Day 313 - 13 Dec 96 - Page 17

     
     1        leaflet produced by McDonald's was to deal with interest
     2        resulting from the trial, not as a response to an attack in
     3        McLibel support campaign, et cetera, press releases and
     4        leaflets.
     5
     6         Going on to (I), on page 12, this is the first clear
     7        mention of countering our -- that is, mine and Mr. Morris',
     8        as they have said on that page.
     9
    10   MR. JUSTICE BELL: What date is page 12?
    11
    12   MS. STEEL:   28th February 1994.
    13
    14   MR. JUSTICE BELL: Thank you.
    15
    16   MS. STEEL:   This is the first clear mention of countering our
    17        press contact, and as far as I can tell it is the only
    18        mention of us being in contact with the media in the whole
    19        of this.  That is, us personally being in contact with the
    20        media in the whole of this bundle of documents that were
         disclosed in relation to this issue.  It is only on a one
    22        to one basis that it is referred to.  It says, in case you
    23        have not got it -- have you got it in front of you or not?
    24
    25   MR. JUSTICE BELL: No, I will get it out if you want me to.
    26
    27   MS. STEEL:   It is OK.
    28
    29   MR. JUSTICE BELL:  I am concentrating on your comments at the
    30        moment.
    31
    32   MS. STEEL:   It says, "Agreed to issue Background Briefing to
    33        all national media before the start of the trial (legal
    34        correspondence wherever possible).  2, number one, ensure
    35        they have the facts so that initial articles are not biased
    36        (Defendants are holding pre-trial press briefings on one to
    37        one basis)."
    38
    39        Now, their reference is that the media contact is on a one
    40        to one basis and there is no indication that McDonald's
         considered this to be anything other than as a natural
    42        result of media interest in a high profile trial.  And also
    43        the fact remains that the briefing paper and leaflets had
    44        been discussed and effectively planned for some time prior
    45        to this in any event.
    46
    47        In conclusion, we would say that it is clear that these
    48        press releases and leaflets produced by McDonald's were
    49        purely and simply a PR exercise to deal with interest from
    50        the media and the public sparked by the trial.  The
    51        documents may have included responses to some of the issues
    52        raised in McLibel support campaign press releases et
    53        cetera, but that was not the motive for their production.
    54        McDonald's motive in producing these press releases and
    55        leaflets was to discredit the Defendants and other critics
    56        of McDonald's in the PR conflict resulting from the trial,
    57        the conflict between their image and the reality, and that
    58        being their motive the defence of qualified privilege must
    59        fail.  As stated before, the fact that a high trial
    60        inevitably attracts publicity does not give McDonald's, or