Day 308 - 28 Nov 96 - Page 04
1 allegation that myself and Mr. Morris are guilty of
2 deliberate deceit or reckless deceit and that we intend to
3 continue to deceive the public. Now, the answer actually
4 says answer 21, but if you look over the page there is
5 another answer 21. That is a mistake there, that
6 answer 21; it should be answer 20.
7
8 Anyway, if you look at the question 20 and the answer 20
9 (which is labelled 21), you see from the answer that
10 McDonald's are trying to rely on "encouragement of people
11 to stand up for what they believe in and to continue
12 protests against McDonald's rather than giving into
13 bullying", to say that this shows deliberate or reckless
14 deceit.
15
16 Now, I just wanted to say at this point that I am not
17 actually sure that you can have reckless deceit. To me,
18 "deceit" is a word which includes intention, and it is to
19 purposely mislead. I do not really see how you can
20 recklessly do something on purpose.
21
22 But, anyway, it is a contradiction to suggest that
23 encouraging people to stand up for what they believe in is
24 an incitement to get them to deceive the public.
25
26 MR. JUSTICE BELL: Sorry, which answer are you looking at now?
27
28 MS. STEEL: It is at the bottom of page 20.
29
30 MR. JUSTICE BELL: Yes.
31
32 MS. STEEL: It is labelled "21", but it is supposed to be
33 answer 20.
34
35 MR. JUSTICE BELL: I follow that.
36
37 MS. STEEL: I will explain it in a second. The example that is
38 quoted by McDonald's makes it clear what the intention and
39 the belief is, and, if you see, it says: "See, for example,
40 document 21 in the McLibel file." Then it says: "The trial
41 will be a platform for dozens of defence witnesses to
42 expose the truth about McDonald's."
43
44 Now, how can wanting to expose the truth be considered an
45 attempt to deceive? It is a complete contradiction.
46
47 MR. JUSTICE BELL: I think what they are intending to say is
48 that you may call it a truth, but they say it is not the
49 truth, and ---
50
51 MS. STEEL: I understand that that is their -----
52
53 MR. JUSTICE BELL: -- that is the expression that you intend to
54 carry on saying what you call the truth but which is not.
55 That is all.
56
57 MS. STEEL: I understand that their position is that it is not
58 the truth. However, it is impossible for them to say --
59 they are relying on this to say that we are guilty of
60 deliberate deceit. Now, they cannot say that we or other
