Ref: A00-300995 Case No. 871626 Macpherson II
Volume VIII, Pages 73-103, Friday 23rd June, 1989
(In the presence of the jury)
JOHN PETER STEWART: Sworn
Examined by Mr. Beckman
Q. My Lord, may I say there is one item not in the report which
I have asked Professor Stewart to deal with, and that relates
to the proton magnatometer [sic]. (To the witness): What is your
full name? A. John Peter Stewart.
Q. Your qualifications? A. My qualifications in letters are
Dip. Tech., which is a Diploma in Technology and Engineering
and PhD. I am a Fellow of the Institute of Electrical
Engineers and a chartered engineer.
Q. What is your present position? A. I am Professor of
Electrical and Electronic Engineering at Portsmouth
Polytechnic.
Q. How long have you been there? A. Six years.
Q. Prior to that, what was your position? A. Prior to that I
was a senior principal scientific officer, head of the
department of engineering at Warren Spring (inaudible) which
is part of the Department of Trade and Industry.
Q. How long were you there? A. Sixteen years.
Q. Your experience, I believe, covers a wide range of electrical
and electronic systems communications, radio controlled
computer systems? A. Yes.
Q. Some 20 odd years of experience. A. About that.
Q. Did you receive on 8th June of this year, from the
defendant's solicitors, a copy of what we call Exhibit 4,
namely the demand document? A. Yes, I did
Q. What were your terms of reference to look at that document?
A. I was asked to look at that document and to report on the
degree of plausibility from the point of view of the
electronic and radio communications side.
Q. We know that on the face of it one can see this document
speaks for itself in this case, the document revealed details
of the construction and operation of the system so as to
perhaps convince the reader of the veracity of the threats.
Is that right? A. That is correct.
Q. On the face of the document? A. Certainly one of the
passages was headed "Validation", and in various pages of the
document there were references to indicate the truth of this
document or some such ---
Q. And invites the recipient of the document to obtain expert
assistance? A. Yes, it does; it refers to experts.
Q. What I want to do is see if the recipient of the document
took advice from you, what an expert would say. In the
document it provides details, does it not, concerning the
electronic command control and communications system?
A. Yes, it was described as "REC-3".
Q. Those are the matters you are concerned with because there
are others and you are not an expert on the toxicological
chemical aspects. A. That is right.
Q. First of all, does the writer of the document use a great
number of technical terms and mnemonics? A. Yes, there was
a large number of technical terms and mnemonics used; very
popular with technical people for various reasons. At least
four of these were ones that were quite clearly invented for
the document and not common usage and phraseology, so, one
thought, showed they were invented for that document. It is
a process that often happens, but among those were terms I am
quite familiar with.
Q. Which are the ones which are invented for the document?
A. "REC-3", "ROT", "GAM" and "PIG".
MR. JUSTICE MACPHERSON: You can, of course, have your report in
front of you if you require it. A. I have some notes here.
I will ask for it if I need it, thank you.
MR. BECKMAN: The selection of terms that are used there, are
they all appropriate to the context to the expert eye?
A. By no means. Some were quite out of context and mixed
in their arrangement.
Q. Mixed in their arrangement, out of context. What effect did
that have upon the degree of plausibility so far as an expert
is concerned? Forget the lay reader like myself, but upon
the expert? A. From my point of view, putting a long list
of mnemonics simply to me, when I read the demand
document ---
MR. JUSTICE MACPHERSON: Do not speak too quickly.
MR. BECKMAN: Would you watch his Lordship's pen?
MR. JUSTICE MACPHERSON: I do not need a great deal because I
have your report, but it is important that you speak clearly
so that we can take it in. A. I realise that and I
apologise.
MR. BECKMAN: You are used to lecturing? A. In my short time.
Q. Do your best to remember the twelve people on the jury are
senior students. A. On page 7 of the demand document I was
given, which in the exhibit page 12, paragraph 4 is a long
list, as an example, of quite well known technical mnemonics.
Q. Shall we go there so we can follow? A. In fact, if you
wish to ask about that it would be helpful if I had a copy of
my statement.
Q. I am sorry, I am actually lost, unless the numbering of mine
has gone wrong. A. The page referred to in the demand
document was page 7. It is at the top, at the bottom there
is "Exhibit 4, page 12".
MR. JUSTICE MACPHERSON: Is this a list of mnemonics? A. Yes,
"FM", "CW", etcetera.
MR. BECKMAN: I am sorry, my Lord, somehow or other I have a
bundle of different numbers. (To the witness): Do carry on,
professor. A. That particular paragraph contains a set of
technical mnemonics, "FM", "AM", "CW" and so on, but what is
immediately apparent is that (inaudible). Some but not all
of these temrs [sic] describe what is called "modulation" and in
this context means a way of impressing information on to a
radio signal, but they are not all of that kind. For
example, "ASCII" (usually pronounced "askey") is not a
modulation at all.
Q. What is it? A. An American standard code for interchange
and that is the way in which the letters of the alphabet are
interpreted into digital signals. It has nothing to do with
radio per se.
Q. Is that to do with computers as well? A. Yes, all computers
usually on their computer terminals carry these particular
codes.
Q. So "ASCII" is used in every single computer there is, just
about? A. Yes, there are one or two are different but the
vast majority in the whole world are like that.
Q. Has it any relevance to this situation? A. No direct
relevance to that list. It had relevance to home computers.
Q. Has it any relevance as to what is proposed as a plausible
scheme in this document? A. It has not in the context in
the set of mnemonics used there. Therefore, to the technical
reader you wonder why it was placed there because the context
used is one in which the writer is saying, "You don't know
what I am using to put these signals across".
Q. Does that make it relevant? A. In fact, some of them are
related to radio signals, some are not, and therefore they
are mixed, they are conflicting, out of context. To the
technical reader it looks like he doesn't quite know the
difference from one to the other.
Q. Can you tell us those which are set out there which, to any
electronics expert, are irrelevant to his proposed scheme?
A. Because perhaps the scheme is described in one place - in
fact it is described on page 2, exhibit page 7, paragraph 4,
as being a radio system, it is given the mnemonic "TNC".
Because of that there are only seven of these listed
mnemonics that make any sense. The ones that are irrelevant
are "AM", "CW". "CW" means cross code, mostly delayed.
Delayed modulation is a means of impressing speech on to
signals, mostly (inaudible). It has nothing to do with what
has been talked about here. "PCM" is a police code
modulation. That has no particular relevance either.
Q. What about "RTTY"? A. "RTTY" is a fairly old-fashioned way
of transmitting messages. It is quite different to the
packet radio system in the demand document and this bit
marked "Validation" says is being used, that is apparently
being used in the page headed "Validation" to say, "This is
the heart of the unit, this is what I am doing to prove that
it is sensible", yet "RTTY" is radio teletype, which is a
much inferior way of transferring messages as far as accuracy
is concerned and one that is quite conflicting with a packet
radio.
Q. Therefore, the two are mutually inconsistent? A. Yes.
Q. And, therefore, one or both of them are quite irrelevant?
A. The question I believe that was asked in that paragraph
was, "You won't be able to tell what I'm using. It might be
one of these or something more exotic", but a technical
expert, once he is told it is a packet radio and "TNC" is
used with that, does know which of these on the list is being
used.
Q. Which are the only ones that can be used? A. The ones that
can be used are "FM", "FM" is modulation signalling for UHF
or VHF radio which is typical for short range radios. "SSB",
signal set bank, that is usable for long range radios on
short wave and "FSK", which is frequency shift (inaudible)
which simply means the way in which you impress the message
on the radio signal of the short or long range type I just
described.
Q. To you as an expert, can you tell me this: would it be too
high to say an introduction of the relevant (sic) ones make
it nonsense to you? Would I be putting it too high or is
that a fair word to use? A. No, it appears to me to be
nonsense since I can readily appreciate that throwing in a
lot of mnemonics of this type, especially as they are all
found in any technical dictionary, might well be confusing to
someone who doesn't use these terms regularly. It is
nonsense.
Q. Now I turn to the last paragraph of the first page of the
report. Assuming, therefore, that the technical description
may appear to be a blatant attempt to blind the lay reader
with science, how would you describe the technical
description, as realistic or fanciful? A. I would describe
it as fanciful, the product of an over-active imagination.
Q. Does it accept or ignore the practical and technical problem?
In other words, is it realistic at all? A. I think that is
the nub of this document. From a technical point of view the
demand document has a lot of possibilities in it, the keen
objective to set out at any time to trigger devices from one
country to another is clear enough, but the way in which it
is explained goes into a wealth of conflicting detail and yet
leaves out all of the problem areas that I know would be
discovered if anyone were to try this and actually try and
set it up. There are a wealth of practical technical
difficulties in doing this job.
MR. JUSTICE MACPHERSON: Just pause. From a technical point of
view a lot of possibilities as to triggering one thing from
one country to another, but examined by an expert there are
what? A. There are a wealth of practical technical
difficulties which beset someone attempting to do this. The
writer of that demand document did not appear to me, when I
read it, to have experience actually doing that, otherwise I
suspect that he would have written a simpler document and
would have made reference to how he had overcome the obvious
technical difficulties.
MR. BECKMAN: Assuming - forgetting you seem to be describing a
method to obtain the objective has not been at all practical,
can I ask you this: if you wanted - you personally wanted to
obtain the objective, would it be possible? A. Yes, it
would be possible for me to obtain that objective provided I
had the technical resources.
Q. I am not suggesting you can do it from Portsmouth or
wherever, but assuming you are constricted to do something of
that sort, can you tell us the sort of resources you would
require in your budget? A. Yes, I will not make an
estimate of the amount of money. I would certainly need the
resources of a large military electronics company. If I was
in the United Kingdom I would immediately seek the purchase
of certain equipment from companies like Plessey, GEC,
Marconi and many others of that type, but I would add to that
that as you are referring to the demand document I couldn't
do that in a clandestine way. Even with these resources
everyone would know about it.
Q. There is no way of keeping it secret? A. No, not unless I
was working for the Ministry of Defence.
Q. You would have to have the whole of the Ministry of Defence
or something of that sort assisting you? A. Yes, to keep
it secret.
Q. We are talking, I take it, in millions costing? A. Since
the specification in that demand document clearly refers to a
military specification, it refers to a military style of
electronics system, then it would cost a very large sum of
money and may be in ---
MR. JUSTICE MACPHERSON: I am sure that is understood. A. That
is why defence budgets are so large.
MR. BECKMAN: How much?
MR. JUSTICE MACPHERSON: He said he did not want to deal in
figures.
MR. BECKMAN: I want to get a minimum and maximum.
MR. JUSTICE MACPHERSON: Are you qualified to tell us that?
A. I regret - I am qualified to estimate it since I am
(inaudible). If I was asked for a quotation off the top of
my head for that I would say it would take a sum of money in
the region of œ500,000 minimum.
MR. BECKMAN: Let us now leave Marconi and Plessey and the
Ministry of Defence and return to the way in which the writer
of the document says it has been and can be carried out. He
said his source of components arose from domestic electronic
consumer goods, mail order stuff from the pages of electronic
and radio magazines. Assuming that is, as he said, the sole
source of supply, is the system suggested plausible or
feasible or practical or possible, using whatever words you
want? A. No, that is not from the kind of shopping list
that was provided in that document. That list - actually I
can give you the page number with it on because I recall it
distinctly. If you would like to look at it, it listed
domestic appliances which ---
MR. JUSTICE MACPHERSON: Page 16. A. Page 16 on the exhibit,
paragraph 2 and paragraph 4. Paragraph 2 lists some common
high technology or some high technology domestic products.
Paragraph 4 goes on to talk of amateur radio equipment
purchased through mail order from magazines. It is not
possible to complete the system to military specifications
with these items.
Q. My Lord, I have covered the next sentence. (To the witness):
Can you turn to some other specifications I think we have
already dealt with - no, we have not specifically with REC-3.
What does that normally indicate or what could it indicate,
or what was it similar to? A. "REC-3" is not something I
have seen used but "C3" I have. "C3" is sometimes called
"Cq", "C" with a little "q" on the top, and it stands for
"command communications and control". It is a great
favourite of military electronics companies and, for example,
leaflets at exhibitions of military electronics even have
such references in there. They are generally referred to
equipment mounted in a trailer or perhaps aircraft and where
used have a long distance command control and communications,
but "communications" in that sense usually means radio and
sending messages to different parts of battle fronts.
Q. So it is a commonly used phrase? A. Yes.
Q. Paragraph 3 of the page, computer terminal loaded with unique
software, where is that? A. I think you will find it is
exhibit page 7, which is the second page of the demand
document.
Q. "A computer terminal loaded with unique software programme."
What does that tell you about the person creating the
document? A. That he is probably - he or she is probably
not very familiar with the use of the terms. You see,
software is in fact the same as computer program. People
who deal with these regularly do not usually refer to
software program, they will, I think, say just "software",
meaning the set of programs perhaps, or they will say "my
computer program", or "my program".
Worse still there is - the spelling of that is
interesting because when I read the demand document most of
the spelling, not all, most of the spelling is quite correct.
It seems to be well written, good English and there are one
or two spelling errors in the technical terms but this wasn't
so much a spelling error but a different form of usage.
Double "M.E." is the way you talk about it when talking about
a radio programme. When talking about computer programs
every computer program uses P.R.O.G.R.A.M. It may sound
American but it is the standard to mean something differently
from radio programme.
Q. So there is something there that is obvious you are not
dealing with an expert at all? A. I'm afraid so.
Q. In the same paragraph it refers to a communications
transceiver being tuned to the right radio frequencies. Is
that inconsistent with something else there? A. Yes, it
is. In that particular paragraph, as you see, the writer
does talk about tuning the radio to the right frequencies to
trigger this device, but later in the paragraph, in paragraph
6 of the same page, in fact the demand document refers to the
fact, as it has to be, that the communications for this
system are established across a number of - and then there is
secure sequentially monitored radio channels. It sounds
a nice way to put it but "secure" means it is difficult to
open. It is what you use in military terms to avoid people
listening to what you are doing. If you have sequentially
monitored something it means you switch from one channel to
the next, to the next. It is very simple that way, it is
easy to find.
Q. Like an efficient button radio almost. A. Not much better
than that.
Q. So these two matters, totally inconsistent, tell you what
about this system, that it is nonsense? A. Well, they tell
me this system as described doesn't sound very plausible at
all. It can also tell me that maybe that was where the
leaflet writer hadn't read one that talks about frequency
hopping.
Q. Let us go on to paragraph 4. It refers to a packet switching
terminal node controller, and I can understand that appears
frequently in most amateur radio systems. Is that
inconsistent with the scheme? A. No, it isn't inconsistent
with the scheme itself, it is a particular method of
transferring messages from one point to another, sometimes
over great distances, sometimes through a great number of
links, but this is inconsistent with a number of other points
made in the demand document, some of which I have mentioned
already in the last two mnemonics.
Q. Is that a further fact which leads you towards the view
everything was quite impracticable? A. I am sorry,
I didn't hear the last word.
Q. Everything was impracticable, unrealistic? A. The scheme
described in the demand document in that detail is
impracticable.
Q. I think there is one of the items there, a packet switching
system. What is that normally used for? A. Well, I use
such a system myself and it is used to transfer messages from
one point to another with more accuracy to ensure that the
message is delivered accurately. It is a very exciting
technical development. It uses an international standard of
rules for how to transfer messages from one point to another.
MR. JUSTICE MACPHERSON: If it is necessary where is it, because
it is not very easy for me or the jury to follow quite a
long dissertation without knowing what the reference is in
the report? A. I'm sorry are you talking about me.
MR. JUSTICE MACPHERSON: You were asked about a packet switching
system.
MR. BECKMAN: That would be TNC; it is a packet switching system.
MR. JUSTICE MACPHERSON: What page?
MR. BECKMAN: That would be paragraph 4 on the same page.
THE WITNESS: Yes, page 2 of the demand document, exhibit page 7,
paragraph 4 refers to a packet radio and TNC.
MR. JUSTICE MACPHERSON: It functions like a packet radio, I see.
A. It is also mentioned on the shopping list page which is
exhibit page 16 which says, "The heart of the unit".
Q. You say, as an expert, it is an impracticable choice for the
system? A. That it is impracticable because it is very
easy to defend; you can jam the transmission.
MR. BECKMAN: If it was intended as a system to send messages
without anyone being able to jam it or get in the way, that
is nonsense, you can easily jam? A. Yes, one of the
difficulties with that type of system is any type of
deliberate or accidental interference causes messages not to
be delivered because they are not accurate, so it just jams
it and doesn't work.
Q. Any difficulty in jamming it? A. Not really, no. From the
description in the demand document it will be operating quite
likely on amateur radio frequencies and these can be
interfered with.
Q. I suppose it would be right that after a certain amount of
messages jammed and not properly received, the thing will
switch off? A. Yes, international standard rules which are
built into these devices all follow the same pattern. One of
the patterns is if a message that is being attempted to be
delivered fails 15 times in succession it gives up, so it
needs a lot of manual intervention at each stage. It isn't
automatic in these circumstances.
Q. I think we have dealt with the irrelevance of various of the
mnemonics in paragraph 12. We now head for the beginning of
your report which deals with the next paragraph. We have the
report, that is why I am referring to this so the learned
judge can see whether I am following. Page 2, exhibit page 7
of the document. That describes the operating codes derived
from true random number tables. A. Yes.
Q. That is paragraph 6. Is that in conflict with anything
else? A. Yes, it conflicts with another part of the demand
document which is on the exhibit as page 12 paragraph 4,
where the writer of that demand document has the statement:
"We lose nothing by revealing that our signals
are Caesar's Code or One-time-pad encripted [sic]
and that no-one actually knows what these codes
are because they were generated by a computer
from toally [sic] random number series that have
since been destroyed."
Q. I think in your report you refer fairly strongly to whether
you thought that is sense or nonsense. Can you tell us what
you thought of that? A. This is because Caesar's Code is
actually a code used by Julius Caesar. It is more popularly
called "Caesar's Substitution", and it is a code formed by
replacing text letters to a message by other letters from the
same alphabet according to a pattern, but you do the decoding
by reversing the process. Therefore both ends, the sender
and the receiver, have to have copies of these codes. If
they have been put on a tape cassette as suggested, sent away
with a courier, or if they have been destroyed, which is
another part of the document, either isn't particularly
helpful if you want to decode them at either end of the radio
link.
Q. I think I am going to read a sentence of yours: "This has
the appearance of utter nonsense". That is your view of
it? A. I'm afraid it is.
Q. That view of utter nonsense, would it be apparent to any
electronics engineer or does one need to have your expertise?
A. Certainly any electronics engineer who has any knowledge
of cryptography - and I do not mean a deep knowledge of the
subject, I mean just basic knowledge - would know that
Caesar's Code is a very simple code. It is one that is
ridiculous for cryptographers to break.
Q. Talking about (inaudible due to counsel turning his back)
inconsistent with having a courier running around being the
only person with a tape cassette and possible destruction,
all make nonsense, they do not make any sense? A. They do
and even a tape cassette becomes nonsense because if you buy
a home computer bought through a mail order ad, you would be
unlikely to use a cassette, you would be more likely to use a
floppy disk.
Q. Then page 2, exhibit page 7, paragraph 7:
"REC-3 is built to military specifications
and features compact size, key circuit
duplication, redundancy and independent
backed up power supplies."
What do you make of that statement as an expert? A. As I
read that in the demand document when I received it, I had a
distinct feeling of deja vu. That phrase - that form of
phrase and words appears in military leaflets all over the
place. It is the kind of thing you slip in advertising
leaflets when you are selling a piece of military
electronics. I have seen it in many leaflets.
Q. When you now read what is described as the system here would
you be prepared to describe this system as familiar (sic) to
military systems and compact size? Would you be prepared to
agree it is an accurate description or something taken out of
a pamphlet? A. It is one that conflicts with other things
put in the same document.
Q. In other words, the description bears no relationship to the
way in which it is set out? A. That's right.
Q. Turn to exhibit page 12. We have in paragraph 3:
"PIGs are also very unresponsive, they do
not talk back to the GAM unless they have
something to say."
What does that tell you? A. Well, it tells me the writer
of the document apparently, although saying that the packet
radio is at the heart of the system, as he does, doesn't
understand exactly how the packet radio works. You see,
in a packet radio the two stations at either end of a link
constantly talk back to each other as part of the method of
operation so they are very responsive, not unresponsive as it
says here.
Q. Paragraph 4:
"Have they" -
that is the experts he has invited them to go and see such as
persons as yourself -
"considered that we might be using military,
commercial or civil satellites which between
them broadcast and relay from longwave through
to microwave?"
The inference of that is such machinery is so brilliant that
no-one would be able to discover, or have enormous difficulty
discovering, the spectrum where the messages are being sent.
What is your view of that? A. Well, with satellites that
is not actually the case.
Q. Why is it not the case? A. Because satellites don't relay
and broadcast on longwave but microwave. They actually
relay and in some cases, very few, broadcast a signal in the
radio spectrum range described as VHF, very high frequency,
through UHF to microwave, a much smaller part of the
spectrum, but that isn't the only reason why satellites were
(inaudible).
Q. What is the other way? Why is it nonsense to say satellite
is a useful form of communciation [sic]? A. All the satellites,
military or otherwise, need to be controlled by a ground
station. The ground station is operated on behalf of the
owners of that satellite, whether it is a television
satellite or a communications satellite, and the ground
station always monitors what is happening, what is going
through their satellite. If they were to see interfering
signals not generated by themselves going through the
satellites they would switch them off.
Q. So in other words it could not work? A. No
MR. BECKMAN: Now will you go to the page that is headed,
"Validation: REC-3", page 12 of the document, page 16 at the
bottom.
MR. JUSTICE MACPHERSON: You have dealt with that, have you not?
MR. BECKMAN: My Lord, I have but I want to ask the witness to
put it in his own words.
MR. JUSTICE MACPHERSON: I did not mean you, I meant the witness.
He has been through this list already.
MR. BECKMAN: Yes, he has been through the list. I was taking
it shortly. (To the witness): You remember you have been
through the list and you have already suggested it is
nonsense to suggest constructing this system. I think you
used the phrase yourself when looking at it, you took such a
strong view. If you do would you mind giving us your
reaction to it? A. Well, I thought constructing a military
system out of that shopping list might be a cross between
Superman and Heath Robinson.
Q. Even when Superman and Heath Robinson work together they
might fail? A. I suspect so.
Q. You took the view that the description, "built to military
specifications" is impossible from the shopping list here or
getting it through mail order magazines? A. Yes, it is.
You need other resources.
Q. Can you help me as to this: are there certain limitations
as far as Cyprus is concerned in transmitting and receiving
radio signals? A. Yes, this part of the world, Cyprus,
Lebanon Turkey, that area, suffers quite badly from radio
static particularly in the spring part of the year, April,
May and so on, which is the date of this demand document.
Since the demand document clearly says that the remote
control is performed by radio - not by telephone but by radio
from overseas, the nearest it could be overseas is Turkey or
the Lebanon, and the problem here is that over that
particular range of about 120 miles or so you would need to
use that radio - a fairly narrow band of the radio spectrum.
It wouldn't be really possible to establish communications
outside that band, and even that is quite difficult at times
because of the large amount of static, so it is possible
over a narrow band and, therefore, if you are hoping to avoid
interception by countries' authorities you are very limited
because they only have to look over that spectrum area, a
window.
Q. We have covered some of the matters which you discovered in
the document and I believe there are others which if you are
asked about you can reply to. If Mr. Temple wants to know
anything you found that is inconsistent or ridiculous, you
will answer that. I want to come to your calculations.
Assuming you had been asked by the Government of Cyprus in
the first instant here and they said - the question posed to
you was, "Is this - having looked at that demand document,
can you please tell us whether it is a genuine threat or a
hoax?" what would your answer be? A. After I had studied -
if I had studied the document to the same depth I have
studied this document; in other words, read it very carefully
indeed, I would come to the conclusion quite clearly it was a
hoax.
Q. Do you think any sensible electronics engineer with your sort
of experience would come to any other conclusion? A. I
don't see how they could because it has very, very little
depth. It has very great depth of mentioning technical
terms, some almost in the right place, but there is no depth
to it.
Q. I am going to use your words: would it be right your view
was the whole scenario was over the top in the description of
technical matters and far too many conflicting and out of
context statements to have a ring of truth about it?
A. Yes, that is the way I feel.
Q. Those are your words, are they not? A. They are indeed.
Q. Is it nearer to an April Fool's joke or a genuine threat?
A. I would certainly be very much inclined to think of it as
an April Fool's joke if it was near April Fool's Day.
Q. The size of the units that would be required for any form of
system to have any practicality would be how big? A. There
are a number of different units. There is the PIGs and the
GAM and the operating terminal called "ROT". The two ends
of that, the GAM and the remote operating terminal, need good
short wave aerials and these would be perhaps 100 foot long,
but mounted up here on the roof there could be (inaudible)
but that would be possible.
Q. And the Cyprus and Turkey difficulties - the mountain in the
middle of Cyprus, - the aerial would have to be how big, 100
foot going up vertically? A. Not necessarily vertically
but it would have to be 50 foot long (inaudible).
Q. And therefore virtually impossible to hide? A. Yes.
Q. One last thing I should ask you about is the proton - I will
not pronounce the word, I get it wrong every time. It is
suggested this proton object be used for the discovery of the
PIGs; is that realistic? A. It isn't realistic considering
that the PIGs are said to be hidden all over Cyprus. The
proton magnatometer [sic] is really just an instrument for
measuring magnetic fields.
Q. Magnetic fields of the world generally? A. Yes.
Q. So, for example, if one flew it over a large area which had
nothing in it at all, it would not work, it would not
indicate anything unless there has been a change to the
earth's magnetic field? A. Correct. If I can give you
an example from my own experience, when I was at Nottingham
University we had to look to see if we could discover where
some objects had been thrown (inaudible) into a lake many
years ago. We used a proton magnatometer [sic] and it took days
and days with only one lake, and that is a fairly uniform
area. If you try and search the whole of the Island of
Cyprus you have got to investigate every little object, every
bit of junk everywhere to determine that it isn't a PIG.
Q. So in other words, we pick up every refrigerator every
bedstead, every single item, and perhaps even heavy junk and
jewellery of people walking? A. As we did in the lake in
Nottingham.
Q. So in other words, yet again it is totally impractical and
nonsense? A. Yes, I have seen them used quite successfully
for seaching [sic] for submarines at sea.
MR. BECKMAN: Perhaps on that note Mr. Temple might want to ask
you some further questions.
CROSS-EXAMINED BY MR. TEMPLE
Q. It is Professor, is it not? A. It is.
Q. Professor, you have evaluated this document purely from the
point of view of being an electronics expert, not a chemist?
A. Yes.
Q. Are we agreed then, that in your mind, in coming to the
conclusion that we have here, you have not taken into account
any aspects of the chemistry involved? A. I certainly
read the chemical aspects, as I read the whole of the
document. I am not unaware of chemistry to a moderate
level. It isn't my specialisation and I don't comment on it.
Q. Have you ever had any dealings with or do you know of
Professor Pearson? A. No, I have never heard of him
before. However, I have heard of Porton Down.
Q. There is no special reason why you should come across
Professor Pearson. Tell me this: other material you had
available to you apart from looking at what we know as
Exhibit 4; have you had the advantage of looking at other
documents in the case? A. When I read the demand document
I had - the only other information about the case I had
delivered was some notes that were made on the toxicological
and chemical aspect.
Q. From where did that come? A. That came from Russell Scaddell [sic]
(inaudible).
Q. What I am getting at is apart from Exhibit 4, you did not
have available to you the rest of the documentation which the
jury have? A. I'm sorry, I recall I have one other
document - I don't think it was sent to me immediately, it
was sent to me a day or two later - which was Dr. Pearson's
statement.
Q. Apart from that, you did not see the other documents which
had been written by the defendant? A. No, the only ones I
saw that were said to be written by the defendant were the
demand document and this covering letter signed "Commander
Nemo".
Q. The other matter about which I want to ask you is, you were
in court this morning whilst the defendant was giving his
evidence? A. For a short time.
Q. May I make it absolutely clear that it is quite proper you
should be. Can we come to the thrust of your evidence:
what you are saying in a nutshell is, "This is nonsense", are
you not? A. Yes, what is written in there is apparently
nonsense.
Q. I noticed you paused. I also noted during the course of
your answers to Mr. Beckman on more than one occasion you
have used the expression, "It was not practical". There is a
distinction between a system being impractical and a system
being wholly impossible to operate. A. There is a
distinction.
Q. No doubt you bore that distinction in mind when you gave
those answers? A. Yes, I did.
Q. Does it come to this - perhaps I can summarise it shortly -
initially it has a superficial attraction of being possible,
but on the close analysis which you made nonsense? A. That
is close to my opinion, yes.
Q. Where do we differ? A. We differ only in the choice of
words that you use and I use.
Q. They may be important. Let us take it in stages. Do you
agree initial reading certain attraction, superficial
attraction? A. No I'm afraid my interpretation was the
objective was apparently feasible; i.e. to trigger devices
remotely.
Q. That is exactly what I want to ask you. That is feasible?
A. It is feasible.
Q. So step No. 1, it is feasible. Step No. 2, are we correct
that the method chosen could possibly work although it is a
pretty poor method to use? A. No, the method chosen in the
demand document couldn't work. The objective is feasible if
undertaken with adequate resources.
Q. I just want to see if I could - not to challenge you. I want
to adduce really why you say you can exclude the system being
put forward in the demand document as being totally
impossible. Can we take it again? The first matter you have
to grapple with is there is very little detail given to you,
do you remember telling us? A. No, I didn't say ---
Q. No depth? A. No depth, that is correct.
Q Does it also follow that you were given very little detail?
A. No, we were given too much detail about too wide an area,
most of which is conflicting.
Q. The fact that the detail may conflict, suppose you have three
or four items - let us use this; you remember telling us
about a radio band, FM and so on, you say of the six or seven
listed three or four are totally incompatible? A. Yes.
Q. Supposing you put these three or four aside and suppose you
put the other incompatible areas aside, would you then be
left with a system that could not possibly work? A. If you
do that you are left with a system that could possibly work
but would be easily defended against and couldn't be
constructed in the way suggested in the document. From the
shopping list it couldn't be built with military
specifications with this and that.
Q. I think you will be pleased to know that there is very little
between us. Can I just come to one final matter. It is
difficult to try to put oneself in the position with
hindsight obviously - you have attempted to do it and I will
try and do it with you once again. You of course knew the
position with regard to actual events that occurred when you
received the documents; in other words, you knew a man was on
trial in respect of them and no doubt you had been told some
of the background. Perhaps it is asking a lot of you, but
supposing you had received these demand documents without any
background (they had come out of the blue) and you are being
asked by a government to advise in terms whether, looking at
the documents as a whole, you could with absolute confidence
say, "Without a shadow of a doubt this is schoolboy
nonsense". Would you have been prepared to do that?
A. Yes, I would. I would have to have borne in mind - it
seems to me that in theory you have not said what
hypothetical position you are putting me in; I assume you are
putting me in the hypothetical position of the Prime Minister
of Cyprus or the technical expert asked by such authority.
MR. JUSTICE MACPHERSON: I think you can only be the latter, can
you not? A. I think I can.
MR. JUSTICE MACPHERSON: That is the point; you can only look at
it as a professor of electronics; you cannot put out of your
mind your very expert and detailed knowledge.
MR. TEMPLE: What could you have done? A. I would have said
that the document gives me a strong impression of being a
hoax but I wouldn't put much strength to it at all, and that
I would advise them to disregard it, though I would also
advise them to try and find out who sent it.
Q. Would you also advise them it might be a good idea to send it
for analysis to a chemical expert? A. Absolutely.
MR. JUSTICE MACPHERSON: Of course, you would advise them to find
out who did it because it looks like a demand for money.
A. Exactly.
Q. That is what you thought it was? A. I don't even like bad
jokes, whatever form they are. I think it would be wrong,
but on the other hand I wouldn't put any credence to it
actually happening.
Q. Because you are an electronics expert and you cannot put
yourself in the position of the President of Cyprus or the
High Commissioner because they are not electronics experts?
A. Exactly, but I would assume I would bear some respons-
ibility to give information if asked.
Q. Of course. I think that is what we understand; that is why
there is very little difference between either side. Reading
it, Professor, does it look to you like the work of a stupid
schoolboy or is it quite a clever document? A. Well, I
have to say that I do mark a lot of students' work of course
in my job and it is always about technical electronic
matters. If I had asked my students as an exercise to
design a remotely operated device - perhaps to wave the Union
Jack rather than poison everyone - if that had been submitted
let us say, that explained how it was done, I would fail that
student.
MR. JUSTICE MACPHERSON: Oh, of course you would as an
electronics expert. I did not mean that, but perhaps what I
have asked is what the jury have to answer.
RE-EXAMINED BY MR. BECKMAN
MR. BECKMAN: You would have failed a student of a polytechnic?
A. Yes.
Q. So the next level down is as a schoolboy because they go to
polytechnics. Would he fail as a schoolboy or just about
pass on schoolboy electronics? A. Just about pass on
schoolboy electronics but I would advise him to learn more.
MR. BECKMAN: He would not get Alpha plus. You were asked
about - of course you cannot say how it would affect the
President of Cyprus, but can you envisage a situation where a
government would not immediately go to its experts?
MR. JUSTICE MACPHERSON: I do not think that is a question for
him.
MR. BECKMAN: I only asked him because of your Lordship's
question to him about what effect it would have on the
President of Cyprus.
MR. JUSTICE MACPHERSON: I am disallowing that question.
MR. BECKMAN: Of course, my Lord, that is the only reason I asked
it. (To the witness): Your knowledge as to expertise; I
think you indicated you had some past knowledge of chemistry?
A. I have some.
Q. Enough to have formed a view about the chemical aspect of
this matter, or not? A. Not about its feasibility, but to
understand what was being said, yes.
Q. You were brought into this matter by Mr. Russell Scaddell [sic]
and he is an expert in his own sphere, which is different
from yours? A. Yes.
Q. But he not being an expert in your sphere, you became the
recommended expert? A. Yes.
Q. You were then asked about whether you knew Dr. Pearson or did
not know Dr. Pearson. Do you know the expert that has been
brought into this case in relation to the chemical aspect?
A. Well, on Tuesday I met Dr. Widdowson for the first time.
Q. He is, as far as you are concerned, an expert in his field?
A. Yes, he is a Reader in Chemistry at Imperial College.
Q. He is at Imperial College in London? A. Yes.
Q You were asked about this - forgive me, I am not sure what is
referred to - you were asked these are the documents you were
given, you were not given all the documents which are
available; you follow? A. Yes (inaudible).
Q. Yes, they are in a small box. Can you help us as to this:
are there any documents you are aware of that have not been
provided to you which might be relevant? A. I don't think
so.
MR. BECKMAN: Again I put this: if there are any such documents
which might assist the professor to assist the jury, I would
ask we be told what they are.
THE WITNESS: It would certainly be very helpful.
MR. BECKMAN: Two other matters: you were dealing with your
expertise you spent some length about that; you follow?
A. Yes.
Q. Then you had an exchange of English language with my learned
friend so I want to do it by way of example away from
specialised technicalities to see what you really mean, if
the words I have used give a wrong impression. You said this
objective was feasible, the plan itself was not practical or
something of that sort? A. Yes.
Q. Let us assume if I wanted - to leave this court, I want to
conquer the world but I decided the only way I was going to
do it was take Mr. Temple with me and the two of us were
going to physically conquer the whole earth. If I said our
objective (inaudible) would I use the words the same way as
you use them? A. Certainly the same way.
Q. The matter I want to ask you is this, again the word
"possibility". Do you remember my learned friend getting
"possibility" out of you? If I said, and of course this is
possible, that Margaret Thatcher may become the next leader
of the Socialist Party, do I take it that is the way you use
the word "possible" or not? A. Naturally that is my
understanding of the word "possible".
Q. In other words, everything is possible but it is totally
unrealistic? A. Not everything is possible.
MR. JUSTICE MACPHERSON: He did not agree with you. Not
everything is possible; he is quite right. I do not think
these analogies help much.
MR. BECKMAN: My Lord, with respect, it is to make sure there is
no misunderstanding of the use of terminology.
MR. JUSTICE MACPHERSON: Very well; have you any more questions?
MR. BECKMAN: Forgive me, my Lord, if your Lordship does say
something about the way I have conducted it, at least I
should be allowed the courtesy to explain as it is in the
presence of the jury so it can be seen to be - it is
justified or no. I have no further questions. If any
subject my learned friend had raised for the purpose of
asking the witness about documents his mind might have been
fixed by seeing these documents. He has not so there is no
point.
(The witness withdrew)
(The trial was adjourned until Monday, 26th June, 1989)
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