Day 128 - 24 May 95 - Page 02


     
     1                                      Wednesday, 24th May 1995.
     2
     3   MS. STEEL:  Before we start, I want to make an objection that a
     4        large part of the evidence of Mrs. Barnes yesterday was not
     5        in her statement; the first one is only two and a half
     6        pages long and the second one is just about Mr. Hopkins.
     7        There were a huge number of things that she discussed, gave
     8        evidence about, that were not referred to in her statement
     9        at all.  For example, safety circles, the publications such
    10        as ---
    11
    12   MR. JUSTICE BELL:  Keep your voice up, please.
    13
    14   MS. STEEL:  -- publications such as High Levels magazine, the
    15        Crew News, and things like that.  I would also like to say
    16        that if the Plaintiffs are intending to rely on health and
    17        safety information in High Levels and the Crew News
    18        magazine, and other documents that were mentioned
    19        yesterday, they ought to disclose copies of those
    20        documents.  Also, they ought to disclose a copy of
    21        Successful Health and Safety Management that has been
    22        referred to in a number of cases by Mrs. Barnes.  So far as
    23        I am aware, we do not have a copy.
    24
    25   MR. JUSTICE BELL:  Yes.  What I would like you to do is go on
    26        with your cross-examination.  If there is a part of
    27        Mrs. Barnes' evidence which you say you were taken unaware
    28        of because it was not in her statement, or was not
    29        disclosed to you by virtue of being in a document which was
    30        disclosed, then draw my attention to that when we come to
    31        it.
    32
    33        One of the difficulties, or a potential difficulty -- it
    34        may not be a difficulty -- is that witnesses on both sides
    35        have, in their evidence, in many cases, gone beyond what
    36        was in their statement.  If that was happening on one side
    37        but not the other, I might be moved to correct it, but
    38        since it has happened both in respect of witnesses called
    39        by Mr. Rampton and in respect of witnesses called by
    40        yourself and Mr. Morris, then even-handedness, it seems to
    41        me, is called for, for me not to stop or object to one
    42        party doing it, because if I am going to indulge the
    43        parties on one side, I must indulge the parties the other.
    44
    45        Anyway, carry on with your cross-examination now.
    46
    47                     MRS. JILL BARNES, recalled.
    48                     Cross-examined by MS. STEEL
    49
    50   Q.   You started at McDonald's as a Trainee Manager? 
    51        A.  I did, yes. 
    52 
    53   Q.   Can you just say what that would involve?
    54        A.  Well, my initial term at McDonald's was spent in crew
    55        uniform.  The first three to four months was spent working
    56        on the stations and learning the procedures, and at the
    57        same time learning two of the management systems as well.
    58
    59   Q.   So you spent part of your time on the crew stations and
    60        part of your time learning the management system?

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