Day 263 - 14 Jun 96 - Page 70


     
     1        another question and let us talk about timing.
     2
     3   MR. MORRIS:  None of those leaflets you looked through had any
     4        reference to any of those details that you remembered
     5        verbatim from the meeting?
     6        A.  Well, I flicked through them.  I have not studied them
     7        in detail.  But I will have to take your word for it.
     8
     9   Q.   The court can decide that for itself, that there does not
    10        seem to be anything there at all, apart from McDonald's,
    11        that related to those matters that you heard at the
    12        meeting.
    13
    14        So, I put it to you that you did not pick up the leaflets
    15        that were on the table, did you?
    16        A.  I am afraid you are wrong.  It would have been, I would
    17        have wanted to have been as professional as possible, and I
    18        would have picked up anything that was going.  I would not
    19        have differentiated between McDonald's leaflets and any
    20        others.  I would have picked up as much as I could.  In
    21        fact, I probably would not have given a second glance to
    22        what I was picking up.  I would have picked up one of
    23        everything as quickly as possible.
    24
    25   Q.   When you say what you would have or would not have done,
    26        you do not remember the detail that you have got in these
    27        notes?  These are notes are refreshing your memory?
    28        A.  Yes, correct.
    29
    30   Q.   It is a long time ago.  I am not giving you a hard time?
    31        A.  Yes.
    32
    33   Q.   It is a long time ago?
    34        A.  It is difficult, yes.
    35
    36   Q.   So, is it fair to say that your actual recollection of the
    37        actual meeting is very sketchy?
    38        A.  Now, yes, after five or six years, whatever it is, yes
    39         -- six years.
    40
    41   Q.   It was the only meeting you went to, you say, of
    42        London Greenpeace?
    43        A.  Yes, it was.
    44
    45   Q.   You have gone to thousands of different, events, meetings,
    46        engagements, as part of your professional work?
    47        A.  Yes, all sorts-- yes.
    48
    49   Q.   Right.  You were not aware that it could be involving
    50        litigation for three years -- until three years later? 
    51        A.  Absolutely not. 
    52 
    53   Q.   So you would probably have just done your report and that
    54        is it, history?
    55        A.  Yes.
    56
    57   Q.   Then along comes a solicitor, you do a statement,
    58        et cetera.
    59
    60        Apart from what is in your notes, your report from Kings

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