunderstanding.  We can all look at the photographs and
    12        draw conclusions about those which may be a positive
    13        conclusion or merely that one cannot draw any conclusion
    14        safely at all.
    15
    16        What I am putting to you is that it is common ground that
    17        you were at the demonstration on the 16th October, 1989,
    18        and if you are going to go into the witness box in due
    19        course and say, "This leaflet was not handed out but this,
    20        that or the other leaflet was", I would like you to put
    21        that to the witness and suggest that leaflet is this one or
    22        this one or this one.  It is no sacrifice to do that.  It
    23        just helps the judge follow the detailed issues as well as
    24        the broad ones.
    25
    26   MS. STEEL:  The problem is that on these pickets it is standard
    27        practice for people, basically, to bring along any leaflets
    28        which they want to hand out.  So I cannot specifically say
    29        whether that woman is holding the London Greenpeace A5
    30        leaflet, the Veggies A5 leaflet, the Hackney and Islington
    31        A5 leaflet, or one she has written herself.  All I know is
    32        that it is certainly not the fact sheet which is complained
    33        of in this action.  That is the difficulty.  I am not
    34        trying to avoid putting the case.  But my recollection is
    35        that I personally did not hand out any leaflets on that
    36        day.
    37
    38        As to what other people were handing out, I am aware that
    39        London Greenpeace generally -- well, all the discussions
    40        that I ever heard concerning what leaflets would be handed
    41        out on the streets were that it would be the A5 version,
    42        not the fact sheet, and that is what appears to be handed
    43        out on that day.  That is my position.  It is very
    44        difficult for me to put that to the witness as a question.
    45
    46   MR. JUSTICE BELL:  That is helpful.  Is it your case that you
    47        did not, for instance, pick up any leaflets and hand them
    48        to another woman, as Mr. Nicholson has suggested, because
    49        I think if -----
    50 
    51   MS. STEEL:   At this distance in time I just honestly cannot 
    52        remember but, you know, the first time Mr. Nicholson 
    53        mentioned it was three weeks ago.  So, I have had no cause
    54        to sort of think back.  All I can remember doing at the
    55        picket was holding the banner and taking a lot of
    56        photographs.
    57
    58   MR. JUSTICE BELL:  Just pause a minute.  What I made as the
    59        note, because subject to anything Mr. Rampton wants to say,
    60        if I have got this clear -- I think you have made it

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