Day 024 - 15 Sep 94 - Page 63
1 remember it, Mr. Rampton?
2 A. Generally, your Lordship, I believe there was
3 reference to that.
4
5 MR. RAMPTON: I think what we are talking about is page 129 of
6 section 34 of volume VI A. It is merely what looks like a
7 dictaphone or answer phone recital of the letter of 24th
8 April.
9
10 MS. STEEL: No, that is a letter.
11
12 MR. RAMPTON: It says "typed from dictaphone transcription".
13
14 MS. STEEL: That was not a press release; that was a letter.
15
16 MR. JUSTICE BELL: But it may refer to it.
17
18 MS. STEEL: But the note I have is something about a press
19 release being read over the phone.
20
21 MR. JUSTICE BELL: Do you ever remember reading a press release
22 or proposed press release over the telephone to
23 Mr. Horwitz?
24 A. Reading, your Lordship, or what? I did not hear.
25
26 Q. Reading a press release or proposed press release over the
27 phone to Mr. Horwitz.
28 A. I could say, by reconstruction of memory, I did not
29 read any, I would not have read a proposed press release
30 to him. I do not-- the Exhibit 129 purports to be a
31 dictaphone transcription of a telephone conversation with
32 me. I would point to the court that what that is is a
33 faulty, but fairly accurate, transcription of my letter
34 that is in that same binder, two pages later, at page
35 131. It is not a press release; it is just the letter.
36
37 I believe, and this is working on memory that is not
38 perfect, but I believe that when we sent this letter to
39 McDonald's on April 24th 1987, again because at that time
40 I do not think we had fax technology in our offices -----
41
42 MR. JUSTICE BELL: I do not actually think -- I may be wrong --
43 that is on the point Ms. Steel is ----
44
45 MS. STEEL: No. It is because I cannot find the reference.
46
47 THE WITNESS: If I may, your Lordship, in our jurisprudence --
48 I do not know that that applies here -- it is said that if
49 you ask a lawyer what time is, he will tell you how to
50 build a watch. I am almost concluded with telling the
51 court how to build a watch.
52
53 MR. JUSTICE BELL: The question is simply the one -- you said
54 you do not recall ever reading a proposed press release to
55 Mr. Horwitz. Do you recall ever reading a press release
56 which had actually been issued to him?
57 A. I was, in fact, to give the court the context, it is
58 possible -- I do not recall it, your Lordship, at all --
59 it is not impossible that on 24th April that we contacted
60 them and extended to them the same courtesy they had
