Day 148 - 05 Jul 95 - Page 26

     
     1        numbers so that we can actually see how the turnover is
     2        calculated and make the calculations for ourselves to check
     3        whether we would agree with the figures given by the
     4        Plaintiffs.
     5
     6   MR. JUSTICE BELL:  To save me looking it up, can you give me the
     7        reference to the turnover schedule which you do have at the
     8        moment?
     9
    10   MS. STEEL:   I think it is behind Mr. Stein's statement.
    11
    12   MR. RAMPTON:  Behind his second statement.  I think it is
    13        appendix 2, which I think is tab 5 of yellow X, as
    14        I recall.
    15
    16   MS. STEEL:   I do not know whether it is appendix 2 because that
    17        is the average hourly rate.
    18
    19   MR. RAMPTON:  In that case it may be in pink XIV, my Lord.
    20
    MS. STEEL:  I think it is document No. 41 in pink XII.  Yes, the
    22        monthly crew turnover figures from 1986 to 1993. Obviously,
    23        we are particularly concerned with the 1988 to 1990.
    24
    25   MR. JUSTICE BELL:  Which years do you want?  Are you saying you
    26        want all those years or do you want to pick particular
    27        ones?
    28
    29   MS. STEEL:   I think 88 to 90 would be appropriate.  Possibly 86
    30        as well, given that that was when the fact sheet was
    31        actually produced.
    32
    33   MR. JUSTICE BELL:  I do not see that really -- I am not sure
    34        what the relevance of that is, because if you did
    35        participate in the publication in 89 and 90, it is a
    36        question of whether and to what extent it was accurate
    37        then.
    38
    39   MS. STEEL:   I will leave that then.
    40
    MR. JUSTICE BELL:  I will put down 88 to 90.  If you succeed on
    42        this, and the figures look all wrong, then you can come
    43        back to me.  Are there any other discovery matters?
    44
    45   MS. STEEL:   Yes.  The next one is the American observation
    46        check lists which, on day 145 -----
    47
    48   MR. JUSTICE BELL:  Are these on your list anywhere?
    49
    50   MS. STEEL:   I do not know if you remember, but after I handed 
    51        over the list, I think it was Thursday afternoon, 
    52        I actually made a mention of some additional ones that we 
    53        wanted that had not been put on the list.
    54
    55   MR. JUSTICE BELL:  Tell me about that.  Mr. Stein just called it
    56        a check list, did he not, rather than an observation check
    57        list?
    58
    59   MS. STEEL:   No, he said it was an OC rather than an OCL, but it
    60        was still an observation check list.