Day 245 - 07 May 96 - Page 19
1 Company about matters relating to the counterclaim?
2 A. I am not sure.
3
4 Q. Perhaps you would like to look at paragraph 17 of your
5 current statement?
6 A. Yes.
7
8 Q. Just read that through to yourself.
9 A. (Pause) Yes.
10
11 Q. When you made the statement, did you write down any old
12 rubbish or did you research what the situation was before
13 you made the statement?
14 A. Make reference to paragraph 16, and I think you read
15 the two together, and the matters speak very clearly.
16
17 Q. Yes, but I am asking you before you made this statement,
18 did you actually research what the situation was or did you
19 just put down any old rubbish?
20 A. I took advice.
21
22 Q. You took advice from who?
23 A. From my solicitors, lawyers.
24
25 Q. So your solicitors told you what to put in the statement?
26 A. No. I took advice from them.
27
28 Q. What do you mean? I am asking you whether, when you made
29 this statement, which is supposed to be about things within
30 your own knowledge, whether you researched it before you
31 wrote the statement or whether you just put down any old
32 rubbish?
33 A. I discussed it with the people who were involved and my
34 counsel.
35
36 Q. The situation is that your company never wrote to myself,
37 Mr. Morris, or any of the other 3 people who were issued
38 with writs until those writs were served upon us in
39 September 1990. That is correct; is it not?
40 A. That is what it says in 16. There was an error made,
41 and we have amended the pleadings accordingly, or are in
42 the process of amending the pleadings accordingly.
43
44 Q. But I am asking you specifically to confirm it is true that
45 your company, McDonald's, neither McDonald's UK nor
46 McDonald's Corporation ever wrote to myself, Mr. Morris, or
47 any of the other 3 people about the fact sheet before
48 service of the writ on us in September 1990?
49 A. I do not ----
50
51 MR. JUSTICE BELL: Do you mean those companies or their
52 solicitors?
53
54 MS. STEEL: Or the solicitors, yes?
55 A. I do not believe we did. I think it was corrected in
56 paragraph 16 and 17 as I said.
57
58 Q. Right. The only letter that your company wrote to London
59 Greenpeace, or solicitors on your behalf wrote to London
60 Greenpeace, was in 1984 and was about an entirely different
