Day 263 - 14 Jun 96 - Page 12


     
     1        that the Hooker reports were apparently sent directly to
     2        Sid Nicholson after a certain point.  So that becomes
     3        relevant.  That is what Mr. Rampton said yesterday.
     4
     5   MS. STEEL:   Mr. Morris has actually dealt with most of what
     6        I was going to say, so I am just going to finish off some
     7        bits and pieces which I do not think he did cover or
     8        I might want to say something slightly different.  But
     9        I adopt all his argument.
    10
    11        In this case, the Plaintiffs seem to be relying on -- they
    12        have relied on agency and, as part of that, they are
    13        relying on our involvement with the group and the nature of
    14        the group.  So, in order for the court to get a true
    15        picture of the nature of the group and of the extent of our
    16        involvement, the court needs to be able to see all the
    17        material that was taken at the time, in terms of notes of
    18        meetings and reports of meetings.
    19
    20        By the Plaintiffs' own admission, they selected the parts
    21        which show us at meetings or show references to McDonald's
    22        and which must, therefore, give an imbalanced picture of
    23        the extent of our involvement and the extent of the
    24        anti-McDonald's campaign, because we do not know the dates
    25        of the other meetings when the inquiry agents attended.
    26        There may be hundreds of them; there may be five, there may
    27        be 10, there may be 15, there may be 100; we do not know.
    28
    29        The picture that has been painted so far is that it seems
    30        to be something that is coming up at almost every meeting
    31        and that -----
    32
    33   MR. JUSTICE BELL:  I know that there were regular
    34        Caledonian Road and Endsleigh Street meetings, do I not?
    35
    36   MS. STEEL:   Yes.  I mean, we know that there was a meeting
    37        every week.  If the Plaintiffs want to concede that every
    38        single other meeting we were not there and McDonald's was
    39        not discussed either -----
    40
    41   MR. JUSTICE BELL:  That is a natural result of the stand they
    42        have taken.
    43
    44   MS. STEEL:   I was not clear that they had taken that stand,
    45        because I thought they were going to infer that -----
    46
    47   MR. JUSTICE BELL:  Taking that stand may be too positive, but it
    48        is clear that the agents who are being called, or some of
    49        them, attended at least one other meeting than appear in
    50        their statements. 
    51 
    52   MR. RAMPTON:  It is, if I may say so -- I do not want to 
    53        interrupt Ms. Steel -- perfectly obvious that I can only
    54        rely for participation, or whatever it may be, or to
    55        counteract a suggestion of encouraging an anti-McDonald's
    56        campaign, on the evidence I adduce.  If the Defendants
    57        deposed, or their witnesses, that this is only a tiny
    58        proportion of the meetings of the group or that the
    59        activities of the group were mainly concerned with other
    60        things, I am not in a position to contradict it.

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