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     1        statement but it was actually made from notes I had made
     2        shortly afterwards taken by Mrs. Brinley-Codd.
     4   Q.   Are they the notes that Mr. Rampton referred you to
     5        yesterday in the counterclaim documents?
     6        A.  No.
     8   Q.   What notes are these?  Can you just explain?
     9        A.  Well, they were -- Mrs. Brinley-Codd came to the Head
    10        Office and took some notes within a couple of days of the
    11        1989 demonstration.  She obviously had other work to do and
    12        other statements to take, and she came back and we did the
    13        statement in 1993.
    15   MR. JUSTICE BELL:  Are you saying that you had made the notes
    16        soon afterwards and Mrs. Brinley-Codd took those, or she
    17        took notes when she came to see you?
    18        A.  She took notes when she came to see me.
    20   MS. STEEL:   That was in 1989?
    21        A.  Yes.
    23   Q.   So at that time you were considering bringing proceedings
    24        against -----
    25        A.  I cannot answer that.  I do not know, quite honestly.
    26        It was not discussed until later.
    28   Q.   I do not know, had you had any kind of similar meetings
    29        about previous pickets?
    30        A.  No.
    32   Q.   So this statement was drawn up by Mrs. Brinley-Codd or
    33        someone at the solicitors' office?  It was not written by
    34        you?
    35        A.  Correct.
    37   Q.   Right.  Did you go in again in 1993, before the statement
    38        was drawn up?  Or was your first contact in 1993 about
    39        this, after a draft was already prepared?
    40        A.  I cannot honestly remember.
    42   Q.   If I just ask, you say that prior to joining the Company
    43        you were employed for 30 years by the Metropolitan Police,
    44        retiring in 1984 with a rank of Chief Superintendent, where
    45        were you based?
    46        A.  What, for the last years, or the whole service?
    48   Q.   Were you just like a normal officer, or were you in a
    49        specialised department?
    50        A.  I was a uniformed officer throughout my service. 
    52   Q.   Right.  Was that in the same area as Mr. Nicholson? 
    53        A.  I was for a time in the area with Mr. Nicholson, yes --
    54        for a period of about three years.
    56   Q.   Was that at the end, just before you left?
    57        A.  No, that was in 1981.
    59   Q.   For three years?
    60        A.  Well, it finished in 1981.  I was promoted in 1981.