Day 306 - 26 Nov 96 - Page 46
1 made in 1990. He had gone in in 1990 and explained what
2 had happened on the picket, that notes had been taken and
3 that the statement was drawn up from that. So, that is a
4 year roughly -- well, it did not say when in 1990, but it
5 is several months at the minimum after the picket. On day
6 259, page 4, line 58 he accepted that there were details
7 wrong in his first statement, that there had been no picket
8 in 1985 and 1986, and I asked him: "So you signed the
9 statement without checking it?" He said: "No, I did check
10 it. I missed it." I think the point about that is, I
11 mean, obviously that is being held against Mr. Morris with
12 his affidavit that he missed something written in his
13 affidavit. That just shows that everybody is fallible.
14
15 The other point about this, which is more important for my
16 sake probably, is that that goes for any details in the
17 statement and particularly this point about the leaflet
18 complained of. There were several mistakes in his first
19 statement. If I just run through some of them. In his
20 first statement in paragraph 8 he said that he observed the
21 demonstration on the 16th October 1989 for periods of about
22 ten to 30 minutes at a time and, yet, in his evidence
23 I think the longest he was out observing the picket at any
24 one time was ten minutes. So, the 30 minutes in his first
25 statement is way out.
26
27 The next thing in his statement which is wrong is in
28 paragraph 9 where he says that wads or piles of the leaflet
29 complained of were placed by the side of the building, and
30 in his evidence he referred to that being in holdalls and
31 boxes. As I said before, on day 250, page 47, he -- in
32 fact, on page 48, line 25, he said: "I did not see in any
33 of the holdalls, really". So he clearly was not in a
34 position to be stating that piles of the leaflet complained
35 of were stacked by the building. So, he should not have
36 said it in his statement. It seems that it does not
37 particularly trouble him to have any number of things in
38 his statement which he does not actually know. He is just
39 basing on supposition.
40
41 In paragraph 10 of his first statement he said that he
42 observed both Paul Gravett and Helen Steel distribute
43 leaflets during the course of the afternoon. However, when
44 he was cross-examined on day 250, page 47, he admitted: "I
45 did not actually see him handing any leaflets to anybody."
46 That was Mr. Gravett. So, you know, again, why did he put
47 it in his statement if he did not see anybody handing
48 leaflets to anybody?
49
50 There is obviously the point in paragraph 12, which I have
51 mentioned already, where what he says is incorrect. So, I
52 will not go through that again.
53
54 MR. MORRIS: It would be correct if, by the leaflet complained
55 of, it meant the A5, an A5, or just any "What's wrong with
56 McDonald's" leaflet.
57
58 MS. STEEL: Actually, there was another thing that I missed out
59 from his statement which is incorrect, which is in
60 paragraph 10, which I have just mentioned, he said: "Prior
