Day 136 - 16 Jun 95 - Page 09


     
     1
     2   Q.   I understand.  I believe you have brought also with you to
     3        court, just by way of example, a ground plan of a typical
     4        McDonald's restaurant which I think is the one at Harrow;
     5        is that right?
     6        A.  Yes.
     7
     8   Q.   Perhaps we can have a look at that so His Lordship can see
     9        what the layout is.  In the areas outside the non-slip
    10        tiling or Altro areas, what material would be used for the
    11        floor?
    12        A.  We would just use an ordinary quarry tile.
    13
    14   Q.   An ordinary quarry tile, what, rather like the one that we
    15        have seen for the customer area?
    16        A.  Yes.
    17
    18   MR. RAMPTON:  Yes. I will give my copy, my Lord, to the
    19        Defendants because this I have looked at and I do not need
    20        it for this purpose.  They will have to share it, I am
    21        afraid.  I am sure they will not mind that.  There is a
    22        copy for your Lordship and one for the witness.
    23
    24   MS. STEEL:   Can we ask why it is that these were not disclosed
    25        some time ago?  Also, Mr. Brown was asked in his evidence
    26        about the previous refurbishment of the Epsom store, and
    27        that was not in his statement.  We could have seen the
    28        tiles before now as well.
    29
    30   MR. RAMPTON:  I do not regard tiles as documents, my Lord.
    31
    32   MR. JUSTICE BELL:  No, but there is no reason why they should
    33        not be brought along earlier and shown.  There is no reason
    34        why the plan should not be shown and there is no reason why
    35        extra information -----
    36
    37   MR. RAMPTON:  It is only to help.  It is just for information so
    38        your Lordship can understand, or the Defendants can
    39        understand, what the materials are like and where they are
    40        put which really is not very difficult or complex.
    41
    42   MR. JUSTICE BELL:  No.
    43
    44   MR. RAMPTON:  Is there a copy there for the witness?  Can you
    45        open it up, Mr. Brown?
    46
    47   MR. JUSTICE BELL:  When you say ordinary quarry tiles outside
    48        the particular non-slip areas, as it were, what do they
    49        feel like to the touch?
    50        A.  They probably -- if I can use this as an example, where 
    51        we have used a non-slip tile with that surface, the other 
    52        side would be the tiles that are used in the areas which 
    53        are not designated as non-slip.
    54
    55   Q.   Could I just have a look at that?  Are they really designed
    56        so that you can lay them one way up or the other way up
    57        according to where they are going to be placed?
    58        A.  That particular one was designed that way, sir.
    59
    60   MR. MORRIS:  Sorry, which one is that again?

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