Day 262 - 13 Jun 96 - Page 35
1 A. I do not remember.
2
3 Q. You do not remember. Would you have remembered this time
4 last year which leaflet it was?
5 A. I do not know what I knew this time last year.
6
7 Q. You see, in your statement, you say that it is the leaflet
8 complained of; but, basically, all your notes say is the
9 "what's wrong with McDonald's?" So it may be that
10 somebody from the solicitors' office assumed that meant
11 that it was the leaflet complained of?
12 A. I have read through all the statements and signed them,
13 and read through them fairly carefully.
14
15 Q. So does that mean within the last year you have forgotten?
16 A. Well, I suppose it does, if that is what -- I do not
17 remember now.
18
19 Q. Is it not just possible that you signed the statement and
20 assumed that the solicitors had got it right?
21 A. No. I read through the statements quite carefully.
22
23 Q. Did you compare them with your notes at the time?
24 A. I did compare. When I was making statements, I had
25 access to notes and to previous statements.
26
27 Q. When you were checking that statement, would you have had
28 this beside you to check it against?
29 A. I do not remember what was beside me when I went
30 through the statement.
31
32 Q. Would you accept that maybe that is a mistake in the
33 statement, and that because it says 10,000 copies of the
34 "What's wrong with McDonald's?" leaflet, you have assumed
35 that that was the leaflet complained of?
36 A. Well, to the best of my knowledge, the information in
37 the statement is true.
38
39 Q. But you could have made a mistake?
40 A. It is possible I could have made a mistake. But, to
41 the best of my knowledge, it is true.
42
43 Q. Actually, in fact, when you averred your statement, you
44 were not in a position to aver it in terms of you could say
45 that now?
46 A. Now and when I made the statement are two different
47 times.
48
49 Q. Yes, but you would not be in a position -- if, for example,
50 you had been giving your evidence verbally, rather than
51 saying, "I made this statement", whatever, "I stand by it"?
52 A. I will stand by the statement that I have read through
53 carefully and signed.
54
55 Q. But you would not be able to remember that now, or you have
56 said you would not?
57 A. No.
58
59 Q. Did you ever see the leaflets arrive?
60 A. I do not ever recall seeing them actually arrive.
