Day 261 - 12 Jun 96 - Page 74
1 the office, some of them in boxes and some of them just
2 sitting on the shelves, without naming which specific
3 leaflets, because, as I say, it is not in your notes of
4 that day. You can check if you want.
5 A. I do not think it is a mistake, no. I checked these
6 statements very carefully at the time I signed them, and
7 the fact that I have not put -- named individual leaflets
8 in my notes may well be the fact -- may well be that I did
9 not know there was a particular interest in any particular
10 leaflet at that time. I may have taken a random sample of
11 leaflets out. I remember on some occasions when, some of
12 the letter answering occasions, for instance, where the
13 leaflets were definitely on boxes and shelves.
14
15 Q. But that was not those specific leaflets solely that you
16 are referring to; you are just talking about leaflets in
17 general?
18 A. What I am referring to -----
19
20 Q. The London Greenpeace leaflets in general?
21 A. The McDonald's, the anti-McDonald's leaflets were
22 certainly stocked in boxes and shelves. I remember them.
23
24 Q. But, I mean, over the course of time you saw quite a lot of
25 leaflets. Three years later you would have been unlikely
26 to recollect which specific leaflet you had seen in which
27 quantities, in which place, in the office and is it,
28 basically, the situation that you recollected that there
29 were leaflets obviously in the office, all sorts of
30 leaflets, and that the solicitors put a copy of the
31 fact sheet in front of you and said, "Was this one of
32 them"?
33 A. I do not remember at the -- when I made the statement.
34 It could well have been that when I presented a report back
35 to my employer, I would present with that report any
36 leaflets that were collected at that particular time. It
37 may well have been with reference to a set of leaflets
38 I collected on that date.
39
40 Q. There is not, as far as I can see, a reference in your
41 notes to any leaflets being collected on that day?
42 A. No, there is not, but there would not necessarily be.
43
44 Q. On most of your other notes you have -- well, in various
45 places in your notes you have actually made a note of where
46 you have enclosed leaflets with the reports. Was that not
47 your normal procedure, that you would make a note of where
48 you were enclosing leaflets with the report?
49 A. It would be the better way of writing the report, but
50 I cannot guarantee I always did it.
51
52 Q. This is the first 5 Caledonian Road meeting that you
53 attended. Is it likely that you would have rummaged
54 through the boxes and filing cabinets that were on the
55 group's shelves, bearing in mind there were going to be ten
56 people in the room?
57 A. It is not likely I would have rummaged, but it is also
58 not unlikely that I would have been shown what leaflets
59 were available as I was new to the group. It is likely I
60 would have been shown what leaflets they were and what
