Day 267 - 21 Jun 96 - Page 23
1 is on one of the sets on the photographs, was in your
2 writing?
3 A. That is correct, sir.
4
5 MS. STEEL: Right. So--
6
7 MR. JUSTICE BELL: And you crossed out "Stephen"?
8 A. Yes.
9
10 MS. STEEL: So do you think that you were given these names with
11 the photographs when you were first asked to start
12 investigating the group?
13 A. I do not recall. It may have been before. It may
14 have been during. I do not recall.
15
16 Q. Well, it must have been fairly early on because you have
17 got the--
18 A. I imagine it would have been near the beginning
19 because, as has been pointed out, Steven has been crossed
20 out.
21
22 Q. Right, and by the 18th January you had put "Paul Allen,
23 reference photo and Ellen/Helen, reference photo"?
24 A. Right.
25
26 MR. JUSTICE BELL: Well, it looks like, is it, between the 4th
27 and 18th January does it not?
28 A. It would appear so.
29
30 MS. STEEL: Did you get any document describing people in the
31 group, or anything like that; do you remember?
32 A. I really do not recall. I remember the meeting
33 vaguely when I was instructed, but as to what was given to
34 me, when, I do not remember.
35
36 Q. Could you just get the counterclaim bundle? It is on the
37 top shelf. It is a pink and white label. I think it is in
38 number 2.
39
40 MR. JUSTICE BELL: What divider is it?
41
42 MS. STEEL: It is number 78 -- it is in number 1, is it? (Same
43 handed)
44 A. Is it a memo?
45
46 Q. Yes, that is it. If you could just read through that?
47 (Pause)
48 A. Right.
49
50 Q. We have been told that this memo was sent to two firms of
51 inquiry agents that were engaged by McDonald's. Do you
52 remember reading it before or during the time when you were
53 infiltrating the group?
54 A. No, I do not recall seeing any McDonald's literature
55 such as that.
56
57 Q. Right. OK. If you go over to page 5 of the notes?
58 A. Do you have the bundle-page again?
59
60 Q. It might be 55, but I might be wrong.
