Day 237 - 18 04 96 - Page 7

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     2   Q.   You did not ask them to specifically get photographs of the
     3        people who were handing out leaflets or anything like that?
     4        A.  Not particularly.  Can I say there were very few
     5        photographs taken of people outside the restaurant
     6        basically because there were very few times we had occasion
     7        to find a camera handy.
     8
     9   Q.   So there is not a camera in every store waiting to be used?
    10        A.  No, there is not.
    11
    12   Q.   Were you aware of any of this information being used to
    13        take any kind of legal action against any of the local
    14        groups around the country?
    15        A.  No.
    16
    17   Q.   I did not ask that very well; is that no, that it did not
    18        happen or no, that you are just not aware of it but it may
    19        have happened?
    20        A.  Could you ask the question again?
    21
    22   MR. JUSTICE BELL:  Were you aware of photographs being used to
    23        take action against people in different parts of the
    24        country?
    25        A.  I was aware that photographs which were taken at the
    26        time were not used to take action against any people in the
    27        country.
    28
    29   MS. STEEL:  What about leaflets that were collected or
    30        information collected about the pickets?
    31        A.  Nothing at all.
    32
    33   Q.   Nothing was ever used for the -----
    34        A.  No, it was purely for an internal matter so that I or
    35        my colleagues could identify people who might have had
    36        reason to have some problem with McDonald's.
    37
    38   Q.   Were there discussions that you were aware of about taking
    39        any kind of legal action or writing threatening letters
    40        from solicitors threatening legal action to any of the
    41        groups that were leafleting?
    42        A.  Not those that were leafleting, as far as I remember
    43        anyway, but certainly we did initiate letters to people who
    44        actually, in our view, libelled us or had some problem
    45        against us which was actionable.
    46
    47   Q.   Right, so far as you are aware, that was separate to this
    48        collecting of information on pickets?
    49        A.  Yes.
    50 
    51   Q.   So was that mainly related to magazine articles or 
    52        students' magazines, or green magazines, or things like 
    53        that?
    54        A.  That is right, yes.
    55
    56   Q.   Of course, organisations like the BBC and The Guardian and
    57        so on?
    58        A.  There were one or two, yes.
    59
    60   Q.   Were you part of the discussions about taking legal action
 
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