Day 148 - 05 Jul 95 - Page 28


     
     1        If we turn three pages on, there should be a chart which in
     2        the top left-hand corner has, "Performance Standards to be
     3        Documented".  If we look at the second to last item on that
     4        left-hand column (this is in April 1983) it says:  "Review
     5        hustle, i.e. message procedures, impact on safety,
     6        recommendations to be communicated and implemented."   Then
     7        it has:  "Target date April to September 1993 for reviewing
     8        hustle message and procedures".  At the end of that line it
     9        says:  "Report to be presented at next meeting of the
    10        Health and Safety Group".  So we would like a copy of that
    11        report reviewing the hustle message and procedures and
    12        impact on safety.
    13
    14        The next document is the Dan Gallein letter which Mr. Stein
    15        was asked about in re-examination.
    16
    17   MR. RAMPTON:  No, he was not.  My Lord, that is inaccurate.
    18        I asked him what he knew about Dan Gallein.  He volunteered
    19        that he had received a letter from Dan Gallein.  I did not
    20        ask him about it.
    21
    22   MR. MORRIS:  Right.  Mr. Rampton knew absolutely nothing about
    23        this Dan Gallein letter.  Anyway, now that we know it
    24        exists and that Mr. Stein had such a strong recollection in
    25        his re-examination about it -----
    26
    27   MR. JUSTICE BELL:  Give me the reference in his evidence.
    28        I remember the evidence, but give me the reference so I can
    29        check it again.
    30
    31   MS. STEEL:   It is day 145.
    32
    33   MR. JUSTICE BELL:  Can you give me dates as well as days,
    34        please?
    35
    36   MR. MORRIS:  Yes, it is 29th June.  It is his re-examination
    37        which was very brief.  It is, effectively, something like
    38        pages 51, 52.  We just cannot find the exact line.
    39
    40   MS. STEEL:   It may be page 53.  We have page 53 missing because
    41        at the top of page 54 Mr. Morris says:  "It must be
    42        relevant.  It goes to the credit of one of our witnesses."
    43        Mr. Rampton said, "That is why it is not necessarily
    44        relevant".  We said we have an entitlement to see it.  It
    45        was then said that we should leave it until this week.
    46
    47   MR. JUSTICE BELL:  In any event, perhaps we could have a copy of
    48        page 53 because it is missing in mine as well.  There is
    49        nothing sinister about that; it is just that in the
    50        photocopying it has been left out. 
    51 
    52   MR. MORRIS:  There is one other thing -- there are two things; 
    53        one was, I do not know what has happened to this -- it was
    54        an application made ages ago about the map that
    55        Dr. Gonzales saw in Guatemala.  We had the map from
    56        Brazil.  I do not believe we ever got a response on whether
    57        the Plaintiffs -----
    58
    59   MR. RAMPTON:  My Lord, we need the transcript reference, please.
    60

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