Day 306 - 26 Nov 96 - Page 51


     
     1        say, and I have -----
     2
     3   MS. STEEL:   I just wanted to make a couple of quick points,
     4        really.
     5
     6   MR. JUSTICE BELL:  Do that.  But I have given you the facility.
     7        You have clearly got a lot of notes, whether word processed
     8        or in your own handwriting, and you do have the opportunity
     9        to word process them out, or any parts of them you want to
    10        word process out, making any additional points and
    11        references by the deadline I have given you.  So, make the
    12        one or two extra points you want to make, and then we will
    13        call it a day.
    14
    15   MS. STEEL:   Just briefly, that, obviously, her evidence was
    16        that she never saw the fact sheet in all the time that she
    17        was attending meetings of London Greenpeace, and it was the
    18        case that she did not consider that McDonald's was very
    19        high on the agenda; it was not discussed much.  I am just
    20        doing this from memory.
    21
    22        Also -- I am not sure what Mr. Rampton is going to say
    23        about this, but when he cross-examined her he asked her
    24        some question about would her notes be more accurate, or
    25        something, than her memory now.  I think the point to be
    26        borne in mind when you are considering her evidence is that
    27        her evidence did not contradict her notes; her evidence
    28        explained what some of the notes said -- for example, where
    29        she had referred to people chairing meetings, or whatever,
    30        she explained what she had meant by that, that there was
    31        not a formal chair but that, for want of a better word or
    32        something and because of the fact that she was used to
    33        being in more formal situations, the terminology she used
    34        she then adopted for London Greenpeace meetings, even
    35        though it was not necessarily appropriate.  So, just really
    36        to bear that in mind, if Mr. Rampton tries to make that
    37        point, that none of the evidence she gave in the witness
    38        box was trying to go back on the notes, or anything like
    39        that; it was explaining what they meant.
    40
    41        The final point, which I think is actually quite important
    42        to make -- this is actually Mr. Russell -- is that if you
    43        look behind his statement at the exhibits, the fact sheet,
    44        the London Greenpeace anti-McDonald's fact sheet which
    45        appears behind his statement has, again, the date on it of
    46        31st May, but if you look at all the other exhibits that
    47        are attached to Mr. Russell's statement you will see that
    48        they have written on them "collected 26th April 1990".
    49        That is in JR/2.  That is on the Greenpeace London leaflet,
    50        that is on the anti-McDonald's fair 1989 programme, that is 
    51        on the anti-McDonald's fair -- I presume that is 1988 
    52        programme; it says "handed out on 26.4.1990".  Presumably, 
    53        there were some old programmes knocking around or
    54        something.
    55
    56        So, I just think it is particularly significant that all
    57        those documents have noted on them that they were obtained
    58        on that date, whereas the fact sheet does not; and that
    59        gives added weight to our argument that, in fact, the fact
    60        sheet was not available on that date and there is not

Prev Next Index