Day 255 - 23 May 96 - Page 37


     
     1        against individuals, and that action had been taken.  Three
     2        of the individuals had accepted that they were in the wrong
     3        and had apologised in court, and that yourself and
     4        Mr. Morris had decided to fight the case.
     5
     6   Q.   Right.
     7        A.  I do not think I told them much more than that.
     8
     9   Q.   Did you tell them about the letter that was written in
    10        1984?
    11        A.  Yes.  Indeed I almost certainly was responsible for
    12        telling them that we had written to you in 1984 and that,
    13        as I thought then, and indeed still do think, and have said
    14        so, we wrote to you again in or around about 1987, that
    15        there had been no response, that I did not anticipate
    16        getting any response, and I think virtually that was it.
    17
    18   Q.   So it was not you who told them that you had written to the
    19        group several times?  You did not tell them that?
    20        A.  I think I said that we had written twice more.  That
    21        was then my belief but I agree, I cannot establish that
    22        now..
    23
    24   MR. JUSTICE BELL:  Do not be concerned about that.  At the
    25        moment it is just what you told them?
    26        A.  I think I told them that we had written twice more, and
    27        that was ----
    28
    29   MS. STEEL:   Sorry?
    30        A.  That was my belief at that time and indeed I still am
    31        sure that we had written to you again.
    32
    33   Q.   Right, and that was then translated by them into several
    34        times, was it?  It was not you who said that you had
    35        written several times twice?
    36        A.  Well, I suppose they could interpret, as media people,
    37        that "3 times" is "several".
    38
    39   Q.   If you just look at it.  For example, if you look in tab 3,
    40        the fourth paragraph:
    41
    42        "In December 1984, McDonald's solicitors wrote to the group
    43        expressing concern about the leaflet, stating that it was
    44        defamatory, and requesting that the organisation
    45        disassociated themselves from the leaflet and its
    46        contents.  Despite several subsequent letters" -- and that
    47        is subsequent -- "no acknowledgment or reply was ever
    48        received and persistent distribution of the leaflet
    49        continued".
    50 
    51        Did you say to the people there at this meeting that the 
    52        solicitors had written once in 1984 and then several 
    53        subsequent letters?
    54        A.  No "twice".  I am quite clear in my mind about that.
    55
    56   Q.   Twice, one of which would have been the letters to us with
    57        the writs that came at the same time?
    58        A.  No.  I thought we had written twice to you asking you
    59        to desist.
    60

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