Day 258 - 07 Jun 96 - Page 54


     
     1        would do a report to Paul Preston, copy me.  I mean, it is
     2        courtesy, of course, because he is the President of the
     3        Company and it comes to me because I was, at that time, his
     4        departmental head.
     5
     6   Q.   Why would it go to Mrs. Brinley-Codd?
     7        A.  Because everything to do with demonstrations at Head
     8        Office we will send over to our solicitors and they would
     9        advise us whether or not there was any further action to
    10        take.
    11
    12   Q.   So, if there had been pickets at Head Office on previous
    13        occasions there would have been reports of those as well?
    14        A.  No, not necessarily, because the one in '87 was, in my
    15        opinion -- I was there -- it was a damp squib, it was not
    16        worth reporting.  He would certainly have done one in '88.
    17        I feel confident he would have done one in '88.
    18
    19   Q.   Did you ask Mr. Carroll where he says about, "I obtained
    20        photographs of all the demonstrators and I will have them
    21        identified in due course".  Did you ask him about where he
    22        was going to get them identified?
    23        A.  No.
    24
    25   Q.   Because it would have saved you a lot of time, would it
    26        not?  You would not have had to bother with all these
    27        inquiry agents?
    28        A.  No.  To be perfectly honest, I had already set out the
    29        inquiry agents.  I just let that pass by.
    30
    31   Q.   You did not take any notice of it at all?
    32        A.  Very little.  That was just an interdepartmental report
    33        which contained nothing that I did not already know.
    34
    35   Q.   You said that whenever there was a picket at Head Office
    36        there would be a report done and you would send it to the
    37        solicitors in case there was any action to be taken?
    38        A.  Yes.
    39
    40   Q.   If it is just a peaceful demonstration, there is no one
    41        hurling bricks, or whatever, there is not going to be any
    42        action to take, is there?
    43        A.  No, it is a formal letter almost, is it not?
    44
    45   Q.   Unless you have already decided that you are going to bring
    46        proceedings?
    47        A.  I had, but Terry Carroll did not know.
    48
    49   MR. JUSTICE BELL:  Do you mean unless you had already decided to
    50        bring proceedings, was the phrase Ms. Steel used.  I know 
    51        you said you decided to investigate further? 
    52        A.  Yes, I beg your pardon, my Lord; that is right, 
    53
    54   Q.   Is that what you meant?
    55        A.  What I meant was I had already decided I was going to
    56        carry out an investigation.
    57
    58   MS. STEEL:  You had already decided that you were going to bring
    59        proceedings, had you not?
    60        A.  That was a distinct possibility.  I was hoping that

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