Day 237 - 18 04 96 - Page 6

     1        were obtained?
     2        A.  I would keep a record of the leaflets obtained but,
     3        frankly, we got so many in from so many different stores it
     4        became almost unwieldy, the file, so we obviously had to
     5        prune them occasionally.
     6
     7   Q.   But you kept records -- you kept all files of all the
     8        photographs?
     9        A.  I would have done, yes.
    10
    11   Q.   What was the purpose of that?
    12        A.  It was to try to and identify whether there was a hard
    13        core of people who had problems, shall we say, with
    14        McDonald's, and if there was a theme, whether they were the
    15        same people moving around the country or whether they were
    16        different people and different areas.
    17
    18   Q.   What did you discover?
    19        A.  We discovered that, basically, it was a local
    20        operation, that occasionally we did get photographs of
    21        people who would appear in several stores which meant that
    22        there was, to a certain extent anyway, a main theme or at
    23        least a mainspring for it all.
    24
    25   Q.   When you say that "by and large it was a local operation",
    26        you mean that, generally speaking, it was local people
    27        carrying out pickets outside their local branch?
    28        A.  Yes.
    29
    30   Q.   Right.  Just this, quite a lot of leaflets from Australia,
    31        for example, in the bundles of documents which you also
    32        collated information on, protests from abroad?
    33        A.  Well, it was not so much a question of collating
    34        information; we were sent documents as obviously originated
    35        in this country by countries outside the UK where they
    36        appeared, and I think they were sent, more or less as a
    37        matter of comment or record, this was what was happening
    38        elsewhere in the world.  We kept some of them.  In fact
    39        I think we kept quite a few of them but they were
    40        principally photocopies.
    41
    42   Q.   But that was something you had requested, was it not?
    43        A.  No, I had not.
    44
    45   Q.   Why should they bring them to the UK rather than any other
    46        branch anywhere in the world, or the US?
    47        A.  Because they had originated here.
    48
    49   MR. JUSTICE BELL:  Was that before these proceedings were
    50        started in September 1990 as well as afterwards or only 
    51        afterwards? 
    52        A.  No, it was for quite a considerable period of about 
    53        four or five years before, during, and after.
    54
    55   MS. STEEL:   The photographs that you instructed or advised
    56        local stores to take, if they could, was it any more
    57        specific than protesters or was it protesters doing certain
    58        things or what?
    59        A.  It was just photographs of people who were picketing
    60        restaurants in various parts of the country.
 
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