Day 237 - 18 04 96 - Page 20

     1
     2   Q.   We see which way you are facing, the photographs, when you
     3        are standing on the steps?
     4        A.  Yes.
     5
     6   Q.   There was never any picket behind you?
     7        A.  No.
     8
     9   Q.   So when you say that I was handing out leaflets, can you
    10        just describe what you saw?
    11        A.  You had some leaflets in your hand and you were handing
    12        them out to passers-by.
    13
    14   Q.   Was I facing you?
    15        A.  At times you were facing; other times you were facing
    16        away; sometimes you were facing towards the road; sometimes
    17        you were looking up the road; sometimes you were looking
    18        down.  You moved around in exactly the same way as anyone
    19        did in that particular demonstration.
    20
    21   Q.   Was I within the crowd or standing ------
    22        A.  Sometimes you were in the crowd, sometimes you were on
    23        the side of it.
    24
    25   Q.   How did you identify the leaflet, I mean the particular
    26        type of leaflet that you say that I was distributing?
    27        A.  If you look at the front of it, you will see it is
    28        quite distinctive from anything else that was put there.
    29
    30   Q.   You were judging from a distance of between yourself to
    31        Mr. Rampton or 30 to 40 yards that the leaflet that you say
    32        you saw me handing out was the London Greenpeace fact
    33        sheet?
    34        A.  Yes.
    35
    36   Q.   That was because of the front cover, was it?
    37        A.  Yes.
    38
    39   MR. JUSTICE BELL:  Yesterday, when being asked questions by
    40        Mr. Rampton, Mr. Carroll spoke of a distance from him to
    41        Mr. Rampton and as far as from him down to the entrance of
    42        the tube station; a few minutes ago he said that at the
    43        closest he was to you, he was from where he is now to where
    44        you are now.
    45
    46   MS. STEEL:  You do not actually remember how far away I was?
    47        A.  You were in a group at the foot of the stairs for most
    48        of the time, which would be approximately where you are
    49        standing now, between you and Mr. Rampton.  You were as
    50        close as that most of the time you were there. 
    51 
    52   MR. JUSTICE BELL:  Just pause.  The reason I said what I did was 
    53        when this goes on the transcript, it will be particularly
    54        uninformative to anyone who reads it.  I would have thought
    55        that you are something like 20 feet, perhaps nearer 25,
    56        from Ms. Steel.  The reason I say that is that from the
    57        days when I used to be more familiar with these things, if
    58        I was shooting at a goal, you would be one goal post and
    59        she would be the other, and I know that is 24 feet, it is
    60        eight yards?
 
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