Day 263 - 14 Jun 96 - Page 12
1 that the Hooker reports were apparently sent directly to
2 Sid Nicholson after a certain point. So that becomes
3 relevant. That is what Mr. Rampton said yesterday.
4
5 MS. STEEL: Mr. Morris has actually dealt with most of what
6 I was going to say, so I am just going to finish off some
7 bits and pieces which I do not think he did cover or
8 I might want to say something slightly different. But
9 I adopt all his argument.
10
11 In this case, the Plaintiffs seem to be relying on -- they
12 have relied on agency and, as part of that, they are
13 relying on our involvement with the group and the nature of
14 the group. So, in order for the court to get a true
15 picture of the nature of the group and of the extent of our
16 involvement, the court needs to be able to see all the
17 material that was taken at the time, in terms of notes of
18 meetings and reports of meetings.
19
20 By the Plaintiffs' own admission, they selected the parts
21 which show us at meetings or show references to McDonald's
22 and which must, therefore, give an imbalanced picture of
23 the extent of our involvement and the extent of the
24 anti-McDonald's campaign, because we do not know the dates
25 of the other meetings when the inquiry agents attended.
26 There may be hundreds of them; there may be five, there may
27 be 10, there may be 15, there may be 100; we do not know.
28
29 The picture that has been painted so far is that it seems
30 to be something that is coming up at almost every meeting
31 and that -----
32
33 MR. JUSTICE BELL: I know that there were regular
34 Caledonian Road and Endsleigh Street meetings, do I not?
35
36 MS. STEEL: Yes. I mean, we know that there was a meeting
37 every week. If the Plaintiffs want to concede that every
38 single other meeting we were not there and McDonald's was
39 not discussed either -----
40
41 MR. JUSTICE BELL: That is a natural result of the stand they
42 have taken.
43
44 MS. STEEL: I was not clear that they had taken that stand,
45 because I thought they were going to infer that -----
46
47 MR. JUSTICE BELL: Taking that stand may be too positive, but it
48 is clear that the agents who are being called, or some of
49 them, attended at least one other meeting than appear in
50 their statements.
51
52 MR. RAMPTON: It is, if I may say so -- I do not want to
53 interrupt Ms. Steel -- perfectly obvious that I can only
54 rely for participation, or whatever it may be, or to
55 counteract a suggestion of encouraging an anti-McDonald's
56 campaign, on the evidence I adduce. If the Defendants
57 deposed, or their witnesses, that this is only a tiny
58 proportion of the meetings of the group or that the
59 activities of the group were mainly concerned with other
60 things, I am not in a position to contradict it.
