Day 306 - 26 Nov 96 - Page 25


     
     1        Line 13, "well, who wrote the statement, was it you or the
     2        solicitors?"  Answer, "I and the solicitors, I believe."
     3        Anyway, that is all with Mr. Clare.
     4
     5   MR. JUSTICE BELL:  Right.
     6
     7   MS. STEEL:   Going on to the picket of 16th October 1989 outside
     8        McDonald's head office, I gave evidence on day 275,
     9        page 11, about having attended the picket and that it was
    10        my recollection that I had been holding a banner and taking
    11        some photographs and that I did not recall handing out any
    12        leaflets on that demonstration, and also that I do not
    13        recall ever having handed out the fact sheet which we are
    14        being sued over.  I should say that if I believed that I
    15        had handed out the fact sheet I would not be ashamed of
    16        admitting it.  I am not ashamed of the fact sheet.  I do
    17        believe that it is true.
    18
    19        However, the reality is that the fact sheet, as I gave
    20        evidence and as Mr. Gravett and Miss Laporte gave evidence,
    21        was not intended for general distribution to the public,
    22        and I did refer in my evidence to the fact that whilst this
    23        decision had been made prior to my becoming involved with
    24        London Greenpeace, I did recall it being referred to on a
    25        number of occasions at meetings of London Greenpeace when
    26        people were talking about the history of the campaign or
    27        referring to the fact sheet, that it was not that the fact
    28        sheet was not for mass distribution, that it was for
    29        specific inquiries, because it cost so much to print and
    30        because it was considered to be too long for people, sort
    31        of, to take in if they were handed it on the street.
    32
    33        Now, obviously, we were asked interrogatories and, as far
    34        as I know, they are not evidence, are they, anyway, unless
    35        they are put in as evidence?
    36
    37   MR. JUSTICE BELL:   No.  But like anything else which is
    38        apparently a statement made by a witness it can be put to
    39        them for the purposes of cross-examination.
    40
    41   MS. STEEL:   Right.  Well, I don't actually think Mr. Rampton
    42        asked me about that interrogatory, but in any event the
    43        reason why I did not give a categoric "no" to the
    44        interrogatory was that they were asked three years after
    45        the event and at that stage -- I am just trying to find
    46        something, sorry.
    47
    48        Yes, I said this in evidence on day 275, page 12, "The only
    49        possibility is that at some stage on the demonstration
    50        somebody said to me something like, 'Oh, that person over 
    51        there is interested, do you mind just going and giving him 
    52        a copy of this'.  And that could be either the London 
    53        Greenpeace fact sheet or the Veggies fact sheet."  As far
    54        as I am concerned that is the only possibility that was
    55        countenanced by the answer given in the interrogatory, and
    56        my evidence on the day is that it is my firm belief that I
    57        did not hand out even one copy of the fact sheet, of the
    58        London Greenpeace fact sheet, on that day and that
    59        certainly I was not distributing it en masse as described
    60        by Mr. Nicholson and Mr. Carroll, and that is basically a

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