Day 237 - 18 04 96 - Page 52

     1
     2   Q.   That is the point I am trying to make.
     3        A.   Yes.
     4
     5   MR. JUSTICE BELL:   What I am putting, you first of all said you
     6        distinguished Animal Liberation Front, but you sometimes
     7        used it just to mean those demonstrating for animal welfare
     8        in one way or another?
     9        A.   It is verbal shorthand.
    10
    11   MS. STEEL:  Your file about Animal Rights protestors or any
    12        pickets of your stores -- I mean, the leaflets are not even
    13        specifically just about animals?
    14        A.   Which leaflets?
    15
    16   Q.   For example, the one right behind it, it is not
    17        specifically just about animals.  It is just a general
    18        criticism of McDonald's.
    19        A.   That one?
    20
    21   Q.   Yes.
    22        A.   Yes.
    23
    24   Q.   All these used to be filed in a file called the Animal
    25        Liberation Front file; is that not right?
    26        A.   Well, it got quite large towards the end.  In fact,
    27        there were several files.  They were all sent across to our
    28        solicitors a couple of years ago but, yes, I used to keep
    29        them, as far as I could, in chronological order.
    30
    31   Q.   But all the reports of general protest against McDonald's
    32        were all put in this file, ALF?
    33        A.   Yes, I do not know if it was exactly called ALF but it
    34        was something along those lines anyway.  It was a file that
    35        I knew as the Animal Rights Movement file.
    36
    37   Q.   It is just that I have seen, for example -- actually I
    38        cannot find an example to hand, but I have seen quite a few
    39        examples of where it just says -- here is one, tab 53 at
    40        the top of the page, "ALF file please."  That is a copy of
    41        the ---
    42        A.  Yes.
    43
    44   Q.   -- London Greenpeace fax sheet?
    45        A.   Yes.
    46
    47   Q.   As far as you were concerned, it did not really matter
    48        where the criticism was coming from.  It could all be
    49        lumped together as Animal Liberation Front -----
    50        A.   Activities. 
    51 
    52   Q.   Yes. 
    53        A.   Yes.
    54
    55   Q.   I just wanted to ask one final question which is in the
    56        counterclaim bundle file II?
    57        A.   This one?
    58
    59   Q.   No, it is actually pink.  It has the same sort of label as
    60        the one that you are putting down, pink and white.
 
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