Day 260 - 11 Jun 96 - Page 20


     
     1        on, we put it to the witness and say, "Is that correct",
     2        I think.
     3
     4   MR. JUSTICE BELL:  Yes, if you are not prepared to take the
     5        omnibus step of getting him to aver all his notes.  I can
     6        see you might not want to do that.  Are there very many
     7        instances you want to refer to?
     8
     9   MS. STEEL:   You mean to get him to aver?
    10
    11   MR. JUSTICE BELL:  Yes.
    12
    13   MS. STEEL:   There is not -- I mean, it varies, but there is not
    14        a massive amount in each one, because we have covered the
    15        kind of general principles, anyway, so it is sort of
    16        specific incidents, really, that is left.
    17
    18        (To the witness)  The statement that I just read out to you
    19        about Anthony and Jonathan engaged in answering
    20        correspondence from various sources, and most of the
    21        letters appeared to be answered by enclosing an existing
    22        leaflet on the relevant subject, that is correct, is it?
    23        A.  Yes.
    24
    25   Q.   The Alan that is referred to in the first paragraph, that
    26        is Alan from -- you might not have known then, because it
    27        says "origin unknown" -- but that is the Alan from Catford
    28        that appears in the later meeting?
    29        A.  I cannot be specific.  I cannot place -- I cannot
    30        picture the individual referred to as Alan in this
    31        particular report.
    32
    33   Q.   If the group agreed to do something as a group, as opposed
    34        to individuals saying they might go to such and such a
    35        demonstration, or whatever, if the group agreed to do
    36        something as a group, you would have made a note of that,
    37        would you?
    38        A.  Yes.
    39
    40   Q.   In the last paragraph on the first page, you talk about the
    41        Musicians Network and confusion between Greenpeace
    42        International and Greenpeace London?
    43        A.  Yes.
    44
    45   Q.   Were you aware that London Greenpeace used to share an
    46        office with the Musicians Network?
    47        A.  No, I did not know that.
    48
    49   Q.   On the second page, you refer to -- the paragraph that is
    50        in the middle of the blanked out bit: 
    51 
    52        "The only other item that received any attention was a red 
    53        invoice from British Telecom to the amount of some £50.
    54        Anthony made the comment neither Helen nor Dave, the two
    55        signatories to the bank account, had been to a meeting for
    56        some months."
    57
    58        In your statement, on the first page of your second
    59        statement, you said:
    60

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