Day 312 - 11 Dec 96 - Page 47


     
     1        is on page 3 and it is about the 1988 anti-McDonald's fair,
     2        and whilst Mr. Rampton correctly says that I could not
     3        remember if I attended, he then goes on to say but, on
     4        balance of probabilities, it is likely that I was there.
     5        If you actually read that reference that is quoted there,
     6        I did not -- I said that I did not agree that it was likely
     7        that I attended.  I just said that it was possible that
     8        I had attended.
     9
    10   MR. RAMPTON:  That is not attributed to Ms. Steel.  That is my
    11        own submission.  Whatever she said, I submit that it is
    12        probable she was there.
    13
    14   MR. JUSTICE BELL:  Which page are you on now?  Are you still in
    15        the volume?
    16
    17   MS. STEEL:   The Plaintiffs' Closing Submission, Volume 6.
    18
    19   MR. JUSTICE BELL:  Which page are you on?
    20
    21   MS. STEEL:   Page 3.
    22
    23   MR. JUSTICE BELL:  Yes.  I have read that as Mr. Rampton's --
    24        the conclusion he would ask me to draw.
    25
    26   MS. STEEL:   The next thing -- I am not going through --  I
    27        mean, obviously, there is a considerable amount in here
    28        that I disagree with.  I am just trying to go through all
    29        the -----
    30
    31   MR. JUSTICE BELL:  My view of this is this:  You do not have any
    32        right to reply.  If there are a few things which are
    33        burning a hole in you, what I want you to do is just
    34        identify them to me very shortly.  But, as you appreciate,
    35        I am sure as well as anyone, we cannot swing backwards and
    36        forwards from one side to the other on argument.
    37
    38   MS. STEEL:   I understand that.  That is what I was saying.
    39
    40   MR. JUSTICE BELL:  Just let me make a note of them so I have
    41        them in mind.
    42
    43   MS. STEEL:   That is what I was saying, that obviously there are
    44        a considerable number of things I disagree with, but I am
    45        just pointing out the things where I think that there is --
    46        I do not know -- that the Plaintiffs' case is completely --
    47        cannot be legally put, whatever.
    48
    49   MR. JUSTICE BELL:  Yes.  Carry on.
    50
    51   MS. STEEL:   I do not know how to express it.
    52
    53        On page 7 Mr. Rampton refers at point 1 to -- he says that
    54        London Greenpeace has or had no form of structural
    55        constitution and then says:  This does not mean, however,
    56        that its members cannot act collectively or by consensus in
    57        pursuit of common aims and objectives.  He gives as a
    58        reference to that pink 1A, tab 55, page 160, the last
    59        paragraph of the leaflet that appears in that tab, which
    60        says at that point: "All our work is done collectively",

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