Day 312 - 11 Dec 96 - Page 48
1 and that is all that Mr. Rampton has quoted.
2
3 Now, I do not actually know whether he put this particular
4 leaflet to any witness, but he certainly did not ask
5 anybody what that statement meant and it should be put in
6 context, and if you read the whole of that leaflet, or the
7 whole of the paragraph, the last paragraph, it actually
8 says that: "The group has no leaders or members" and then
9 says the quote, "and all our work is done collectively";
10 i.e., that the work to be done is done on a collective
11 rather than a hierarchical basis, if you look at the whole
12 context of what is being said, and it does not mean (as
13 Mr. Rampton is trying to interpret it) that everybody
14 remotely involved with the group is involved in everything
15 in a collective way.
16
17 So, it is important to read the context of that leaflet or
18 the whole of it to get the context; the whole of that
19 paragraph to get the context of it.
20
21 MR. JUSTICE BELL: Yes.
22
23 MS. STEEL: On page 8 there is, firstly, a question that
24 I wanted to ask about this, the thing in the left-hand
25 margin. I have absolutely no idea what that means.
26
27 MR. RAMPTON: All that means -- I had better explain it; I
28 should not have put it in Latin, but it is a convenient
29 shorthand -- all it means is that is the day before which
30 it is not possible to make a claim for libel. "Before
31 which not" is what the Latin means.
32
33 MR. JUSTICE BELL: It is just explaining why September 1987 has
34 been chosen, not because it is factually significant so far
35 as whether, as I understand it, the group's anti-McDonald's
36 campaign was one of its principal activities, but it is
37 legally significant because of the limitation point.
38
39 MS. STEEL: Right. The thing about paragraph 5 is that, as a
40 reference for saying that the group's anti-McDonald's
41 campaign was clearly one of its principal activities --
42 perhaps the principal activity -- Mr. Rampton gives this
43 leaflet as a reference. Now, that is not what the leaflet
44 says. The leaflet says it is one of the most successful
45 campaigns, which is entirely different to being a principal
46 campaign.
47
48 In paragraph 7 on that page Mr. Rampton refers to myself
49 and Mr. Morris enthusiastically associating ourselves with
50 the anti-McDonald's campaign and the particular leaflet
51 that is referred to there. I just wanted to point out that
52 is actually -- what is suggested there is actually contrary
53 to the evidence where Mr. Gravett actually said that he
54 wrote the leaflet without us having read it or being
55 consulted.
56
57 On page 9, this is about the Plaintiffs' case for
58 distribution of the anti-McDonald's fact sheet and
59 encouraging its distribution, and the reference -- the
60 third reference under number 9, pink 1A, 47, 131,
