Day 185 - 07 Nov 95 - Page 25
1 MR. JUSTICE BELL: No, if I did say that, then it may have
2 crossed my mind that someone at the NLRB had said: "If you
3 want to intervene, you ought to write a letter along these
4 lines", just as if someone who was acting for themselves
5 goes into the County Court office, they get a bit of free
6 advice from one of the people working in the office there,
7 but I did not know whether that was so.
8
9 MS. STEEL: Right, OK.
10
11 MR. JUSTICE BELL: When I was saying be wary of going into much
12 detail, if it is your case that, for instance,
13 Mr. Ballantyne or someone had said: "Scurry round and get
14 as many people as you can to write letters saying that they
15 did not really need to sign the cards after all", you
16 should put that, sort of, main feature to the witness
17 rather than a lot of more peripheral detail.
18
19 MS. STEEL: The impression I got from the witness, which I do
20 not know whether it is the right one, was that the green
21 forms said what kind of information you needed to include,
22 but the witness actually drew up a draft letter with just
23 those basic things in it which she then showed to other
24 people.
25
26 MR. JUSTICE BELL (To the witness): Is that so or not?
27 A. The green sheets had, like, stuff on it and then it had
28 a A, B, C or D, the green sheets had that, but mine did
29 not. The John Doe letter just that had those few sentences
30 and, you know, make sure to write down if you mention any
31 names, their address and phone number.
32
33 MR. JUSTICE BELL: What, if anything, did you say to any of the
34 other young people who were contemplating writing a letter
35 about whether they should include a ground A, B, C, or D?
36 A. I did not talk to them about what they should put in
37 their letters.
38
39 MS. STEEL: Did you show the other employees the green form or
40 would they have looked at it in the store anyway?
41 A. It was in the crew room. There was, I think there was
42 a -- well, I am not sure how many copies. I think there
43 was two or three hanging in the crew room. I do not know.
44
45 MR. JUSTICE BELL: The reason if you are suggesting that
46 Mr. Ballantyne does have a part in motivating this you
47 should put it is that if you do not put it, I am certainly,
48 unless you call a witness who positively says that he did
49 from their own knowledge, I am not going to have any
50 evidence to that effect.
51
52 MISS STEEL: Right.
53
54 MR. JUSTICE BELL: You may say, well, draw the inference, but if
55 you are going to ask me to draw an inference like that, it
56 is best to put it to a witness so it is out in the open, as
57 I have said before in other contexts.
58
59 MS. STEEL: OK. (To the witness): Did Cam say anything
60 directly to you about doing these letters?
