Day 265 - 19 Jun 96 - Page 23


     
     1        extent, now in June 1996, are you able to rely on your
     2        memory for the detail of the events which took place and
     3        you attended at London Greenpeace and to what extent are
     4        you reliant on your notes?
     5        A.   I am primarily reliant on my notes after such a time.
     6
     7   Q.   What was your habit in relation to when you made your notes
     8        after attending or, perhaps, at these meetings; I do not
     9        know, when you made your notes for each of these meetings?
    10        A.   Following, leaving, the meetings I would walk to my
    11        car, which was parked in the nearby streets, and on
    12        occasion make the notes there in the vehicle or, having
    13        driven away a couple of miles, would have made the notes in
    14        the car at another location.
    15
    16   Q.   They are all in your manuscript?
    17        A.   That is correct, yes.
    18
    19   Q.   What would you do with the manuscript?
    20        A.   The notes, were made in the--
    21
    22   Q.   They are in a book?
    23        A.  They are in a book, yes.  It is a black, hardback
    24        book.  The notes were made and the book was located at my
    25        office and was taken with me on such occasions.
    26
    27   Q.   Though, Mr. Claire, we all make mistakes because we are all
    28        human, do you have any reason to think that the notes which
    29        you made the same evening as the meetings took place, do
    30        you have any reason to think that any of those notes are
    31        substantially inaccurate as a record of the meeting?
    32        A.   No, I do not.
    33
    34   Q.   Can I ask you a general question about your memory of that
    35        time, that 6 months period or so?  Do you have a general
    36        recollection of what the proceedings within the group were
    37        like?
    38        A.   Yes, I do.
    39
    40   Q.   Do you have a recollection of the people, two people
    41        sitting on the other side of the Court from me?
    42        A.   Yes, I do.
    43
    44   Q.   When you were first instructed, I cannot remember now, but
    45        you tell us.  Do you recall whether you were shown any
    46        photographs before you joined the group?
    47        A.   I think I was, yes.
    48
    49   Q.   Can I ask you to have a look at another volume?  Leave that
    50        one, do not bother moving it.  Get a pink one with a Roman 
    51        II on it, please? 
    52        A.   Number two. 
    53
    54   Q.   Yes.  It should have 211.  It should be called
    55        'publication'?
    56        A.   That is correct (Same handed).
    57
    58   Q.   I will ask you to turn to tab 5A, please.  There are at tab
    59        5A three different sets of photographs.  They are marked
    60        set A, set B and set C at the top.  Can I just ask you to

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