Day 165 - 27 Sep 95 - Page 11

     
     1   MR. JUSTICE BELL:  Yes.
     2
     3   MS. STEEL:   Firstly, I wanted to make a point in relation to
     4        what Mr. Rampton said yesterday, that what they left in was
     5        anything relating to our involvement in the anti-McDonald's
     6        campaign, anything relating to our involvement in the group
     7        generally, all references to McDonald's -----
     8
     9   MR. JUSTICE BELL:  My note was all the Defendants' attendances
    10        and contributions to meetings and all references to
    11        McDonald's, whether they helped the Plaintiffs or not, in
    12        other words, all references to the Defendants and to
    13        McDonald's were left in.
    14
    15   MS. STEEL:  Yes.  He said that where other things had been
    16        discussed, other campaigns of the group had been discussed,
    17        but our names were not specifically mentioned, those parts
    18        had been blanked out.  Because the witnesses were there for
    19        the purposes of getting information about the
    20        anti-McDonald's campaign, any other subject that came up
         would more than likely have been in brief, as is pretty
    22        apparent from the notes in any case and, additionally, the
    23        spies would have felt less need to reference who was
    24        actually talking about a particular subject.
    25
    26        Therefore, general discussions about, say, for example, the
    27        World Bank campaign, maybe organising a picket on such a
    28        such a date, might have just gone in as that, without a
    29        reference to who said that or who supported that discussion
    30        or whatever.  I remember that in that particular discussion
    31        I took an active part and that I was particularly
    32        interested in that campaign.  Therefore, that may be useful
    33        for my argument, that just by being in the group and taking
    34        part in its activities, or some of its activities, does not
    35        mean that -----
    36
    37   MR. JUSTICE BELL:  This is jogging your memory?
    38
    39   MS. STEEL:   It is not just jogging my memory, it is because the
    40        Plaintiffs have said that by being in the group, we were
         involved in the anti-McDonald's campaign, that the
    42        anti-McDonald's campaign was a main part of the group's
    43        activities.  So, if I was particularly interested in a
    44        certain campaign and particularly talking about that, that
    45        might be evidence to assist me in saying that that was my
    46        main interest and that I was not particularly involved in
    47        the anti-McDonald's campaign.
    48
    49        There is also the secondary point that it may jog my memory
    50        as to whether or not I was at particular meeting. 
    51 
    52        Mr. Rampton also said something yesterday about whether or 
    53        not McDonald's is 1 or 5 on the scale of London Greenpeace
    54        activities does not help to determine the question of how
    55        far the Defendants have been involved in the
    56        anti-McDonald's campaign.  I would say that that is
    57        incorrect because the Plaintiffs have pleaded that just
    58        involvement in the group, therefore, made us responsible.
    59
    60        A huge number of things were discussed at London Greenpeace