Day 146 - 03 Jul 95 - Page 33


     
     1        pleading there is a paragraph 5 which sets out the
     2        particulars in support of that, if I can call it Lucas-Box,
     3        now having explained it.
     4
     5        So, my Lord, having gone through that letter, that really
     6        deals with the issues that are raised there.  Then the
     7        letter goes on to set out the sort of documentation that we
     8        require, or that we think is the sort of thing that is
     9        likely to be a relevant document.  That arises out of the
    10        fact that your Lordship asked me back in December last year
    11        at the hearing to try and give a list on my feet, as it
    12        were, of the sort of documents that the Defendants should
    13        be looking to see if they had.  Rather embarrassingly,
    14        I petered out mid stream and I then went back and had a bit
    15        more thought about it and was able to----
    16
    17   MR. JUSTICE BELL:  Produced a flood.
    18
    19   MR. ATKINSON:   -- produce this list which, I hope, is long
    20        enough.  In fact, if I might just, in a burst of
    21        enthusiasm, add some further things.  It is quite an
    22        important point -- not meaning to be flippant about it
    23        because it is an important point -- I would like to add
    24        into that list any London Greenpeace or McLibel support
    25        campaign cheque books.  I will tell your Lordship how this
    26        arises in a minute, but cheque books or cheque stubs.
    27
    28   MS. STEEL:  Can you just slow down, please?
    29
    30   MR. ATKINSON:  Any bank statements to do with those two groups,
    31        something called either the bank book or pass book of
    32        London Greenpeace or, if appropriate, the McLibel support
    33        campaign, any invoices or receipts to do with those two
    34        groups and, indeed, any record that go to the issue -- and
    35        this is the issue -- of whether or not the Defendants,
    36        either one or other or both, were, in fact, the signatories
    37        to the London Greenpeace bank account or the signatories to
    38        the McLibel support campaign bank account, or indeed, less
    39        specifically, were responsible for handling the financial
    40        affairs of those two groups.  I will tell your Lordship how
    41        this has arisen as we are on it.
    42
    43        My Lord, I do not know whether -- you ought to have now
    44        some supplementary statements from two of our private ----
    45
    46   MR. JUSTICE BELL:  What is the distinction between all this and
    47        the simple issue of publication on your Statement of Claim?
    48
    49   MR. ATKINSON:  In one sense, the question of involvement in the
    50        campaign has been raised at a very early stage because it 
    51        was dealt with not only in the Statement of Claim, as your 
    52        Lordship says, in paragraph 2 of that pleading, it was also 
    53        dealt with in the further and better particulars of the
    54        Statement of Claim at various paragraphs, and it was also
    55        dealt with in the further and better particulars of the
    56        further and better particulars of the Statement of Claim.
    57
    58   MR. JUSTICE BELL:  But do you say all these matters, if there
    59        were documents under any of these heads which you have
    60        actually related to the defence to counterclaim, then they

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