Day 249 - 14 May 96 - Page 41

     
     1
     2   Q.   Whoever it is, who's writing a message to Mr. Carroll's
     3        secretary, was hoping to get information on a regular basis
     4        but was told that it was only available sporadically?
     5        A.  Yes, that suggests to me it has something to do with
     6        animal rights, but I do not know.  I really am speculating.
     7
     8   Q.   Right.  Why would that suggest to you it was something to
     9        do with animal rights?
    10        A.  Because it says 'Animal Rights National Index'.  That
    11        is all they deal with, they are not interested in this case
    12        other than peripherally.
    13
    14   Q.   OK.  That is about it.
    15
    16   MR. JUSTICE BELL: Yes.  We will break there until two o'clock.
    17
    18                        (Luncheon adjournment)
    19   MS. STEEL:   I am handing up a copy of the document that was
    20        referred to this morning.
    21
    22   MR. JUSTICE BELL:  Thank you.  (Handed).  I think I have said
    23        when you were in the witness box before, if you want to sit
    24        down at any stage, Mr. Nicholson, pull the chair forward.
    25        A.  Thank you, my Lord.  I am more comfortable standing.
    26
    27   MS. STEEL:   (To the witness):  The leaflet, which is the
    28        subject of this action, first came into your possession in
    29        1987, you say.  Presumably, all the ones that were sent to
    30        the security department you would have seen?
    31        A.  No, not necessarily.  I was quite happy for Terry
    32        Carroll to keep them as long as he did not dispose of them,
    33        but he did keep them.
    34
    35   Q.   Right.
    36        A.  I certainly did not see them.
    37
    38   Q.   You were giving him instructions to keep copies of every
    39        leaflet that got sent in?
    40        A.  Whatever came in, yes.
    41
    42   Q.   Presumably, some sort of record of where it came from?
    43        A.  If he had it.
    44
    45   Q.   Yes.  So, all the leaflets which the Company received would
    46        have been kept and would be in the trial bundles, or are
    47        there some that your Company has held back and not
    48        disclosed?
    49        A.  I am not sure.  No, there were none that we
    50        deliberately held back.  I do remember Mr. Carroll -- well, 
    51        this is hearsay -- telling me that Barlows came and cleared 
    52        out all of his documentation. 
    53
    54   Q.   Right.  They came to your offices and took the whole -----
    55        A.  Everything away, as I understand it; yes, everything
    56        away.
    57
    58   Q.   In order to prepare for this case?
    59        A.  In preparation for this case, yes.
    60