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
