Day 249 - 14 May 96 - Page 69


     
     1        the witness statement of someone else, because you propose
     2        or hope to adduce evidence of it in due course.
     3
     4   MS. STEEL:   Right.
     5
     6   MR. JUSTICE BELL:  What it seems to me at the moment is it looks
     7        like it occurs to me that Mr. Brett may not go past late
     8        morning and Miss Bramford may not.  So you will have an
     9        opportunity to put things to Mr. Nicholson on those
    10        afternoons.  If you say that you want an early day on
    11        either of those days because you have some specific
    12        preparation, you tell me about it.  But what I suggest is
    13        you go on for about quarter of an hour now and then make a
    14        note overnight, bearing in mind what I have said, of the
    15        specific things which it would be helpful to put.  You have
    16        clearly got some challenges to make.  For instance, you are
    17        challenging Mr. Nicholson's evidence of what happened on
    18        16th October 1989, which we have not come to yet.
    19
    20   MS. STEEL:   Yes.  Just some of the things I am putting with
    21        regard to the private investigators will be things which
    22        I will say in a statement.  Other things are things which
    23        other of our witnesses have told me, which I will try and
    24        get a supplementary statement from them to cover them as
    25        soon as possible
    26
    27   MR. JUSTICE BELL:  Anything which you think there is a
    28        reasonable prospect of adducing in evidence and which is
    29        part of your case and which you know of now and along those
    30        lines, you should put and, indeed, even if you think you
    31        may not be able to call a witness but you have information
    32        to that effect, this is your opportunity to put it to the
    33        witness if you think that it may be something upon which
    34        you will be relying on in due course, put it to Mr.
    35        Nicholson.  You can do it in fairly short form and you can
    36        either accept it -- if he says, "Well I do not know
    37        anything about that", you can accept that for the time
    38        being or you can pursue it further.  But put it in the
    39        first place.
    40
    41   MS. STEEL:   Well, I suggest to you, Mr. Nicholson, that there
    42        were private investigators attending London Greenpeace
    43        meetings long after January 1991 on behalf of McDonald's,
    44        private investigators that were employed by companies hired
    45        by McDonald's.  I cannot remember off-hand exactly when
    46        they stopped actually, so that is why I am saying it was
    47        several months at least.
    48        A.  Not for me.
    49
    50   Q.   I suggest to you that throughout the late part of 1990 and 
    51        some of 1991, I am not sure how long, that one of the 
    52        private investigators employed by your Company was 
    53        attending pickets of McDonald's stores on a regular basis,
    54        I think every month, at, I think, the Dalston store and the
    55        Seven Sisters store and handing out anti-McDonald's
    56        leaflets?
    57        A.  I cannot help you, I am afraid.
    58
    59   Q.   And that private investigators hired by McDonald's attended
    60        the pickets at McDonald's Head Office and handed out

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