Day 240 - 24 Apr 96 - Page 05

     
     1   MR. MORRIS:  Yes.
     2
     3   MR. JUSTICE BELL:  I am not objecting to any of the rest which
     4        does in fact include what you ought to be trying to get
     5        over.  There are some parts of the rest which are
     6        objectionable on the same basis, but I am not prepared to
     7        tease out a sentence here and a sentence there, so I have
     8        only raised the point in relation to whole paragraphs or
     9        whole sections which are not, in my view, evidence of fact
    10        or true expert opinion.  Tell me the parts which you are
    11        particularly concerned with.
    12
    13   MR. MORRIS:  We are going to check them together.  We will do it
    14        independently because we briefly skipped through it.
    15        I think that on page 5, the first paragraph, 6.5, because
    16        obviously we are going to look at the documents anyway that
    17        came out of the meeting that Mr. Secrett had with
    18        McDonald's, and so that paragraph, we would say, would be
    19        relevant.
    20
    MR. JUSTICE BELL:  Yes.
    22
    23   MR. MORRIS:  The paragraph on page 6, the bottom paragraph.
    24
    25   MR. JUSTICE BELL:  Just let me make a note.
    26
    27   MR. MORRIS:  I think that, for example, Mr. Secrett may have
    28        knowledge of Dr. Myers and ----
    29
    30   MR. JUSTICE BELL:  Yes?
    31
    32   MR. MORRIS:  Which would go over, so that would be one.
    33
    34   MR. JUSTICE BELL:  I am not unreceptive to this.  I just want
    35        you to draw my attention to the parts that you are
    36        particularly ----
    37
    38   MR. MORRIS:  Those two paragraphs there and I think paragraph 7.
    39
    40   MR. JUSTICE BELL:  Page 7?
    41
    42   MR. MORRIS:  Page 7, paragraph 7.  The first paragraph is not
    43        strictly referring to evidence in this case.
    44
    45   MR. JUSTICE BELL:  Let me just read that (Pause).
    46
    47   MR. MORRIS:  Mr. Secrett will rely on other correspondence with
    48        Friends of the Earth as well which has been disclosed.
    49
    50   MR. JUSTICE BELL:  You carry on with your argument but paragraph 
    51        7, number 7, really just highlights the point I have been 
    52        trying to make.  It is for me to decide whether it is 
    53        highly significant and I cannot accept from a witness that
    54        it is highly significant.  That is why I am here.
    55
    56   MR. MORRIS:  If a witness has been in discussions with a
    57        multi-Corporation, and members of his organisation have
    58        written asking for information from McDonald's Corporation
    59        and have not been provided with satisfactory answers at
    60        other times ----