Day 306 - 26 Nov 96 - Page 20


     
     1        Here we have a witness, whose job it is to record, as he
     2        said, anything of relevance said by myself and Ms. Steel,
     3        to check our involvement in the campaign or not, lack of,
     4        not noting something of absolute central relevance which
     5        would have shown that I could not have been involved in the
     6        group or in the campaign for a considerable amount of
     7        time.  He was saying that not only did he not record it,
     8        but it was not relevant, which completely throws doubt on
     9        his credibility as an observer and as a recorder.  Do not
    10        forget that we are relying on recorded -- not
    11        observations -- in this case, we are relying on the
    12        recorded evidence, because witnesses cannot remember
    13        anything other than what they have recorded.
    14
    15        So, in fact, the only conclusion must be that he did not
    16        put it down because it would undermine his attempt to paint
    17        myself as whatever he said at that meeting, being this
    18        great, solid activist who was involved with the campaign
    19        and the group, and all this kind of stuff -- which of
    20        course is completely made up, because I had not even been
    21        to a meeting for five months, apart from one general
    22        discussion.  So that should be considered as significant,
    23        when we say that he fabricated -----
    24
    25   MR. JUSTICE BELL:   You have made your point.
    26
    27   MR. MORRIS:   All I am saying is, it is of equal importance to
    28        understanding -- it should be taken as an equal balance of:
    29        why did he put X, Y, Z in, when we say it did not happen;
    30        and we say that should be contrasted with: why did he leave
    31        that out, when it clearly did happen and their own other
    32        agent recorded it?
    33
    34        Then, on page 61, line 42, about me helping to organise the
    35        1989 anti-McDonald's fair and the leaflets campaign.
    36
    37        "Do you know if I said that or somebody else said that?"
    38
    39        Answer: "It would have been said or implied or it would
    40        have been something that I would have gleaned from that
    41        meeting, but I do not recall if others said it or if you
    42        had said it."
    43
    44        So, it is not something which he could say that I had
    45        said.
    46
    47        He says, on the top of page 62:  "It may have been what you
    48        said or somebody else said, or general conversation."
    49
    50        "You cannot remember now?" 
    51 
    52        "No." 
    53
    54        I asked him, at line 45, page 62: "I would never have said
    55        I helped produce the leaflets for the anti-McDonald's
    56        campaign?"
    57
    58        Answer: "If you said it, I do not recall.  It would have
    59        been said or I would have had the impression from those
    60        present of what I have made in my notes."

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