Day 261 - 12 Jun 96 - Page 75
1 campaigns they were.
2
3 Q. But in terms of quantities of leaflets inside boxes, you
4 would not know about, you know, how many there were of
5 particular leaflets?
6 A. I could not give exact numbers, no.
7
8 MR. MORRIS: Can you say now, from your memory now, at this
9 time, this period of time, November 1989, which specific
10 leaflets relating to McDonald's were available in the
11 office? I do not mean leaflets that someone might have
12 given you.
13 A. On that occasion, on the 2nd -----
14
15 Q. In November 1989.
16 A. I cannot remember exactly from -- at this moment, my
17 memory now; no, I do not recollect exactly what was
18 available and what was not available
19
20 Q. Right. You said that actually in evidence-in-chief. There
21 were various varieties of McDonald's leaflets available.
22 So, you are standing by what you said in that -- when
23 Mr. Rampton asked you that there were various varieties of
24 McDonald's leaflets available at one time or another?
25
26 MR. JUSTICE BELL: You do not have to repeat it unless you
27 disagree with it.
28
29 MR. MORRIS: All right.
30
31 MS. STEEL: Just about the filing cabinets, would you accept in
32 actual fact that what the filing cabinets contained was old
33 letters, old leaflets and, you know, they were kind of
34 reference material?
35 A. I never made a close examination of the contents of the
36 filing cabinets. From memory, it is certainly possible
37 that is what they contained.
38
39 Q. OK. In your statement in paragraph 10 talking -- actually,
40 sorry, forget that because it is not actually the next
41 meeting to go to. Shall I carry on?
42
43 MR. JUSTICE BELL: What I would like you to do, unless it is
44 going to take a very long time, I would like you to finish
45 what you want to ask about the 2nd November and then we
46 will break off until tomorrow.
47
48 MS. STEEL: Yes, that is actually it.
49
50 MR. RAMPTON: My Lord, can I say something? I find myself in
51 the same position in relation to the boxes of the words
52 complained of on the shelves in the offices as I did in
53 relation to the table at the stall that London Greenpeace
54 had on the 21st October of that year. I am quite unclear
55 whether the Defendants accepted they were there or that
56 they are not sure, or whether they say they were not. One
57 has seen the photograph. I have no idea what the relevance
58 is to that. Maybe they will tell us that when Mr. Clare
59 gives evidence, but at the moment there seems to have been
60 again -----
