Day 313 - 13 Dec 96 - Page 15


     
     1        appears to be an afterthought.  This does not give the
     2        appearance of a leaflet that was needed in order to set the
     3        record straight, as McDonald's have claimed.  It is more
     4        consistent with being a PR move to deal with customer
     5        inquiries once the trial started getting the inevitable
     6        media coverage.
     7
     8        (F), page 7, appears to have been produced in February.  It
     9        has not actually got a date on the top of it but if you
    10        look in the bottom right-hand corner it has a kind of print
    11        out reference page, or something, that says February 1994.
    12        Yes, it appears to have been produced in February after the
    13        first meeting to discuss their strategy.  It is headed
    14        "McDonald's London Greenpeace trial communications
    15        strategy"; it is not headed "Strategy for countering
    16        McLibel support campaign press releases and leaflets".  And
    17        whilst there are some matters which may be a response to
    18        matters raised by the Defendants or others, such as
    19        preventing freedom of speech, this is clearly not the main
    20        thrust of the document.
    21
    22        Obviously, in a high profile trial both parties are likely
    23        to speak to the media.  However, this does not give
    24        McDonald's the right to make statements they know to be
    25        false, or to make statements either not caring whether or
    26        not they are true, under the guise of "privileged
    27        self-defence".
    28
    29        Can I just say to this point about whether or not it was a
    30        response, it is possible that the particular point about
    31        free speech could have been a response to something raised
    32        in press releases.  However, it is equally possible that at
    33        this time it was a response to a question which kept
    34        cropping up because it is something of a question that
    35        might fairly spring to the mind of a journalist as a
    36        relevant issue to ask questions about, and that in that
    37        case, you know, the McDonald's response to this issue may
    38        in fact have been prompted by questions raised by the
    39        media.
    40
    41        I think in later documents they do mention -- in the last
    42        press release they produced they did mention the group
    43        having complained about McDonald's attempting to stifle
    44        free speech, but prior to that press release there is no
    45        indication about whether or not they are replying to
    46        printed leaflets or-----
    47
    48   MR. RAMPTON:  My Lord, I am sorry.  Ms. Steel has not got the
    49        document in front of her.  It is inevitable, therefore,
    50        that this document which she is reading from may be
    51        selective.  It is, I am afraid, selective because the very
    52        paragraph before the one she is referring to says, "to
    53        minimise the negative impact of the Defendants' evidence,
    54        witness statements and out of court activities", and that
    55        is immediately followed by the words "to counterclaim that
    56        McDonald's prevent free speech and any other inaccuracies
    57        which might arise before, during and after the trial".
    58
    59   MS. STEEL:  No, there are three bullet points under
    60        "communication objectives".  Those that Mr. Rampton read

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