Day 313 - 13 Dec 96 - Page 16

     
     1        out were two of them, and they are two separate points and
     2        out of court activities could include anything, such as
     3        pickets of McDonald's stores, which as we have seen from
     4        other documents the Plaintiffs were expecting.  Or it could
     5        include anything anyway, it is completely unspecific.
     6
     7        Anyway, the point I am making is that it could be a
     8        response to either, there is no specific evidence that it
     9        was a response to a McLibel support campaign press release,
    10        for example.
    11
    12   MR. JUSTICE BELL: I suggest you carry on through your points,
    13        Ms. Steel, because I will read all these documents in full
    14        in any event.
    15
    16   MS. STEEL:   Say that again?
    17
    18   MR. JUSTICE BELL: I have seen them all already.  I do not have,
    19        I must confess, a very clear recollection of their detail
    20        now so I will read them all again with your points in mind.
    21
    22   MS. STEEL:   Did I get to the end of paragraph F or not?
    23
    24   MR. JUSTICE BELL:  I have read to the end of paragraph F.
    25        I think you did.
    26
    27   MS. STEEL:   Yes.  It does not give them the right to make
    28        statements they know to be false or not caring whether or
    29        not they are true under the guise of privileged
    30        self-defence.
    31
    32        (G), page 9, this is entitled, "London Greenpeace
    33        Discussion Paper for PR Brainstorm".  Sorry, it is entitled
    34        "London Greenpeace Discussion Paper", and then it says
    35        "this paper is intending to prompt discussion at our PR
    36        brainstorm on Monday, 28th February".
    37
    38        There is nothing there about answering McLibel support
    39        campaign press releases.  This is purely and simply about
    40        developing a strategy for dealing with media interest
         resulting from the trial.  Also on this page, at No. 2, it
    42        should be noted that it states, "should we produce a
    43        briefing paper for media that can be faxed quickly in
    44        response to inquiries, or offered pro-actively to a
    45        selected number of target journalists, the briefing paper
    46        would simply give the rationale behind McDonald's bringing
    47        the action".
    48
    49        Now, offering something pro-actively to a selected number
    50        of target journalists is hardly indicative of a response to
    51        an attack in McLibel support campaign press releases, et
    52        cetera.  The same applies to the final sentence of
    53        paragraph 2 on that page of the document.
    54
    55        (H), page ten.  This page says "local media coverage" and
    56        then underneath it says, "What impact will local coverage
    57        have on restaurants and how will staff deal with customer
    58        questions.  Should we have a leaflet prepared for handing
    59        out in response to questions or even included in the
    60        leaflet dispensers?"  Now, here is clear evidence that the