Day 306 - 26 Nov 96 - Page 51
1 say, and I have -----
2
3 MS. STEEL: I just wanted to make a couple of quick points,
4 really.
5
6 MR. JUSTICE BELL: Do that. But I have given you the facility.
7 You have clearly got a lot of notes, whether word processed
8 or in your own handwriting, and you do have the opportunity
9 to word process them out, or any parts of them you want to
10 word process out, making any additional points and
11 references by the deadline I have given you. So, make the
12 one or two extra points you want to make, and then we will
13 call it a day.
14
15 MS. STEEL: Just briefly, that, obviously, her evidence was
16 that she never saw the fact sheet in all the time that she
17 was attending meetings of London Greenpeace, and it was the
18 case that she did not consider that McDonald's was very
19 high on the agenda; it was not discussed much. I am just
20 doing this from memory.
21
22 Also -- I am not sure what Mr. Rampton is going to say
23 about this, but when he cross-examined her he asked her
24 some question about would her notes be more accurate, or
25 something, than her memory now. I think the point to be
26 borne in mind when you are considering her evidence is that
27 her evidence did not contradict her notes; her evidence
28 explained what some of the notes said -- for example, where
29 she had referred to people chairing meetings, or whatever,
30 she explained what she had meant by that, that there was
31 not a formal chair but that, for want of a better word or
32 something and because of the fact that she was used to
33 being in more formal situations, the terminology she used
34 she then adopted for London Greenpeace meetings, even
35 though it was not necessarily appropriate. So, just really
36 to bear that in mind, if Mr. Rampton tries to make that
37 point, that none of the evidence she gave in the witness
38 box was trying to go back on the notes, or anything like
39 that; it was explaining what they meant.
40
41 The final point, which I think is actually quite important
42 to make -- this is actually Mr. Russell -- is that if you
43 look behind his statement at the exhibits, the fact sheet,
44 the London Greenpeace anti-McDonald's fact sheet which
45 appears behind his statement has, again, the date on it of
46 31st May, but if you look at all the other exhibits that
47 are attached to Mr. Russell's statement you will see that
48 they have written on them "collected 26th April 1990".
49 That is in JR/2. That is on the Greenpeace London leaflet,
50 that is on the anti-McDonald's fair 1989 programme, that is
51 on the anti-McDonald's fair -- I presume that is 1988
52 programme; it says "handed out on 26.4.1990". Presumably,
53 there were some old programmes knocking around or
54 something.
55
56 So, I just think it is particularly significant that all
57 those documents have noted on them that they were obtained
58 on that date, whereas the fact sheet does not; and that
59 gives added weight to our argument that, in fact, the fact
60 sheet was not available on that date and there is not
