Day 237 - 18 04 96 - Page 48

     1   THE WITNESS:  I am sorry, I cannot help you. I do not recognize
     2        my voice or anybody else's there.  In fact, I could not
     3        even hear what was said.
     4
     5   MS. STEEL:  If you could go back to the witness box?
     6
     7   MR. JUSTICE BELL:   Yes.
     8
     9   MS. STEEL:   Mr. Carroll, you have spoken to me on a lot of
    10        demonstrations, pickets at your Head Office, have you not?
    11        A.  Once or twice, yes.
    12
    13   Q.   No, more than once or twice -- quite frequently, yes?
    14        A.   Yes, yes.
    15
    16   Q.   The reality is, is it not, Mr. Carroll, that, as was said
    17        by -- well, I still contend that it is you but it is
    18        obviously someone standing over where the video camera is,
    19        so somebody from your department, there was an undercover
    20        lady or undercover agents who were attending pickets, were
    21        there not?
    22        A.  These particular ones?
    23
    24   MR. JUSTICE BELL:   Start with any of the pickets outside the
    25        Head Office, so far as you were aware, because you can only
    26        be asked of your own knowledge?
    27        A.   As far as I am aware, I had no knowledge of the
    28        identity of anybody on behalf of this company outside it.
    29        I did not know their identity.
    30
    31   Q.   Did you know whether there was anyone working under cover,
    32        as it were, on behalf of the company, taking part in the
    33        demonstration?
    34        A.   I was not specifically told, but I did suspect there
    35        was somebody there but I had no idea who it was.
    36
    37   Q.   Which demonstration or demonstrations was that?
    38        A.   That would have been the 1989 one, 1991, May and
    39        probably 1991, October.
    40
    41   Q.   October 91?
    42        A.   Yes.
    43
    44   MS. STEEL:   Can I just ask, as well as leaflets going to the
    45        Security Department, copies were also sent to the Public
    46        Relations Department, were they not?
    47        A.   Very possibly, yes.
    48
    49   Q.   Sometimes, for example, Miss Bensilum sent on a copy to
    50        you? 
    51        A.   That would have been the case, yes.  I was about to 
    52        add that. 
    53
    54   Q.   Can I just clarify your responsibilities at the time of the
    55        October 1989 picket, your responsibilities as Head of
    56        Security?
    57        A.   My principal responsibility was the care of the fabric
    58        of the building, members of the staff, and to ensure there
    59        was no disorder which might disrupt the Company or its
    60        operations.  Secondary was to see what was happening as
 
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