Day 057 - 29 Nov 94 - Page 54
1 "(6) Our Defence", etc., and they are relying on this
2 document.
3
4 MR. JUSTICE BELL: Let me just turn it up. Which part of page
5 11?
6
7 MS. STEEL: I think it is page 8 of tab 1 that is at the back of
8 that.
9
10 MR. JUSTICE BELL: Page 266.
11
12 MS. STEEL: 275 at the bottom. I think it has 8 at the top.
13 Well, the page before has 7 at the top.
14
15 MR. JUSTICE BELL: 370 it has got on.
16
17 MS. STEEL: 275 it should have on it.
18
19 MR. JUSTICE BELL: "What is wrong with McDonald's"?
20
21 MR. MORRIS: No.
22
23 MR. JUSTICE BELL: If I turn to tab 1 I have a document with a
24 (viii) in the top right-hand corner, is that what you are
25 referring to?
26
27 MR. RAMPTON: My Lord, it looks like that. It is headed
28 "Greenpeace (London)". It has 275 at the bottom of the
29 page.
30
31 MR. JUSTICE BELL: All the numbers are in a funny order I go
32 from 273 which is Greenpeace (London) 18.5.91 to 265.
33
34 MS. STEEL: In the top right-hand corner there should be the
35 numbers 1 to 6, but where it is like a double-sided leaflet
36 the second page is not numbered but it is No. 6.
37
38 MR. ATKINSON: My Lord, they are in funny order because they
39 are taken from the trial bundles.
40
41 MR. JUSTICE BELL: I have it now, thank you. I have to say it
42 is almost entirely illegible, my copy.
43
44 MS. STEEL: The point I want to make on this is, it is a legally
45 privileged document. It is not a leaflet. It was
46 correspondence with a potential witness. I do not know how
47 the Plaintiffs got hold of it, but we object obviously
48 strongly to them trying to use it in evidence -- well, we
49 just object strongly to them using it in any form really.
50 It cannot be relied upon as a leaflet.
51
52 MR. JUSTICE BELL: I will hear what Mr. Atkinson says. Who do
53 you say it is addressed to, do you mind telling me that?
54
55 MS. STEEL: It has been scribbled out.
56
57 MR. MORRIS: It is addressed to Alexander Bonilla who appears in
58 "Jungle Burger". He is now an adviser to the ministry of
59 something or other in Costa Rica. The document here is a
60 copy of the relevant section of our pleaded particulars
