Day 001 - 28 Jun 94 - Page 24
1 I ask the question: Are the defendants' denials of
responsibility for the distribution of the leaflet
2 complained of in this action in the least bit credible?
I ask that now at this stage without your Lordship yet
3 having heard any of the oral evidence at all.
4 My Lord, if the answer to that question is no, they are
not credible, there is a further and very important
5 question: What further material will the defendants see
fit to distribute or prompt others to distribute if they
6 are not restrained by injunction?
7 My Lord, as an illustration of that problem, your Lordship
may find it helpful to look at two documents in whose
8 distribution Helen Steel is seen to have participated on
16th October 1990. I remind your Lordship that the writ
9 was issued a month before that, on 20th September 1990,
and served by a letter of that date. Your Lordship will
10 find those documents in that appendix to Mr. Terry
Carroll's second statement at volume yellow 2, tab 3.
11 Each of the documents in this appendix has written on it
in Mr. Carroll's handwriting in most cases the date when
12 it was distributed outside the second plaintiffs' head
office at East Finchley.
13
My Lord, the first document in the appendix is the leaflet
14 complained of. It is marked (or should be marked) 189.
It is the October 1989 one which is the words complained
15 of in this action. It is the foundation of the action.
The second document is what I have called the shorter
16 brother of the leaflet complained of. It should have
written in the right hand corner "Distributed outside head
17 office 16.10.90".
18 MR. JUSTICE BELL: Yes.
19 MR. RAMPTON: My Lord, I am not going to read the whole of this
for one reason, because I shrink from repeating these
20 allegations more often than I have to in a public court,
but I do draw your Lordship's attention to the fact that
21 this is simply an abbreviated or summary version of the
leaflet, longer leaflet, that I read earlier this
22 morning.
23 I draw your Lordship's attention, first of all, to the
first two sentences in the first left-hand column beside
24 the black triangle, and then a repetition of a sentence in
the leaflet as the last sentence of that paragraph.
25 I draw your Lordship's attention to the second black
triangle and the introduction "Raping the earth" and what
26 follows down to the middle of the right hand column.
Perhaps your Lordship might read the whole of that
27 column? It repeats the allegation that McDonald's forced
the tribal people off their ancestral lands, for example.
28
MR. JUSTICE BELL: Yes.
29
MR. RAMPTON: Over the page, my Lord, the first black triangle,
30 "Slaughtering the innocent", again a repetition of the
allegation that animals are often killed by a knife when
