MR RICHARD
To answer the question specifically, it is denied and disputed that Mr McBride made any honest or diligent effort to conduct a meaningful reconnaissance of the place.  It is alleged that he did what he did without heed for the consequences of innocent civilians in the pub or pubs at the time, and without applying his mind to what in fact he was doing, in other words his allegation that he did a reconnaissance upon which he could make the statement that he does, is disputed and he will be put to the proof thereof.