Day 265 - 19 Jun 96 - Page 29


     
     1   MR. RAMPTON:  Yes.  Do you remember seeing that at London
     2        Greenpeace meetings?
     3        A.  Yes, I do.
     4
     5   Q.   Do you remember whether you yourself ever took one away
     6        from those meetings?
     7        A.  Yes, I would have done, yes.
     8
     9   Q.   Do you remember any other kinds of anti-McDonald's
    10        literature?
    11        A.   Yes, I do.
    12
    13   Q.   What were the other sort that you can remember?
    14        A.   There was a two-sided piece of paper, leaflets. There
    15        were posters.  There were other documents.
    16
    17   Q.   Can I borrow that two-sided paper?  Mr. Riley, I am sorry.
    18        Ignore the writing, Mr. Claire.  (Same handed) Just look at
    19        the general -- do not even bother about the words, just
    20        look at the general get up of it?
    21        A.  Yes.
    22
    23   Q.   Do you recognise that one?
    24        A.   Yes, I do.
    25
    26   Q.   Or something like it.  Do you differentiate clearly in your
    27        memory between the...  What did you call it -- the
    28        multi-sided one?
    29        A.  Well, that was referred to by me and my colleagues as
    30        the multi-sided fact sheet, the leaflet.
    31
    32   Q.   Without reference to names or anything else, does your
    33        memory allow you to distinguish -- does it distinguish --
    34        between those two documents?
    35        A.  Yes, primarily.  I was instructed, or my concerns were
    36        with the fact sheet, with the leaflet, with the multi-sided
    37        leaflets.
    38
    39   Q.   With the fact sheet did you call it?
    40        A.   We referred to it as several things.  I referred to it
    41        as the multi-sided because you could differentiate it
    42        between a one-page document, but it was referred to as the
    43        fact sheet, the multi-sided leaflet.
    44
    45   Q.   That is what I thought you said, fact sheet.  Who referred
    46        to it as a fact sheet?
    47        A.  My principals, myself, I believe the Defendants would
    48        have.
    49
    50   Q.   While we have got this note open, where you have given a 
    51        description of the office have you also got -- can you move 
    52        the blue file slightly to one side so that you can look at 
    53        the statements?   Behind your latest statement, which
    54        should be the one you have already got open you should find
    55        some photographs?
    56        A.   Yes, sir.
    57
    58   Q.   The first document in that section of photographs should be
    59        a typewritten sheet headed 'key to photographs'.  Is it
    60        there; have you got that or not?

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