Party : Respondent Deponent : Alex Potts : 1st Sworn : July 1999 IN THE HIGH COURT OF JUSTICE 1998-M-NO 1180 QUEENS BENCH DIVISION BETWEEN MONSANTO PLC Plaintiff -and- (1) ROWAN TILLY (2) JO HAMILTON (3) KATHRYN TULIP (4) MELANIE JARMAN (5) ZOE ELFORD (6) ANDREW WOOD (sued on their own behalf and on behalf of all the other members or representatives of "genetiX snowball", an unincorporated association) Defendants - and - Alex Potts Respondent AFFIDAVIT OF ALEX POTTS I, Alex Potts of 207A Upper Chalton Road, Whalley Range M16 OBH make oath and say as follows: 1. On the 16th of June 1999 I attended Cereals '99 held at Vine farm, Wendy in Hertfordshire.I entered the show at around 11;00am and then after briefly walking around the site, and establishing which plots were containing GMO's. 2. I went behind Monsanto's stall and began putting on a white biohazard suit which I hoped would minimalise the risk of my clothes being contaminated by Liberty (a broad-spectrum herbicide) and any further genetic pollution. I then walked around to the front of the promotional plots and calmly and carefully began removing the plants, and putting them into plastic bags. 3. I focused on what I was doing and removed less than 100 individual plants . I stopped at one moment to plead with one gentleman who was being abusive and violent . I politely asked him to "please stop" and "not be violent". He did not reply but did stop his unnecessary behaviour. Except for this I did not look up at anyone. At one moment I heard someone shout "You're twats", to which I replied "That is not true" . 4. After I had finished removing plants from the demonstrational plot, I tied up the plastic bags they were within ,and left the bags neatly by the side of the plot. One of the bags was slightly ripped but I made sure that it was clearly visible so that it could be removed safely. I then began talking to journalists and others explaining the reasons for my actions. 5. Within minutes the security arrived and politely asked me to leave which I did. I was kindly allowed to remove my biohazard suit within twenty or-so metres of Monsanto's stall. I was escorted away from the site in a big car after giving a policeman my name and address. 6. I did not know that an injunction against six other people that I know very little about , was relevant to me or my co-defendants ,and presumed that to break an injunction one must be first aware of it. I was not at the court on the 20th April nor have I seen the injunction.