Day 237 - 18 04 96 - Page 29

     1        report, was it not?
     2        A.  Yes, it could have been, yes, the gist certainly.
     3
     4   Q.   The language ties in almost exactly although there are some
     5        parts -----
     6        A.  Well, it is my language in both, it would do.
     7
     8   Q.   There are some parts omitted and other parts added, but the
     9        phraseology is exactly the same?
    10        A.  It is a very short report.
    11
    12   Q.   In this you say:  "I obtained photographs of all the
    13        demonstrators and I would have them identified in due
    14        course".
    15        A.  In the event I did not.
    16
    17   Q.   Right, but you were going to get them identified by
    18        Mr. O'Hara?
    19        A.  No.
    20
    21   Q.   How were you going to get them identified?
    22        A.  In fact, I did not bother to get them identified.
    23
    24   Q.   How were you intending to have them identified?
    25        A.  Through whatever source I could.
    26
    27   Q.   Which was?
    28        A.  It could be other companies, it could be -----
    29
    30   Q.   Or the Police?
    31        A.  I doubt very much whether they would use the Police for
    32        it.
    33
    34   Q.   But you were confident that you could have all the people
    35        in the photographs identified?
    36        A.  No, I was not confident.
    37
    38   Q.   Why do you say, "and I will have them identified in due
    39        course", not "I will try to have them identified in due
    40        course"?
    41        A.  It is a -- it is a turn of phrase.  That is all.
    42
    43   Q.   You did have the means to identify the people in the
    44        photographs, did you not, without the Company needing to
    45        hire private investigators to infiltrate London Greenpeace?
    46        A.  No, I did not.
    47
    48   Q.   You just said that you had various sources so .....
    49        A.  It would have been outside.  I doubt very much we would
    50        have identified them all had I decided to spend as much 
    51        time as was necessary to identify them all.  In the event, 
    52        it turned out to be, frankly, irrelevant. 
    53
    54   Q.   Why was it irrelevant?
    55        A.  It just was not necessary.  The demonstration was
    56        over.  There were no arrests.  There was no damage to
    57        property.
    58
    59   Q.   You knew that when you wrote this report?
    60        A.  That is right.
 
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