Day 263 - 14 Jun 96 - Page 08


     
     1        in relation to McDonald's while the agents were there could
     2        be said to be of potential relevance, whether you and
     3        Ms. Steel were there or not.
     4
     5        You do not have to argue that, but Mr. Rampton says that is
     6        the measure of it.  Moreover, you stop at September 1990,
     7        because the only two events which he relies on thereafter
     8        have nothing to do with -- are not related to
     9        London Greenpeace meetings or, rather, are not related to
    10        anything which the agents were investigating.
    11
    12   MR. MORRIS:  So, if Mr. Rampton's argument is that our
    13        involvement in the group in general is relevant because it
    14        relates to the consent, our consent or whatever, then that
    15        even more applies to our specified -- equally or even more
    16        applies to our specified pleading of the Plaintiffs'
    17        consent, because of the level of involvement of their
    18        individual agents in the group.  Therefore, any mention of
    19        any agent, just as Mr. Rampton has accepted that any
    20        mention of myself and Ms. Steel in any reports is relevant
    21        to a general picture of how involved or not we were, then
    22        the same applies to the agents, the seven agents that we
    23        know of.  Any mention in any reports of any of the seven
    24        agents' attendance or involvement in any London Greenpeace
    25        activities are of equal relevance as the relevance that
    26        Mr. Rampton has conceded for myself and Ms. Steel, our
    27        attendance and involvement in group activities.  I cannot
    28        see how he can have one without the other, especially on a
    29        matter as fundamental as this in the case.  I think that
    30        the court must have the full information at its fingertips
    31        with which to come to a correct decision.
    32
    33   MR. JUSTICE BELL:  Yes.
    34
    35   MR. MORRIS:  So, the relevance -- I see four categories of
    36        relevance, I think.  There is the records of each day, each
    37        event, meeting or whatever, full records of each of
    38        those -- without blanked out parts, because if the agents
    39        attended, it is important to get the full picture of their
    40        involvement or non-involvement or, indeed, their thoughts,
    41        because our state of mind has been canvassed, not just what
    42        we did but what we might have said or thought or what
    43        somebody else reported we might have said or thought.  So
    44        that is that.
    45
    46        Secondly, obviously, if an agent's evidence is relevant,
    47        then their full experience and evidence is relevant;
    48        therefore, all the notes and reports relating to each of
    49        the four agents that McDonald's have already called or are
    50        calling must be relevant.  The records ----- 
    51 
    52   MR. JUSTICE BELL:  What you are saying it boils down to is this, 
    53        is it not -- and I have to weigh up whether I think
    54        Mr. Rampton is right or you are right -- you say that all
    55        observations of meetings of London Greenpeace or events in
    56        which they were or might have been involved by all agents
    57        to be called or not to be called are relevant?
    58
    59   MR. MORRIS:  Yes.
    60

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