Day 250 - 15 May 96 - Page 34

     
     1        A.  No.
     2
     3   Q.   If you could get your first statement in the bundle in
     4        front of you.  If you look at paragraph 11?
     5        A.  Yes.
     6
     7   Q.   Can you just tell us, that is correct is it; that paragraph
     8        is true is it?
     9        A.  Yes.
    10
    11   Q.   What were the instructions that you gave?
    12        A.  To photograph as many of the demonstrators as possible.
    13
    14   Q.   That was it?
    15        A.  Yes.
    16
    17   Q.   That was all there was to it?
    18        A.  Yes.
    19
    20   Q.   What do you want the photographs for?
         A.  I was going to send them to the two agencies.
    22
    23   Q.   For what purpose?
    24        A.  That was their starter.
    25
    26   Q.   It was to help with bringing a case over this leaflet, was
    27        it not, over the London Greenpeace fact sheet?
    28        A.  It was to help them identify people in
    29        London Greenpeace.
    30
    31   Q.   For the purposes of bringing a case over the
    32        London Greenpeace fact sheet?
    33        A.  No, no.  The object at that time was to stop the
    34        distribution of the leaflet.  If it was necessary to go to
    35        court, then clearly I wanted them to gather the information
    36        that we would require to follow that particular line.  But
    37        we would make that decision in the light of what they found
    38        out, so possibly possible litigation was in the back of our
    39        minds, yes.  But the main objective was to stop the
    40        distribution of the leaflet.
    41
    42   Q.   So part of the purpose of taking the photographs was to
    43        produce evidence that could be used in a court case?
    44        A.  No, no.
    45
    46   MR. JUSTICE BELL:  All you have done, he has given his answer,
    47        you have then rephrased it in words which were not his, and
    48        therefore he said, no, and now, presumably, he will repeat
    49        it.
    50 
    51   MS. STEEL:  I am putting it to him. 
    52 
    53   MR. JUSTICE BELL:  You did put it like that before, and he said
    54        no, and gave an answer.  You are now putting it in a
    55        slightly different way and he is going to, I suppose, say
    56        no and give the same answer he gave a moment ago.
    57
    58   MS. STEEL:   How were you going to stop the distribution of the
    59        leaflet?
    60        A.  Well, the object was to get as much information as