Day 148 - 05 Jul 95 - Page 14

     
     1        another gap where it jumps to 213 which is bundle page 27.
     2        It finishes on page 214 which does not actually look as
     3        though it is the end of the section on milk shakes.
     4
     5        In any event, there is nothing whatsoever in there about
     6        the cooking procedures for chicken products which,
     7        obviously, are an area of dispute in terms of food
     8        poisoning in the case.  So those should be disclosed.
     9        Also, the two types of grill for all the meat products that
    10        are relevant, which is all the quarter pounders,
    11        hamburgers, cheeseburgers, Big Macs, all the pages relevant
    12        to the cooking of those and the manufacture of those,
    13        cooking, manufacture and preparation of those should be
    14        disclosed.
    15
    16        In case there is any doubt about whether or not the
    17        Operations and Training Manual contains that information,
    18        this Operations and Training Manual, we have heard on a
    19        number of occasions, covers the whole procedure for
    20        everything, really, in terms of running the stores.  So
         that information must be in there.  After the milk shakes
    22        we then jump to Quality Assurance.  That section -----
    23
    24   MR. JUSTICE BELL:  Are you arguing that there have been relevant
    25        omissions after we get to page 248 of the manual which is
    26        page 29 of the bundle?
    27
    28   MS. STEEL:   No, I said Quality Assurance just because it went
    29        on to that, but I am not saying anything about that at the
    30        moment.
    31
    32   MR. JUSTICE BELL:  That is what I am checking, so it is really
    33        the parts up to 248, is it?
    34
    35   MS. STEEL:  Yes, there are some later matters as well.  Then on
    36        page 388, which is bundle page 50, is open, transition and
    37        close.  That does not appear to be the first part of that,
    38        and we only have pages 388, 392, 395 and 402.
    39
    40   MR. JUSTICE BELL:  What is it you are saying would be relevant
         about this?
    42
    43   MS. STEEL:   The whole section, really, because it relates to
    44        both -- it relates to personnel matters in any event, but
    45        also the section that we have is just about the opening of
    46        the grill.  There would be other matters relevant to ---
    47
    48   MR. JUSTICE BELL:  I am asking you to give me---
    49
    50   MS. STEEL:  -- freezers. 
    51 
    52   MR. JUSTICE BELL:  -- some examples, you see. 
    53
    54   MS. STEEL:  Food poisoning.
    55
    56   MR. JUSTICE BELL:  What sorts of things do you say you expect to
    57        be there?  Relate them to an issue you are interested in.
    58
    59   MS. STEEL:  In the personnel field, in terms of the job that
    60        people have to do, the conditions that they are working