Day 262 - 13 Jun 96 - Page 35


     
     1        A.  I do not remember.
     2
     3   Q.   You do not remember.  Would you have remembered this time
     4        last year which leaflet it was?
     5        A.  I do not know what I knew this time last year.
     6
     7   Q.   You see, in your statement, you say that it is the leaflet
     8        complained of; but, basically, all your notes say is the
     9        "what's wrong with McDonald's?"  So it may be that
    10        somebody from the solicitors' office assumed that meant
    11        that it was the leaflet complained of?
    12        A.  I have read through all the statements and signed them,
    13        and read through them fairly carefully.
    14
    15   Q.   So does that mean within the last year you have forgotten?
    16        A.  Well, I suppose it does, if that is what -- I do not
    17        remember now.
    18
    19   Q.   Is it not just possible that you signed the statement and
    20        assumed that the solicitors had got it right?
    21        A.  No.  I read through the statements quite carefully.
    22
    23   Q.   Did you compare them with your notes at the time?
    24        A.  I did compare.  When I was making statements, I had
    25        access to notes and to previous statements.
    26
    27   Q.   When you were checking that statement, would you have had
    28        this beside you to check it against?
    29        A.  I do not remember what was beside me when I went
    30        through the statement.
    31
    32   Q.   Would you accept that maybe that is a mistake in the
    33        statement, and that because it says 10,000 copies of the
    34        "What's wrong with McDonald's?" leaflet, you have assumed
    35        that that was the leaflet complained of?
    36        A.  Well, to the best of my knowledge, the information in
    37        the statement is true.
    38
    39   Q.   But you could have made a mistake?
    40        A.  It is possible I could have made a mistake.  But, to
    41        the best of my knowledge, it is true.
    42
    43   Q.   Actually, in fact, when you averred your statement, you
    44        were not in a position to aver it in terms of you could say
    45        that now?
    46        A.  Now and when I made the statement are two different
    47        times.
    48
    49   Q.   Yes, but you would not be in a position -- if, for example,
    50        you had been giving your evidence verbally, rather than 
    51        saying, "I made this statement", whatever, "I stand by it"? 
    52        A.  I will stand by the statement that I have read through 
    53        carefully and signed.
    54
    55   Q.   But you would not be able to remember that now, or you have
    56        said you would not?
    57        A.  No.
    58
    59   Q.   Did you ever see the leaflets arrive?
    60        A.  I do not ever recall seeing them actually arrive.

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