Day 277 - 10 Jul 96 - Page 35


     
     1        anti-McDonald's literature".  Answer "No"?
     2        A.  That is right.
     3
     4   Q.   Simply because it was not a whole filing cabinet?
     5        A.  Well, it was not a whole filing cabinet, it was one
     6        drawer.  Not only that, it was not just devoted to
     7        anti-McDonald's literature, there was various of McDonald's
     8        own literature in there.  It was just a general reference
     9        drawer for McDonald's stuff.
    10
    11   Q.   Can you turn then, please, to interrogatory 19?
    12        A.  Yes.
    13
    14   Q.  "Did not London Greenpeace in 1989 and/or 1990 receive
    15        correspondence at its said offices from members of the
    16        public from England and abroad relating to its
    17        anti-McDonald's campaign."  Answer by you, "I think so"?
    18        A.  Yes.
    19
    20   Q.   Well, that is not an honest answer is it?
    21        A.  It was at the time I answered the interrogatories.  I
    22        did recollect that letters had come in about the
    23        anti-McDonald's campaign, or about other people's
    24        anti-McDonald's activities.  I could not remember
    25        specifically whether or not that was 1989, 1990, so that
    26        was why I put "I think so".  Having read all the private
    27        investigators notes, where they refer to all the various
    28        letters being read out it is quite obvious that it was
    29        1989/1990.
    30
    31   Q.   Your memory of 1993 must have been much better than it is
    32        now?
    33        A.  Well, my memory in 1993 had not been prompted by all
    34        the references to various letters that appear in the spy's
    35        notes and in the letters which were disclosed when we asked
    36        for all the letters that the spies had stolen to be
    37        disclosed to us.
    38
    39   Q.   But you were at literally dozens of these meetings in 1989
    40        and 1990.  I don't know how many in 1989 in total, but I
    41        mean we must be talking about 60 or 70 meetings from the
    42        beginning of 1989 through to September 1990, and you say
    43        you could not, in March 1993, honestly answer "Yes, of
    44        course these letters were answered"?
    45        A.  I have put "I think so".  And I would point out that I
    46        had been, as we have been through, I had been involved in
    47        the group since 1988 and I do not stop being involved in
    48        the group in 1990.  I can't specifically remember which
    49        year letters were received, and I thought that they
    50        probably had been received.  So that is why I put "I think
    51        so" in those years.
    52
    53   Q.   Can I ask you to look at your answers to interrogatories 5
    54        and 7, please?  5 says: "Did you not in 1989 and/or 1990
    55        take part in and/or become involved in and/or participate
    56        in the said campaign" -- that is the McDonald's campaign.
    57        And you put "sometimes"?
    58        A.  Yes.
    59
    60   Q.   Is that an honest answer?

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