Day 261 - 12 Jun 96 - Page 73


     
     1        that it was inquiry agents who were keeping any such
     2        campaign going.
     3
     4   MS. STEEL:   It is my recollection that Mr. Rampton did make
     5        some comment to that effect.
     6
     7   MR. JUSTICE BELL:  Maybe it was, but let us clear the air now so
     8        you know in the future.
     9
    10   MS. STEEL:   (To the witness):  The next paragraph you go on to
    11        say you went to the public house "where we remained until
    12        11.10 p.m..  Here, I found out little else other than the
    13        fact that most of the correspondence they received was in
    14        response to particular campaigns that they ran and also
    15        that they received many letters from people confusing them
    16        with Greenpeace International."
    17
    18        That was the situation, was it not, that letters came in
    19        about particular campaigns and the particular people who
    20        had a particular interest in that campaign would be the
    21        ones that dealt with those particular letters?
    22        A.  It may well have been but not in my experience.  In my
    23        experience the mail was answered quite sporadically.  It
    24        would build up and then people would go in and have a day
    25        of answering letters.  There were times, as I said before,
    26        that if it was something that it was felt someone was more
    27        knowledgeable on, then letters were put to one side for
    28        that person to deal with.  But it was not a case, as far as
    29        I can remember, of people going in and saying, "That letter
    30        is for me and that letter is for him".
    31
    32   Q.   Right.  In terms of correspondence about McDonald's, as you
    33        have already said, generally that would be Mr. Gravett that
    34        it would be put on one side for?
    35        A.  On the occasion that I -- on the occasion that
    36        I recall, the notes that I have seen, on that instance that
    37        is what I was informed, that they should be put to one side
    38        and Mr. Gravett would deal with those.
    39
    40   Q.   Right.  If you could just look at your statement, the first
    41        statement that you made in tab 7.  It should be 7A,
    42        I think.  It is dated 8th June, 1993.
    43        A.  Sorry, can you repeat the date?
    44
    45   MR. JUSTICE BELL:  Tab 7, divider 7, at the beginning of that
    46        divider.
    47
    48   MS. STEEL:   In your statement in paragraph 7 you said, "In the
    49        office I noted", and this was with reference to 2nd
    50        November 1989, "I noted copies of the leaflet complained 
    51        of", and then it says at appendix 2, "which were stocked in 
    52        boxes on homemade shelfing".  Then the solicitors had 
    53        originally written, "There were also filing cabinets packed
    54        with leaflets", which you have changed to, "There was also
    55        a filing cabinet packed with leaflets".
    56
    57        The reference to "leaflets stocked in boxes" does not
    58        actually appear in your notes.  Do you think that is,
    59        basically, a mistake and that you just referred to the fact
    60        that there were various leaflets sitting on the shelves in

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