Day 246 - 09 May 96 - Page 06


     
     1        particularly appear to be very detailed in terms of each of
     2        the points covered by the libel action.  Do you know
     3        whether there was a separate document, or what the
     4        situation was?
     5        A.  I do not know.
     6
     7   Q.   You do not know?
     8        A.  No.
     9
    10   Q.   Then No 6 is a letter from London Greenpeace distancing
    11        themselves from London Greenpeace which can be used in
    12        briefing media and consumer, so you were aware that your
    13        communications department was initiating, getting, such a
    14        letter?
    15        A.  Well, from this, I cannot tell you if they were
    16        initiating or if they already had it, but I certainly know
    17        such a letter exists.  Whether we instigated it or whether
    18        they came to us and said, "We want you to know this",
    19        I really do not know, I cannot remember.
    20
    21   Q.   I think the letter actually indicates that it is in
    22        response to an enquiry?
    23        A.  That could be.
    24
    25   Q.   I will not turn it up right now.  It also says they need a
    26        meeting as soon as possible and one strategy, 2 spokes
    27        people.  Do you know what that is referring to?
    28        A.  I would assume it is a meeting with Greenpeace. There
    29        is an error in front of that.  Maybe "need a meeting with
    30        Greenpeace".
    31
    32   Q.   Do you know whether one took place?
    33        A.  I do not know.  I certainly did not attend one.
    34
    35   Q.   Right.  Do you know what the "strategy and spokes people"
    36        refers to?  Is that the Company or is that asking for
    37        spokes people from Greenpeace, or what?
    38        A.  I could only speculate, I do not know.
    39
    40   Q.   You do not know.  No 11 is: "Subject to agree strategy,
    41        briefing of key media in advance of case to clarify why
    42        McDonald's is bringing this action".  What was the "agreed
    43        strategy"?
    44        A.  I think the overall goal was to establish the truth,
    45        and that is all it has ever been.
    46
    47   Q.   Yes, but we are talking about "the strategy" in terms of
    48        putting over how you were going to put over what you
    49        considered your side of the story to be?
    50        A.  I do not think we had any strategy.  I think it all 
    51        depended on what was happening at the time.  At the end of 
    52        January the circulation of material by London Greenpeace, 
    53        or the so-called McLibel Support Group, had either just
    54        begun or was about to begin.  We, until this point in time,
    55        had not done any circulation of anything at all in
    56        literature form.  I think it was to be used as and when
    57        necessary, but certainly not to use as a first issue.
    58
    59   Q.   So, you do not actually know what the "agreed strategy"
    60        that is referred to there is?

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