Day 261 - 12 Jun 96 - Page 07

     
     1
     2   Q.   Why did you ask what the writs had been served for?
     3        A.  I did not know that the writs were anything to do with
     4        the job that I was connected with.  They could have been
     5        for some other purpose.
     6
     7   Q.   In the next paragraph, you say:
     8
     9        "I also quietly asked Jonathan if he knew about the writs,
    10        and he replied, 'I do not know enough about the details, so
    11        I will not talk about it in case I give the wrong
    12        impression.'"
    13        A.  Yes.
    14
    15   Q.   That is correct, is it?
    16        A.  That is what he said.
    17
    18   Q.   So why did you ask him about the writs?
    19        A.  Because at this point the people present at the meeting
    20        knew a lot more about the writs than I did.
    21
    22   Q.   But why did you need to know about the writs?  When you
    23        heard that they were from McDonald's, you knew that it was
    24        connected with the inquiry that you had been making?
    25        A.  Yes.
    26
    27   Q.   So what was the need to ask people about the writs?
    28        A.  I did not see that there was anything wrong in asking
    29        people about writs that had been served.  There was no
    30        specific need; it was just a general intelligence gathering
    31        exercise.
    32
    33   Q.   The point about the intelligence gathering being to find
    34        out for McDonald's whether or not we were going to fight
    35        the case and how we were going to fight the case?
    36        A.  Not specifically, no.
    37
    38   Q.   That was part of it, though?
    39        A.  No, that was not in my mind at the time.
    40
    MR. JUSTICE BELL:  Were the writs endorsed with the Statement of
    42        Claim?
    43
    44   MR. RAMPTON:  No.  I have said no; I think the answer to
    45        that -----
    46
    47   MS. STEEL:   What does that mean?
    48
    49   MR. JUSTICE BELL:  A writ can just have a general endorsement
    50        which says what the nature of the claim is, that they are 
    51        asking for damages and an injunction for defamation arising 
    52        out of publication of a leaflet "What's wrong with 
    53        McDonald's?", end of matter; or you can endorse on the writ
    54        of summons your whole Statement of Claim.
    55
    56   MS. STEEL:   They were served together, if that is any help.
    57
    58   MR. JUSTICE BELL:  Well, that is what I was asking.
    59
    60   MS. STEEL:  There was a letter, a writ and a Statement of Claim