Day 261 - 12 Jun 96 - Page 74


     
     1        the office, some of them in boxes and some of them just
     2        sitting on the shelves, without naming which specific
     3        leaflets, because, as I say, it is not in your notes of
     4        that day.  You can check if you want.
     5        A.  I do not think it is a mistake, no.  I checked these
     6        statements very carefully at the time I signed them, and
     7        the fact that I have not put -- named individual leaflets
     8        in my notes may well be the fact -- may well be that I did
     9        not know there was a particular interest in any particular
    10        leaflet at that time.  I may have taken a random sample of
    11        leaflets out.  I remember on some occasions when, some of
    12        the letter answering occasions, for instance, where the
    13        leaflets were definitely on boxes and shelves.
    14
    15   Q.   But that was not those specific leaflets solely that you
    16        are referring to; you are just talking about leaflets in
    17        general?
    18        A.  What I am referring to -----
    19
    20   Q.   The London Greenpeace leaflets in general?
    21        A.  The McDonald's, the anti-McDonald's leaflets were
    22        certainly stocked in boxes and shelves.  I remember them.
    23
    24   Q.   But, I mean, over the course of time you saw quite a lot of
    25        leaflets.  Three years later you would have been unlikely
    26        to recollect which specific leaflet you had seen in which
    27        quantities, in which place, in the office and is it,
    28        basically, the situation that you recollected that there
    29        were leaflets obviously in the office, all sorts of
    30        leaflets, and that the solicitors put a copy of the
    31        fact sheet in front of you and said, "Was this one of
    32        them"?
    33        A.  I do not remember at the -- when I made the statement.
    34        It could well have been that when I presented a report back
    35        to my employer, I would present with that report any
    36        leaflets that were collected at that particular time.  It
    37        may well have been with reference to a set of leaflets
    38        I collected on that date.
    39
    40   Q.   There is not, as far as I can see, a reference in your
    41        notes to any leaflets being collected on that day?
    42        A.  No, there is not, but there would not necessarily be.
    43
    44   Q.   On most of your other notes you have -- well, in various
    45        places in your notes you have actually made a note of where
    46        you have enclosed leaflets with the reports.  Was that not
    47        your normal procedure, that you would make a note of where
    48        you were enclosing leaflets with the report?
    49        A.  It would be the better way of writing the report, but
    50        I cannot guarantee I always did it. 
    51 
    52   Q.   This is the first 5 Caledonian Road meeting that you 
    53        attended.  Is it likely that you would have rummaged
    54        through the boxes and filing cabinets that were on the
    55        group's shelves, bearing in mind there were going to be ten
    56        people in the room?
    57        A.  It is not likely I would have rummaged, but it is also
    58        not unlikely that I would have been shown what leaflets
    59        were available as I was new to the group.  It is likely I
    60        would have been shown what leaflets they were and what

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