Day 237 - 18 04 96 - Page 25

     1   MS. STEEL:  -- they make observations of all Animal Rights
     2        activities, protests and things like that, not just as
     3        Mr. Carroll described it, anti-terrorist things.  (To the
     4        witness):  So it was that man in the photograph that
     5        pointed out myself and Mr. Gravett to you?
     6        A.  I think it was, yes.
     7
     8   Q.   He did not point out Mr. Clarke?
     9        A.  I do not recall him pointing out Mr. Clarke.
    10
    11   Q.   You do not recall saying, "Hello, Andrew" to
    12        Mr. Clarke ---
    13        A.  No.
    14
    15   Q.   -- towards the end of the picket?
    16        A.  No.
    17
    18   Q.   Did you ask him who we were or did he volunteer that
    19        information?
    20        A.  I think it came out in conversation.  I do not know if
    21        I asked him or whether he told me, but it was just a topic
    22        of conversation, a point that was raised during the course
    23        of the demonstration.
    24
    25   Q.   Moving onto the counterclaim document that we looked at
    26        yesterday, No 78 ---
    27
    28   MR. JUSTICE BELL:  That is in the other bundle, Mr. Carroll.
    29
    30   MS. STEEL:  -- had you ever spoken to the man in the photograph
    31        before?
    32        A.  Which photograph?
    33
    34   Q.   The man in the photograph that we have just been
    35        discussing, Mr. O'Hara?
    36        A.  Have I spoken to him -- possibly, yes.
    37
    38   Q.   During the course of your inquiries, finding out about who
    39        was responsible for protests at various stores around the
    40        country?
    41        A.  No, I would not have spoken to him about that.
    42
    43   Q.   Do you remember what else you spoke to him about?
    44        A.  No, I do not -- he is a Police Officer; I am an
    45        ex-Police Officer -- it was probably discussions more to do
    46        with the state of the Police service at the time.
    47
    48   Q.   He was not someone who you had worked with previously?
    49        A.  No, I have never worked with him.
    50 
    51   Q.   This report, what was the purpose of it? 
    52        A.  To inform the head of the Company and my immediate 
    53        superior as to exactly what had taken place.
    54
    55   Q.   For what purpose?
    56        A.  For record purpose.
    57
    58   Q.   For record purposes.  Why Mrs. Brinley-Codd?
    59        A.  Because it was a protest which was taking place outside
    60        our Head Office, and I felt that if there was going to be
 
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