Day 245 - 07 May 96 - Page 39


     
     1        Preston?
     2        A.  Ms. Steel, I am not lying.
     3
     4   Q.   In fact lying to 2 MPs?
     5        A.  I am not lying to 2 MPs.  I do not lie.
     6
     7   Q.   If you turn to tab 11, or document number 11, this is a
     8        letter to a member of the public dated 27th February 1996?
     9        A.  Yes.
    10
    11   Q.   To a Mr. Wood in Liverpool.  Again on the second page of
    12        that, it says that it has never been your intention to seek
    13        damages or to recover costs from the Defendants.  So you
    14        are also lying to the public again?
    15        A.  Well, I am not lying to the public and I am not lying
    16        to 2 MPs. I have stated my case now 3 times.  I do not know
    17        what more I can do.
    18
    19   Q.   Can I just ask you about your statement dated 8th March
    20        1996.  Was it all drawn up on that day or did you have
    21        discussions before then?
    22        A.  I certainly knew that I was going to have to make a
    23        supplementary statement regarding the counterclaim.
    24        Whether I talked about them in the morning of or the
    25        afternoon before, I do not actually remember.  I am sure
    26        I did not go in and write the thing in a half an hour
    27        sitting with counsel.  I took a little longer than that.
    28
    29   Q.   The point in paragraph 17 of your statement?
    30        A.  Yes?
    31
    32   Q.   About no letter having been sent before the action which
    33        was in the counterclaim pleadings?
    34        A.  Yes.
    35
    36   Q.   When were you aware of that?  Do you keep abreast of what
    37        is going on with the case and get notified of when there
    38        are new pleadings in the case?
    39        A.  I am sure I do not catch them all but I am reasonably
    40        au fait with what is happening, yes.
    41
    42   Q.   I have not got a date for when those particular
    43        counterclaim pleadings were served but I am sure it was
    44        quite some time before your statement was made.  I do not
    45        know if the Plaintiffs can help with it.  Do you have the
    46        counterclaim?
    47
    48   MR. JUSTICE BELL:  What are you asking about now?
    49
    50   MS. STEEL:  The point where we say in our counterclaim pleadings 
    51        that there was no letter sent to us.  I think it is in the 
    52        Further and Better Particulars of the Reply to the Defence 
    53        to Counterclaim.  I think they should be towards the back
    54        of all the pleadings.  I think it was quite a small
    55        document.
    56
    57   MR. JUSTICE BELL:  What you said in paragraph 17(c) of your
    58        Defence and Counterclaim was that the words in the releases
    59        meant that you and Mr. Morris, as members and
    60        representatives of London Greenpeace, had deliberately

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