Day 237 - 18 04 96 - Page 35

     1        subject of this court case was the fact sheet entitled
     2         "What's wrong with McDonald's?"
     3        A.  No, the two documents are for entirely different
     4        reasons.  The document report is intended for my superiors,
     5        to let them know what happened, the number of people who
     6        turned up, whether there was any damage to property,
     7        whether, in fact, our business was disrupted.  That is the
     8        purpose of the report.  The purpose of the statement is for
     9        a court case.
    10
    11   Q.   It does not mention that either myself or Mr. Gravett
    12        handed out leaflets?
    13        A.  Well, as I say, it is a purely factual report or just
    14        the circumstances.  As you see, it is much shorter for a
    15        start.
    16
    17   Q.   In terms of about the demonstration, I do not know that it
    18        is.  But you did not think that it was worth mentioning to
    19        Mr. Preston, Mr. Nicholson and Mrs. Brindley-Codd that
    20        myself and Mr. Gravett you claim that you had seen us
    21        handing out leaflets?
    22        A.  Yes, but by that time I did not know the Company was
    23        going to take action.
    24
    25   Q.   You must have known it was under consideration or it was a
    26        possibility because otherwise you would not have sent it to
    27        your solicitors, to Mrs. Brinley-Codd?
    28        A.  I knew it was a possibility, yes.
    29
    30   Q.   So it would be a relevant matter to have in there, had it
    31        been the truth?
    32        A.  I did not consider it necessary in a factual report to
    33        my superiors.
    34
    35   Q.   You did not mention it in the report because it did not
    36        happen?
    37        A.  It did happen.
    38
    39   Q.   You thought it worth mentioning that Mr. Gravett had got
    40        into a cow suit but not that myself and Mr. Gravett had
    41        been handing out leaflets?
    42        A.  Not as far as I was concerned, as regards the
    43        demonstration itself.  I did not think it was relevant at
    44        that time to mention that you were handing out "What's
    45        wrong with McDonald's?" leaflets specifically.
    46
    47   Q.   You do not even mention that I am handing out any leaflets,
    48        full stop, whether they be the London Greenpeace fact sheet
    49        complained of or A5 leaflets.
    50        A.  I did not consider it necessary to inform my superiors 
    51        exactly the nature of the leaflets that were handed out. 
    52 
    53   Q.   Can I just ask about the report, how did you know that
    54        I lived in the Tottenham area?
    55        A.  I think someone told me.  I did not know your address.
    56
    57   Q.   Would that be the same person, the same man in the
    58        photograph?
    59        A.  Very possibly, yes.
    60
 
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