Day 024 - 15 Sep 94 - Page 63


     
     1        remember it, Mr. Rampton?
     2        A.  Generally, your Lordship, I believe there was
     3        reference to that.
     4
     5   MR. RAMPTON:  I think what we are talking about is page 129 of
     6        section 34 of volume VI A.  It is merely what looks like a
     7        dictaphone or answer phone recital of the letter of 24th
     8        April.
     9
    10   MS. STEEL:   No, that is a letter.
    11
    12   MR. RAMPTON:  It says "typed from dictaphone transcription".
    13
    14   MS. STEEL:   That was not a press release; that was a letter.
    15
    16   MR. JUSTICE BELL:  But it may refer to it.
    17
    18   MS. STEEL:   But the note I have is something about a press
    19        release being read over the phone.
    20
    21   MR. JUSTICE BELL:  Do you ever remember reading a press release
    22        or proposed press release over the telephone to
    23        Mr. Horwitz?
    24        A.  Reading, your Lordship, or what?  I did not hear.
    25
    26   Q.   Reading a press release or proposed press release over the
    27        phone to Mr. Horwitz.
    28        A.  I could say, by reconstruction of memory, I did not
    29        read any, I would not have read a proposed press release
    30        to him.  I do not-- the Exhibit 129 purports to be a
    31        dictaphone transcription of a telephone conversation with
    32        me.  I would point to the court that what that is is a
    33        faulty, but fairly accurate, transcription of my letter
    34        that is in that same binder, two pages later, at page
    35        131.  It is not a press release; it is just the letter.
    36
    37        I believe, and this is working on memory that is not
    38        perfect, but I believe that when we sent this letter to
    39        McDonald's on April 24th 1987, again because at that time
    40        I do not think we had fax technology in our offices -----
    41
    42   MR. JUSTICE BELL:  I do not actually think -- I may be wrong --
    43        that is on the point Ms. Steel is ----
    44
    45   MS. STEEL:  No.  It is because I cannot find the reference.
    46
    47   THE WITNESS:  If I may, your Lordship, in our jurisprudence --
    48        I do not know that that applies here -- it is said that if
    49        you ask a lawyer what time is, he will tell you how to
    50        build a watch.  I am almost concluded with telling the 
    51        court how to build a watch. 
    52 
    53   MR. JUSTICE BELL:  The question is simply the one -- you said
    54        you do not recall ever reading a proposed press release to
    55        Mr. Horwitz.  Do you recall ever reading a press release
    56        which had actually been issued to him?
    57        A.  I was, in fact, to give the court the context, it is
    58        possible -- I do not recall it, your Lordship, at all --
    59        it is not impossible that on 24th April that we contacted
    60        them and extended to them the same courtesy they had

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