Day 248 - 13 May 96 - Page 32


     
     1   Q.   Which was?
     2        A.  Giving out of leaflets.  I think, I am not sure, if it
     3        was this one, the 88 or one other one where there were
     4        people dressed up in a cow suit and there was stuff about
     5        'picket McDonald's' being either distributed or talked
     6        about, certainly the giving out of leaflets was something
     7        he commented on.  I seem to remember him talking about
     8        piles of leaflets that people could pick up if they wanted,
     9        or they were being given out as well.
    10
    11   Q.   He did not say anything to you about having spoken to
    12        anybody or tried to find out who was involved, or anything
    13        like that?
    14        A.  I do not recall.  He may very well have said "I spoke
    15        to people while I am there".  I do not remember though.
    16
    17   Q.   Were you aware of Mr. Nicholson visiting Caledonian Road
    18        bookshop?
    19        A.  Yes.  That he attempted to find out ----
    20
    21   Q.   The Greenpeace address?
    22        A.  Yes, yes.
    23
    24   Q.   What did he tell you about that?
    25        A.  I think he said to me there was a shop above which were
    26        some offices, there was no one there at the time.  I do not
    27        know that he told me anything more than that.
    28
    29   Q.   Why did not the Company decide to take any action after
    30        that?
    31        A.  I said to you earlier, the catalyst for me is now life
    32        and limb of people who are endangered with the links with
    33        Animal Liberation Front and this thing got frighteningly
    34        acute.  At that point in time it could not be left just to
    35        'Oh, eventually it will go away, eventually it will go
    36        away', it was now endangering people.  I could not let that
    37        go unanswered.
    38
    39   Q.   The threatening letter that your company says it sent to
    40        London Greenpeace in 1984, threatening legal action, that
    41        was before you had seen any leaflet of London Greenpeace
    42        aims and objectives was it not?
    43        A.  Yes.
    44
    45   Q.   In reality, your company did not see the London Greenpeace
    46        aims and objectives leaflet until after the writ...  Well,
    47        after you had already hired private investigators?
    48        A.  Well, I am not sure about that date.  I am not sure
    49        that is true.  I could not confirm it, and I certainly
    50        could not deny it.  I am not sure. 
    51 
    52   Q.   If you cannot confirm and you cannot deny then you are not 
    53        in a position to say that leaflet is the reason why you
    54        decided to take action against London Greenpeace are you?
    55        A.  I am sorry, it played an immense part in the decision
    56        to go to court.
    57
    58   Q.   Right so you are saying now it was a part of the decision
    59        to go to court, but you had already decided to hire private
    60        investigators precisely for that purpose?

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