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     1   MR. JUSTICE BELL:   On the first page, do you mean?
     2
     3   MS. STEEL:  No, you have got the right one, but it is just above
     4        that.  I did not call that a paragraph because it was only
     5        one line.  That is all.
     6
     7   MR. JUSTICE BELL:  The one in bold?
     8
     9   MS. STEEL:  Yes.  "Supporters of Greenpeace may arrange
    10        demonstrations outside some restaurants/offices.  You
    11        should have already received advice from the Security
    12        Department.  Please read this carefully and brief your
    13        management team so that we can take the appropriate action,
    14        if necessary."   What was the advice that the Security
    15        Department was giving out?  Was that more collating of
    16        leaflets, photographs?
    17        A.   That was part of it.  It is an advice I sent out every
    18        year before 16th October, alerting -- first of all,
    19        alerting all the restaurants and the Regional Offices of
    20        the fact that there would be a demonstration outside Head
    21        Offices and outside some of our restaurants.  All it was
    22        was a common sense guide as to what to do if the restaurant
    23        is picketed, if demonstrators turn up, what the level of
    24        the demonstration would be, whether the Police should be
    25        called and the general sort of action they should take
    26        should they be entered by London Greenpeace demonstrators
    27        or any of that lot.
    28             It was a general theme as regards the general action
    29        to be taken; plus the fact, of course, that if there were
    30        any leaflets to be distributed, I would have appreciated
    31        what they were and to notify Head Office of any
    32        demonstration.
    33
    34   Q.   When you say "London Greenpeace demonstrators", you just
    35        mean people who are demonstrating in support of London
    36        Greenpeace?
    37        A.   Correct.
    38
    39   Q.   While we are in this bundle, you talked about the Animal
    40        Liberation Front earlier.  That is something of a phrase
    41        which you use pretty loosely, is it not, to describe any
    42        Animal Rights protestors, or even any people protesting
    43        against McDonald's?
    44        A.   No, the Animal Rights Movement, as far as I am
    45        concerned, is the militant movement.  A lot of people who
    46        demonstrate outside our stores are people whose sympathies
    47        are with animals, I accept that, but they are not in the
    48        militant venin as the Animal Liberation Front or the Animal
    49        Rights Movement -- Animal Liberation Front are.
    50 
    51   Q.   I just wonder, because if you turn to tab 47, I mean, this 
    52        is called "An Animal Liberation Front day of action on 16th 
    53        October 1995"?
    54        A.   Yes.
    55
    56   Q.   On the second page it says:  "Approximately six ALF
    57        demonstrators outside the entrance to the store handing out
    58        leaflets; no attempt to enter the store".
    59        A.   That, frankly, is a shorthand version of saying six
    60        animal protesters demonstrating outside the store.
 
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