Day 237 - 18 04 96 - Page 49

     1        regards the leaflets that were being handed out and to
     2        report the incidents back to my company and, latterly, so
     3        it transpired, to complete a statement for litigation which
     4        ensued.
     5
     6   Q.   The incident report forms that are in all the counterclaim
     7        bundles, they all go to you, do they?
     8        A.   It depends entirely what the incident is.  If it was
     9        concerned with crime or -----
    10
    11   Q.   Concerning leaflet distribution?
    12        A.  Most of them would have done, yes, although I believe
    13        some did go to the Personnel Department -- not Personnel,
    14        Public Relations.  Thank you.
    15
    16   Q.   Would Public Relations actually get incident report forms
    17        or just the leaflets that are -----
    18        A.   Well, normally speaking, there is a fairly clear
    19        system of how they should come but sometimes the system
    20        does get fouled up.
    21
    22   Q.   What was the system that is supposed to happen?
    23        A.   Well, I think you will find at the top right-hand
    24        corner of that page, certain copies go to whatever
    25        department is responsible for it.
    26
    27   Q.   For incidents -----
    28        A.   Incidents like this, they would probably send to it me
    29        although some did go to Human Resources, I think.
    30
    31   Q.   Human Resources?
    32
    33   MR. JUSTICE BELL:  PR?
    34        A.   PR -- Public Relations.
    35
    36   MS. STEEL:  We have not actually got a massive amount left and I
    37        do not know whether it would be possible to have the 5
    38        minute break or 10 minutes?
    39
    40   MR. JUSTICE BELL:   Yes.  I will come back at quarter-past.
    41
    42                         (Short adjournment)
    43
    44   MR. MORRIS:   You said what your responsibilities were as
    45        regards October 89, that demonstration about protecting the
    46        building, effectively?
    47        A.   Personnel principally.
    48
    49   Q.   If you look at photograph 21 ---
    50        A.   Yes. 
    51 
    52   Q.   -- you see the flag? 
    53        A.   Yes.
    54
    55   Q.   Is that a duty camera next to the flag on the side of the
    56        building?
    57        A.  There is one there, yes.
    58
    59   Q.   That is pointing at the demonstration, is it?
    60        A.   I cannot see which way it is pointing but there is
 
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