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Particulars the defendant knew or ought to have known

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Particulars The defendant knew or ought to have known from the identity of the reporter and the presence of a television camera that the words were being recorded for broadcast on a television news service. 9. By reason of the publication of the defendant’s words and actions described in paragraphs 6-8, the plaintiffs have suffered damage to their reputations. 10. On 12 January 2009 at or around 9:00am the second plaintiff requested that the defendant leave the site and the defendant refused. Page 2 of 3
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11. By reason of the defendant’s actions described in paragraphs 5-10 the first plaintiff was unable to conduct its usual business at the site and thereby suffered loss and damage. *** The Statement of Claim then went on to claim damages of an unspecified amount and an injunction preventing Natasha Green from coming within 500 metres of the company’s property near Mildura. Natasha’s instructions to you are that she did indeed launch a one-woman protest against the proposed nuclear waste dump at the plaintiff company’s property on 12 January 2009. She confirms that she chained herself to a gate, along with a banner that said “No Nuclear Waste Dump.” She had telephoned a reporter at ABC news the previous day and invited him to attend and film the protest. She confirms to you that the reporter and his crew arrived at around 9:30am and that she was interviewed by the reporter and had a long discussion on camera about the evils of the proposed dump. She does not know which portions of that discussion were broadcast because
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