Day 261 - 12 Jun 96 - Page 75


     
     1        campaigns they were.
     2
     3   Q.   But in terms of quantities of leaflets inside boxes, you
     4        would not know about, you know, how many there were of
     5        particular leaflets?
     6        A.  I could not give exact numbers, no.
     7
     8   MR. MORRIS:  Can you say now, from your memory now, at this
     9        time, this period of time, November 1989, which specific
    10        leaflets relating to McDonald's were available in the
    11        office?  I do not mean leaflets that someone might have
    12        given you.
    13        A.  On that occasion, on the 2nd -----
    14
    15   Q.   In November 1989.
    16        A.  I cannot remember exactly from -- at this moment, my
    17        memory now; no, I do not recollect exactly what was
    18        available and what was not available
    19
    20   Q.   Right.  You said that actually in evidence-in-chief.  There
    21        were various varieties of McDonald's leaflets available.
    22        So, you are standing by what you said in that -- when
    23        Mr. Rampton asked you that there were various varieties of
    24        McDonald's leaflets available at one time or another?
    25
    26   MR. JUSTICE BELL:  You do not have to repeat it unless you
    27        disagree with it.
    28
    29   MR. MORRIS:  All right.
    30
    31   MS. STEEL:   Just about the filing cabinets, would you accept in
    32        actual fact that what the filing cabinets contained was old
    33        letters, old leaflets and, you know, they were kind of
    34        reference material?
    35        A.  I never made a close examination of the contents of the
    36        filing cabinets.  From memory, it is certainly possible
    37        that is what they contained.
    38
    39   Q.   OK.  In your statement in paragraph 10 talking -- actually,
    40        sorry, forget that because it is not actually the next
    41        meeting to go to.  Shall I carry on?
    42
    43   MR. JUSTICE BELL:  What I would like you to do, unless it is
    44        going to take a very long time, I would like you to finish
    45        what you want to ask about the 2nd November and then we
    46        will break off until tomorrow.
    47
    48   MS. STEEL:   Yes, that is actually it.
    49
    50   MR. RAMPTON:  My Lord, can I say something?  I find myself in 
    51        the same position in relation to the boxes of the words 
    52        complained of on the shelves in the offices as I did in 
    53        relation to the table at the stall that London Greenpeace
    54        had on the 21st October of that year.  I am quite unclear
    55        whether the Defendants accepted they were there or that
    56        they are not sure, or whether they say they were not.  One
    57        has seen the photograph.  I have no idea what the relevance
    58        is to that.  Maybe they will tell us that when Mr. Clare
    59        gives evidence, but at the moment there seems to have been
    60        again -----

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