Day 262 - 13 Jun 96 - Page 14


     
     1        wanting more information being put on one side for
     2        Paul Gravett.  Do you recollect that there was a specific
     3        drawer for McDonald's letters?
     4        A.  No, I do not recollect that.
     5
     6   Q.   If we find Mr. Clare's photographs that you were looking at
     7        the other day -- I think they are behind Mr. Clare's
     8        statement, which is in tab 5, probably 5C -- if you turn to
     9        the seventh photograph, yes?
    10        A.  Yes.
    11
    12   Q.   Have you got that?  There is a set of wooden drawers on the
    13        left of the extremely untidy desk.  There are four drawers
    14        there.  Do you see that, yes?
    15        A.  Is the top one a drawer?
    16
    17   Q.   The top one is not a draw.
    18        A.  Then there are four.
    19
    20   Q.   If I put to you that the top drawer, which has "1" on it,
    21        was for urgent letters, the second drawer was McDonald's
    22        letters, the third drawer was not so urgent, any general
    23        inquiries about various other campaigns or about the group
    24        in general, and the fourth drawer, the bottom one which has
    25        not got a number on it, was letters that had been answered,
    26        would you disagree with that, would you accept that?
    27        A.  I do not remember.
    28
    29   MS. STEEL:  You do not remember.  OK.
    30
    31   MR. MORRIS:  If we had the originals of these photographs, we
    32        might be able to see if we can read the writing.
    33
    34   MR. JUSTICE BELL:  Well, you have to get this in proportion.
    35        You have actually put that to the witness.  He cannot
    36        remember.  I suppose that if someone comes along, you ask
    37        one of your witnesses that or, if you give evidence, you
    38        say so yourself, Mr. Rampton could say, "That is not in the
    39        statement, I have had no notice of it"; but, in effect, you
    40        have given notice by asking the question.  So I do not
    41        suppose there will be any objection.  So, these matters
    42        which you have actually raised with the witness have got
    43        something shorter (inaudible), if they are important, you
    44        probably pick up later.  I am not asking you to pick them
    45        all up, because you have to decide what is important and
    46        what is not.
    47
    48   MS. STEEL:   Right, OK.
    49
    50   MR. JUSTICE BELL:  Provided you have put it clearly and got an 
    51        "I do not know" or "I cannot remember now" answer, that is 
    52        probably sufficient to lay your ground for later. 
    53
    54   MS. STEEL:   OK.  (To the witness)  so, the letters that you put
    55        on one side for Paul Gravett, you do not actually remember
    56        where they got put?
    57        A.  They may have been put in a drawer.  I may have put
    58        them in a drawer.  I really do not recall.  It was just
    59        that they were put to one side, figuratively speaking.
    60

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