Day 245 - 07 May 96 - Page 66


     
     1
     2   Q.   Can we get my statement out.  I think it is important.
     3
     4   MR. JUSTICE BELL:  Yes.
     5
     6   MR. MORRIS:  It is in the Defendants' statement.  I am not sure
     7        what number that is in.   It is in the publication section,
     8        I believe.
     9
    10   MR. JUSTICE BELL:  It is pale blue 1C.  The bundles are divided
    11        up and at the very beginning there is a divider F.  Divider
    12        1 was Ms. Steel's statement and divider 2 is Mr. Morris's.
    13
    14   MR. MORRIS:  Have you read this?
    15        A.  I believe I have.  I have not done it recently.
    16
    17   Q.   Right.  If you look at the fourth page, it has a
    18        handwritten continuation statement on 28th July 1993; is
    19        that correct?
    20        A.  There is a handwritten statement.  The date is 28th
    21        July, 1993.  Is that what you are saying?
    22
    23   Q.   That is correct.  It is a continuation of the statement of
    24        Dave Morris in my handwriting and signed at the bottom.
    25        You will accept, for example, that it says that I (the
    26        second paragraph), had spoken to officials of the
    27        International Union of Food Workers about McDonald's
    28        employment policies, poor pay and conditions, that I had
    29        spoken to the makers of the Jungle Burger where suppliers
    30        of McDonald's had been interviewed saying that they
    31        exported to McDonald's in the US, and I had spoken (the
    32        next paragraph) to experts on the inadequacies of the US
    33        beef labelling system.  The next paragraph says I spoke to
    34        many parents who objected to the advertising and promotion
    35        and pressures on their kids to go to McDonald's, etcetera
    36        and it goes through the issues: environment/index.html">litter, animal suffering,
    37        over the page.  My belief is that companies are motivated
    38        predominantly by profits and power and all that kind of
    39        stuff.  That was in 1993.
    40
    41        You knew, or should have known, or were reckless not to
    42        have known, that I fervently believed that the material in
    43        the London Greenpeace fact sheet was true?
    44        A.  I am sorry?
    45
    46   MR. JUSTICE BELL:  Take it in steps.  Ask whether he accepts the
    47        contents of your statement first of all.
    48
    49   MR. MORRIS:  Do you accept that I believe those things that
    50        I have written in my statement, that I did contact those 
    51        people and? 
    52        A.  You may very well have.  I have no way of knowing.  You 
    53        say you did.  We will give the benefit of the doubt.  You
    54        contacted them.
    55
    56   Q.   Right.  That we prepared a substantial case with 65 or 70
    57        witnesses to defend?
    58        A.  You are here in defence, certainly.
    59
    60   Q.   Yes, so to attack my state of mind being that I have

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