Day 250 - 15 May 96 - Page 10

     
     1        responsibility to make sure we had them covered, and then
     2        eventually the file would be seen by our solicitors who
     3        would take out of that that which they felt assisted the
     4        case.  But everything was kept.  I mean, nothing would be
     5        thrown away.
     6
     7   MS. STEEL:   Inside that bundle of documents there is a copy of
     8        the Veggies version of the fact sheet, and you will have
     9        seen that at the time?
    10        A.  I had probably seen that before in any case.
    11
    12   MR. MORRIS:  It is in the middle of that bundle?
    13        A.  I probably seen that in any case.  Yes, Veggies
    14        catering campaign.
    15
    16   MS. STEEL:   Then on in tab 127 is a letter which was sent to
    17        Mr. Ed Oakley, on 18th February 1994, from Kitchen Range
    18        Foods?
    19        A.  Yes.
    20
    Q.   He passed on a copy to you; is that right?
    22        A.  Yes.
    23
    24   Q.   It says, "It seems these leaflets are still being given
    25        out" and there is a copy of the Veggies short version of
    26        the leaflet?
    27        A.  Yes.
    28
    29   Q.   Again, that was something you were interested in?
    30        A.  It would go on file, along with all the others.
    31
    32   Q.   Right.  If we just note, it says, 'it seems these leaflets
    33        are still being given out'?
    34        A.  Yes.
    35
    36   Q.   The Veggies leaflet.  So, basically, the situation is that
    37        for either the purposes of this case or for just your files
    38        generally, you and the Company, McDonald's, were interested
    39        to finding out what leaflets were being given out when?
    40        A.  Yes.
    41
    42   Q.   Right.  So, why was it you said yesterday you did not take
    43        any notice of which leaflets were being handed out on the
    44        picket on 16th October 1990?
    45        A.  Because we would get copies and they would go on the
    46        file.
    47
    48   Q.   It would have been interesting to find out who was handing
    49        out what would it not?
    50        A.  Not particularly. 
    51 
    52   Q.   If I was handing out copies of the fact sheet which you 
    53        were suing over?
    54        A.  No.  When I talked about distribution I did not mean
    55        I was not all that interested in individuals who are
    56        handing out odd copies outside restaurants or Head Office,
    57        or anywhere else.  When I talk about distribution I wanted
    58        people who were organising the worldwide distribution of
    59        this leaflet.  That is what I was after; I really was not
    60        all that interested in the individual standing outside of a