Day 261 - 12 Jun 96 - Page 13

     
     1
     2   MR. MORRIS:  Yes.  (To the witness)  There is nothing in your
     3        notes about it, so do you know how this got into the
     4        statement?
     5        A.  As I previously said, the statement was compiled for
     6        me.
     7
     8   Q.   So, that point there about the leaflets being stored or
     9        which particular leaflets were being stored where, was not
    10        based upon your notes; it was something which the
    11        solicitors were aware of?
    12        A.  In my notes of 17th May, I mention the leaflets; and,
    13        to the best of my knowledge, they were present at every
    14        meeting I went to.
    15
    16   MS. STEEL:   Can you point to where in the notes you are
    17        referring to?
    18        A.  Yes.  I was doing that from memory.  I am reading them
    19        now.  (Pause)  I would have to read the notes from the
    20        beginning to find out where -- I really cannot remember
         now ---
    22
    23   MR. MORRIS:  You cannot remember now?
    24        A.  -- on which occasion I mention the leaflets, no.
    25
    26   Q.   But now, in the witness box, you cannot remember which
    27        leaflets were stored in which places and when they were
    28        available?
    29        A.  To the best of my recollection, the smaller leaflet as
    30        on the shelves and the larger leaflet or the longer version
    31        was in the metal filing cabinet, to the best of my
    32        remembrance.
    33
    34   MR. JUSTICE BELL:  Just pause.  (Pause)
    35
    36   MR. MORRIS:  And -----
    37
    38   MR. JUSTICE BELL:  Just pause. (Pause)  Yes.
    39
    40   MR. MORRIS:  But, regarding the version in the metal filing
         cabinet -- I have already asked you, but I will ask you to
    42        say it again -- you were not sure which version of the
    43        longer version that would be?
    44        A.  I would have only been aware of what I saw.  I would
    45        not have known what I did not see.
    46
    47   Q.   When you looked at it in the filing cabinet, did you
    48        actually look in the filing cabinet or did someone just
    49        take one out or show it to you?
    50        A.  I cannot recall the specific details. 
    51 
    52   Q.   How would you know it was the longer version?  Was it 
    53        because of the front cover, or just -----
    54        A.  It had more information in it, as far as I can recall.
    55
    56   Q.   So it was something that had more information about
    57        McDonald's?
    58        A.  Yes.
    59
    60   Q.   And therefore -- OK.   But, recalling now, you do not know