HIGH COURT TRIAL JUNE/JULY 1999 Case No: DD04199 Court 58 John Alfred Donovan v. Shell UK Ltd (name of relevant Shell executive changed to his initials "AJL" - modified 23 April 2018

AJL cross examination under oath by lead barrister Geoffrey Cox during the above trial at the Royal Courts of Justice

These selective extracts cover his "close" relationship with Option One

The complete relevant pages from the trial transcript can be read here


Pages 34/35:

Q: Turn the page. You then pen a more personal note to Jeremy and Tim. You had established in 1992 a friendly personal working relationship with Jeremy and Tim of Option One, had you not?

A: Yes, as one does normally with any relationship you work with closely.

Q: In this case, you got along very well?

A: Indeed

Q: in fact, I think you went away for weekends with Mr Bonnet?

A: Bonnet, probably.

Page 51/52

Q: You got on well with Tim, did you not, and Jeremy?

A: Everyone in the promotions department got on well with the whole of their team.

Q: And you were socialising with them, were you not?

A: Yes, as was normal in the industry, I guess.

Q: Really?

A: I socialised with everyone that I worked with.

Q: You went to dinners and you went to the new year's party, for example?

A: Client entertainment is a standard part of the industry.

Q: For Option One?

A: For almost every agency that I had experience of. Now we did not accept many of the invitations and so on that we got. Ones we did accept were always on management approval and normally after, well, always after work had been done.

Q: Did you go to the new year's party of any other agency?

A: I cannot recall.

Q: Did you go away for weekends with members of any other agency?

A: No, I did not, because, I mean, can you point me to where the weekend was or weekends?

Q: Not immediately, but you can remember going away for a weekend, can you?

A: Yes, with Tim Bonnet. He became a very good friend.

Q: Did you go out to dinner with members of other agences?

A: I had one or two lunches or dinners with people we had done work with. I can remember one with Senior King, for example.

Q: Lunches?

A: There was a lunch with Senior King.

Q: Not dinners?

A: If you can point me to actual instances.

Q: I am asking you to remember, please.

A: I cannot remember any other dinners. I also entertained Tim Bonnet to my own house and cooked him dinner with a variety of my other friends, as you would normally do with a friend.

Q: Yes, two days after Mr Donovan's idea was given to you, you telephoned him about Onyx?

Page 140/1

Q: During this time, you were in close contact - certainly, I suggest to you, from late 1992, 26th November, when you rang Bonnet about Onyx, you were going out with, socialising with and in close personal contact with people at Option One, were you not?

A: We were definitely working very closely, we were putting together concurrently two very major national promotions. I have already said that. I cannot remember, without reference to my diaries, when we actually went out privately, but I was developing a good private relationship with Tim Bonnet as well as a good working relationship.