Day 086 - 09 Feb 95 - Page 04


     
     1        of it?
     2        A.  It certainly is at the back of everyone's minds,
     3        particularly in health and safety.  It is something that
     4        causes a lot of people in McDonald's distress when we talk
     5        about that incident.
     6
     7   Q.   Has nobody ever said to you that McDonald's was at fault in
     8        any way?
     9        A.  I do not think anyone has ever suggested that we were
    10        at fault in that incident.
    11
    12   Q.   Would you go to file number pink XIII?
    13        A.  Yes.
    14
    15   Q.   If you go to page 773 -- that is in tab 52 -- we have a
    16        memo here to all store managers, northern region,
    17        17th February 1992.  This is before the accident, yes?
    18        Accident, electrical equipment, from Frank Frost.  Do you
    19        know Frank Frost?
    20        A.  I do know Frank.  I do not deal with him directly but
    21        I know who he is.
    22
    23   Q.   Did you deal with him directly at any time?
    24        A.  No, he was in the northern region.  I think his title
    25        is Facilities Manager.  It is a regional position.  I was
    26        always in the Midlands region until I came down to London.
    27
    28   Q.   But he feeds into the meetings that you attend; he must
    29        feed information about what is happening in the northern
    30        region, yes?
    31        A.  Not direct meetings that I have, no.
    32
    33   MR. RAMPTON:  My Lord, I do wonder somewhat -- I am not trying
    34        to avoid anything -- we are fully armed to deal with the
    35        Mark Hopkins -----
    36
    37   MR. JUSTICE BELL:  I was trying to turn it up -- I have not yet.
    38
    39   MR. RAMPTON:  There is a statement by Jill Barnes about it for
    40        one thing.
    41
    42   MR. JUSTICE BELL:  Yes, I was trying to find the pleading.  You
    43        do not have it to hand, do you?
    44
    45   MR. MORRIS:  It will be in the Abstract.
    46
    47   MR. JUSTICE BELL:  That is what I am looking through.
    48
    49   MR. MORRIS:  It may be possibly we did not plead it.
    50 
    51   MR. RAMPTON:  Yes, yes, it is pleaded. 
    52 
    53   MR. MORRIS:  It is page 28 of tab 7.
    54
    55   MR. JUSTICE BELL:  Thank you.  Do not read it out.
    56
    57   MR. MORRIS:  G.
    58
    59   MR. JUSTICE BELL:  Just let me read it.  I cannot find my
    60        up-to-date Abstract.  I thought it was brought up by

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