Day 258 - 07 Jun 96 - Page 61


     
     1        was limited to the high street.
     2
     3   Q.   So, if we had photographs -----
     4        A.  It is never used.
     5
     6   Q.   -- at another time of people walking in to that front gate,
     7        sorry, to that front door -----
     8        A.  The only time that is used -- it is alarmed,
     9        permanently alarmed -- the only time that is used is if we
    10        switch off the alarm for some particular reason.  It is
    11        never used except for, you know, Terry Carroll had a
    12        demonstration in '88, '89, '90 he would switch the alarm
    13        off so he could come in and out of that entrance.  But,
    14        apart from that, that entrance is never used.
    15
    16   Q.   Are you trying to tell the court that the security camera
    17        system at McDonald's Headquarters does not focus on any---
    18        A.  It probably does.
    19
    20   Q.   -- place near the front entrance in the street and where
    21        the cars come out, that whole area?
    22        A.  No, where the cars come out, that is covered.
    23
    24   Q.   Right.
    25        A.  The next point covered are the main entrances to both
    26        the Head Office and Hamburger University, and then there
    27        are cameras at the rear of the building covering the fire
    28        escape entrances.
    29
    30   Q.   Your security monitors, if somebody was to, say, rob
    31        Headquarters, they would be there for identification
    32        purposes, would they not?
    33        A.  Yes.
    34
    35   Q.   So, knowing that you were trying to identify people on the
    36        picket in October 1989 for potential litigation, the
    37        security monitors that caught any protesters, or whatever,
    38        could be useful?
    39        A.  You would be much better, as we were, with a camera on
    40        the ground.
    41
    42   Q.   Yes, a camera?
    43        A.  You get much better pictures.
    44
    45   Q.   But we are talking about, apparently, only about whatever
    46        it was, 20 odd pictures, are we not?
    47        A.  I am not sure.  I cannot remember how many pictures
    48        were taken.
    49
    50   Q.   Whatever it is, whereas a video can show activities over a 
    51        long period of time? 
    52        A.  They are not good pictures. 
    53
    54   MR. JUSTICE BELL:  No, what he is saying is if you wanted to
    55        video the demonstration you would be much better with a
    56        camera on the ground, as they did later.
    57
    58   MR. MORRIS:  Right.  You were in charge of that picket, were you
    59        not, and the arrangements for that particular
    60        demonstration?

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