Day 250 - 15 May 96 - Page 50


     
     1
     2   Q.   -- was to prove the case against myself and Mr. Morris?
     3        A.  No, I could not do that.
     4
     5   Q.   Or as part of trying to prove the case against -----
     6        A.  Yes, part of it, yes.  It was to show the continuity
     7        from the time that we put in the teams and then their
     8        evidence.
     9
    10   Q.   And the evidence of what happened on the picket on 16th
    11        October, 1989, which you pleaded as the date of
    12        distribution?
    13        A.  Yes, yes.
    14
    15   Q.   And that is what paragraphs 8 to 11 were intended to deal
    16        with?
    17        A.  Yes.
    18
    19   Q.   This was based on what you told Mrs. Brinley-Codd?
    20        A.  Yes.
    21
    22   Q.   Immediately after the demonstration, or within a few days
    23        of the demonstration, was it, or was it based on something
    24        else?
    25        A.  No.  I mean, I first saw Mrs. Brinley-Codd the
    26        following day when I handed her the leaflet and I told her
    27        briefly what had happened.  I do not think at that time we
    28        were contemplating legal action.  There was certainly a
    29        possibility of it, depending upon your reaction, your
    30        group's reaction to the service of writ if it got that
    31        far.  The interview in 1990 was certainly to start
    32        establishing the case.
    33
    34   Q.   I am not sure I understood that.  You do not think you were
    35        contemplating legal action at the time of 1989?
    36        A.  No, I said it was a possibility, but it was not the
    37        objective.
    38
    39   Q.   There was a possibility depending on our reaction to
    40        serving writ?
    41        A.  Yes, if it got that far.
    42
    43   MR. JUSTICE BELL:  I wonder if there is a bit of confusion
    44        here.  I suppose the moment you issue a writ it could be
    45        said you started proceedings, and certainly once it is
    46        served; but what do you mean by starting proceedings?
    47        A.  Well, I suppose that is the start of proceedings.  I
    48        mean, you have started the legal process then.
    49
    50   Q.   Yes. 
    51        A.  But what I mean is that when we were preparing the case 
    52        for court, that was -- that started in 1990. 
    53
    54   MS. STEEL:   Sorry, can you just clarify what this statement was
    55        based on when you spoke to Mrs. Brinley-Codd the day after
    56        the protest or two days after the protest or when you spoke
    57        to her in 1990 or when you spoke to her in 1993?
    58        A.  This statement was based on the -- when she took proof
    59        of evidence in 1990.
    60

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