Day 306 - 26 Nov 96 - Page 17


     
     1
     2   MR. JUSTICE BELL:  Obviously, it is reasonable to have some
     3        discussion in court, but as quietly as possible.  Right.  A
     4        leaflet was described to him, but he did not say more about
     5        it?
     6
     7   MR. MORRIS:   No.  Mr. Rampton showed him, I think, the fact
     8        sheet and he said that he thinks he would have seen it.
     9        The bottom of page 28.  He thinks he would have seen it
    10        before going to any meetings, and that his instructions had
    11        included to identify and establish the authors of the
    12        multi-sided leaflet.
    13
    14        Then on page 29, "Do you remember if you ever took one away
    15        from those meetings?"  Answer, "Yes, I would have done."
    16        He did say in the middle of page 29 that he and his
    17        colleagues referred to the fact sheet as the multi-sided
    18        fact sheet.  Then Mr. Rampton said, line 46, "Who referred
    19        to it as a fact sheet?"  Answer, "My principals, myself, I
    20        believe the Defendants would have."  This is line 47.
    21
    22        So, presumably, if he is referring to the fact sheet then
    23        he would have specified that in his notes because he says
    24        that his principals referred to it as that and that he was
    25        instructed before he started, and that he and his
    26        colleagues referred to it as a multi-sided fact sheet.  So
    27        he does not mention that, we would say then it is not the
    28        same document.  Of course, if he does refer to it then he
    29        would have to distinguish whether it was the Veggies
    30        version or the London Greenpeace version for it to be of
    31        compelling, or even balance of probabilities, the words
    32        complained of, or the leaflet complained of.
    33
    34        He does say at the top of page 32, line 14, that the
    35        standard practice at monthly meetings was for numerous
    36        leaflets to be taken by a member of London Greenpeace and,
    37        of course, that relates to what Mr. Russell said about
    38        picking up copies of all the leaflets that are on the
    39        table, there would have been numerous different types of
    40        leaflets.
    41
    42        1st March -- sorry, no.  Moving to cross-examination now.
    43        His instructions on page 45, lines 48 to 50, were to do
    44        those things I have already said, plus also to identify
    45        simply those involved with the anti-McDonald's campaign.
    46        So he had in his mind the photographs, the core members
    47        instructions, that he was expected to find and looking, we
    48        would say, to link those who he had been told about with
    49        his keenness to identify those involved with the
    50        anti-McDonald's campaign. 
    51 
    52        Then he says on page 46, line 32, "The instructions were to 
    53        establish or identify those involved with the group, and/or
    54        where the leaflets, particularly the fact sheet complained
    55        of, where that was mentioned."  So, here we have an
    56        absolute clear as day indication that the fact sheet
    57        complained of was something that was particularly needed to
    58        be identified and, therefore, where he does not identify it
    59        specifically in the notes, then it would not be that, and
    60        if he does identify it specifically, there needs to be

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