Day 237 - 18 04 96 - Page 40

     1   Q.   Why do you remember that there were pickets on those dates?
     2        A.   I am not positively certain, but I imagine -- I think
     3        I have read something since, but my whole recollection of
     4        '87/88 is extremely hazy.
     5
     6   Q.   So, you do not even know that it is from your own
     7        knowledge?
     8        A.   That is correct.
     9
    10   Q.   You said that on those pickets people must have handed out
    11        the leaflets, the London Greenpeace fact sheets.  Why must
    12        they have done?
    13        A.   Sorry, which pickets?
    14
    15   Q.   The October 1987 and '88, you said yesterday that they must
    16        have handed out leaflets.
    17
    18   MR. RAMPTON:   Leaflets, yes.  I am not at all sure that
    19        Mr. Carroll said that he thought they handed out the
    20        leaflet complained of.  He just said "leaflets."
    21
    22   MS. STEEL:   All right, then.  You said they must have handed
    23        out leaflets.  Why must they have done?
    24        A.   Basically, because that was the way that pickets used
    25        to behave.
    26
    27   Q.   So, you just assumed that that is what was going on?
    28        A.   '87 and '88.  As I say, my recollection of both
    29        pickets is fairly hazy.
    30
    31   Q.   But the point is that yesterday, when you said that, you
    32        were just assuming that they would have been handed out?
    33        A.   I was, yes.
    34
    35   Q.   Can I just ask, behind your statement, your second
    36        statement, the leaflet that is numbered number 11 behind
    37        you -- I do not know whether yours will be -- it says
    38        16.10.91 at the top.
    39
    40   MR. JUSTICE BELL:   Let us just pause for a moment.
    41
    42   MS. STEEL:   TEC1.
    43
    44   MR. JUSTICE BELL:   You have that, TEC5, do you?
    45        A.   TEC1, I have, number 11.
    46
    47   MR. JUSTICE BELL:   I thought you said behind the second
    48        statement?
    49
    50   MS. STEEL:   Yes, but in the top right-hand corner of the 
    51        leaflet. 
    52 
    53   MR. JUSTICE BELL:  I see, yes.
    54
    55   MS. STEEL:  Is that your handwriting?
    56        A.   The TC1 is mine but the 16.10.91 is not.
    57
    58   Q.   Right.  If you keep your hand in that one and go back to
    59        the appendices to TEC2 to your first statement -- sorry --
    60        on page 41 of the bundle?
 
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