Day 192 - 27 Nov 95 - Page 62


     
     1        A.  But she had invited me to her house to explain to her
     2        about the union.
     3
     4   Q.   And you came with Rui Amorim, did you not?
     5        A.  Yes.
     6
     7   Q.   You, between you, kept telling her that there would be
     8        certain guaranteed benefits for her and others if she
     9        signed a card?
    10        A.  I did not guarantee benefits.  I told her there would
    11        be job security, respect and dignity, and I said that we
    12        can negotiate benefits.  I did not promise any benefits.
    13
    14   Q.   And you promised, the two of you, that she could have her
    15        card back if she changed her mind, did you not?
    16        A.  No, I did not.
    17
    18   Q.   She telephoned you the same evening; and can I suggest the
    19        conversation went something like this -- you tell me if you
    20        disagree.  She said: "Can I have my card back?"  You said:
    21        "No."  She said: "Why not?"  You said: "Remember the
    22        benefits you will get."  She said: "I have heard about all
    23        that already.  I want my card back.  I do not want to be
    24        part of the union."  So far so good?
    25        A.  No.
    26
    27   Q.   What is wrong with it so far?
    28        A.  I did not -- is there any way that I could see a copy
    29        of that?
    30
    31   Q.   No.  It is taken from the transcript, which I think you
    32        had.
    33
    34   MS. STEEL:   Can you tell us where it is in the transcript?
    35
    36   MR. RAMPTON:  No, I cannot.  I am afraid I have not got a note
    37        of it.
    38
    39   MS. STEEL:   I do not actually recall that particular
    40        conversation being given in evidence.
    41
    42   MR. JUSTICE BELL:  All that matters now is what the witness's
    43        response to the suggestion is.
    44
    45   MR. RAMPTON:  Not only that; there will be other matters,
    46        my Lord, which I shall be putting to the witness which are
    47        not in the transcripts or the Civil Evidence Act
    48        statements, which are based on instructions.
    49
    50   THE WITNESS:  I believe -- I am not sure if she called me that 
    51        night or a day or two later, but I told her: "I cannot 
    52        personally give you your card back.  You have to call Rui", 
    53        and I gave her Rui's phone number in Toronto, where she had
    54        it to do it.  I told her it was out of my hands --
    55        "I cannot do anything about it.  I do not have your card
    56        to give back to you.  Rui has it."
    57
    58   MR. RAMPTON:   Did you suggest to her that it was unlikely that
    59        she would get it back from Rui?
    60        A.  I knew that at that point -- because I believe it was a

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