Day 255 - 23 May 96 - Page 35


     
     1        line, there is the word "lies".  The last line has "lies"?
     2        A.  Yes.
     3
     4   Q.   Then on the last page under "there are a number of
     5        additional issues which have been raised", there is the
     6        word "lies".  In the next paragraph, the last word is the
     7        word "lies".  The fourth paragraph in that section, third
     8        line, is the word "lies".
     9        A.  Sorry, which section are you now on?
    10
    11   Q.   In the section under "there are a number of additional
    12        issues"?
    13        A.  Which page are you on?
    14
    15   MR. JUSTICE BELL: It is the last page of the background
    16        briefing, the one with the date on the bottom?
    17        A.  Yes, I have got that.
    18
    19   Q.   In the second line of the first full starred point?
    20        A.  Yes.  There is "lies" at the end.
    21
    22   Q.   Yes.  Well, "lies" in the middle of the first paragraph,
    23        first starred paragraph?
    24        A.  Yes, I see that.
    25
    26   Q.   "Lies" at the end of the second starred paragraph; "lies"
    27        in the penultimate line of the fourth starred paragraph?
    28        A.  Yes.
    29
    30   MS. STEEL:   There is very liberal use of the words "lies" in
    31        this document, is there not, a liberal sprinkling of the
    32        word?
    33
    34   MR. JUSTICE BELL:  Do you remember that the word "lies" was
    35        used?
    36        A.  I do not know whether the word "lies" was used at any
    37        of the meetings I attended.  I think I only attended 2, my
    38        Lord, and I am not sure whether the word "lies" was used.
    39        I saw a draft document which was not anything like as big
    40        as this.  I am not a media man.  This is media speak.
    41
    42   MS. STEEL:  I do not know whether you have all the documents?
    43        A.  I do not know what they would have used if they had not
    44        have used the word "lies".  They may have been able to
    45        express themselves differently, I do not know'.
    46
    47   MS. STEEL:  Have we got all the documents relating to this?
    48
    49   MR. JUSTICE BELL: I think you ought to assume that you have all
    50        the documents which are material to the issues which arise 
    51        on the counterclaim.  Certainly if you have not, I do not 
    52        suppose for a moment that Mr. Nicholson will know, bearing 
    53        in mind that their provenance seems to be largely the
    54        public relations agents.
    55
    56   MS. STEEL:  Right.
    57
    58   MR. JUSTICE BELL: What I suggest you might do is you have
    59        identified two of the documents.  If you identify the
    60        others upon which you rely just so Mr. Nicholson can see

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