Day 313 - 13 Dec 96 - Page 12
1 demonstrations" et cetera, for many years. Aside from this
2 McDonald's has not proved that any of the witness
3 statements contained lies; that is, either my witness
4 statement or Mr. Morris's witness statement, nor that any
5 of the answers to interrogatories are lies.
6
7 Can I just say further to that point that the closest the
8 Plaintiffs got to an accusation of lying was when I was
9 questioned about the interrogatories, asking if I have
10 attended meetings of London Greenpeace at No 5 Endsleigh
11 Street, to which I answered, 'No', and how can a correct
12 answer to a question be a lie? As stated in my evidence on
13 day 277, page 56, I was given legal advice to answer 'no'
14 to that question since that was the correct answer, and as
15 stated on page 59, same day's evidence, if this was a
16 deliberate attempt to deceive the Plaintiffs because they
17 had made a mistake about the number, which is what they
18 were trying to assert in court, then why only three months
19 later would I voluntarily declare in my witness statement
20 that I had attended London Greenpeace meetings at 6
21 Endsleigh Street? There is absolutely no basis for an
22 allegation that that was a deliberate attempt to deceive.
23
24 MR. JUSTICE BELL: Yes.
25
26 MS. STEEL: (C), recording the comment in the left margin,
27 about our attempt to distance ourselves from the
28 anti-McDonald's campaign in the leaflet, the simple fact is
29 that neither of us were involved in the running of the
30 anti-McDonald's campaign nor in production and distribution
31 of the fact sheet. And that is shown by the evidence not
32 only of our witnesses but of the inquiry agents that
33 McDonald's sent in to infiltrate the group.
34
35 Just on page 4 of Mr. Rampton's submission, this is just a
36 legal point really: in terms of the comment in the note in
37 the margin on that page and in terms of all the other
38 documents that are listed on that page, although I agreed
39 in evidence that I have distributed A5 leaflets there is no
40 evidence to show distribution of the particular leaflet set
41 out on the page. Not all of them are anti-McDonald's
42 leaflets, some of them are about the campaign and other
43 things, I think. I have not actually looked them all up to
44 check, but there has been no evidence to connect us, either
45 of us, to each of those documents.
46
47 Also, just on point 5 on that page, in terms of their
48 charges (B) and (C), if it is their (B) and (C) we do not
49 accept this -- in fact, they say it is their pleaded
50 meaning (B) and (C) -- because the press releases and
51 leaflets referred to 'the' leaflet, i.e. the fact sheet
52 that is the subject of this action, not other leaflets.
53
54 Paragraph 3.3: in terms of what Mr. Rampton says here,
55 whilst failing to answer a solicitors' letter may not in
56 some circumstances be thought to be a very serious matter
57 or allegation to make, failure to answer several, which is
58 what the Plaintiffs alleged in their press releases and
59 leaflets about us, is clearly an attempt at portrayal of
60 being unreasonable and ignoring the truth, et cetera, which
