Day 165 - 27 Sep 95 - Page 22

     
     1        a particular person a copy of the London Greenpeace fact
     2        sheet on which, so far as I can see, they do not have any
     3        evidence.
     4
     5   MR. JUSTICE BELL:  Yes, thank you.  Does that complete the
     6        matters on discovery?
     7
     8   MR. RAMPTON:  Not quite, my Lord, because I promised your
     9        Lordship I would come back to the Management and Crew
    10        Scheduling Programme.  I think in due course it is likely
    11         -- not today, but in due course -- Mr. Atkinson will wish
    12        to make some submissions in relation to the discovery which
    13        the Defendants have made in relation to the counterclaim
    14        issues, but I am not inviting your Lordship to consider
    15        that today.
    16
    17        But I did promise I would come to your Lordship on the
    18        Management and Crew Scheduling Programme.  I have now made
    19        copies of the document which I told your Lordship I had
    20        seen but not read, I had glanced at. (Handed).  I do owe
         your Lordship an explanation in relation to this because,
    22        as your Lordship knows, originally Mrs. Brinley-Codd wrote
    23        a letter in which she said that the document asked for no
    24        longer existed and that the whole thing was now done by
    25        computer.
    26
    27        She had made enquiries and that is what she was told for
    28        this reason, that originally up to about four years ago it
    29        was all done manually.  There was in those days a much
    30        bulkier and a rather different document in existence which
    31        had, I think, the same title.  The person to whom she spoke
    32        (who was Mrs. Barnes) who has just taken over training said
    33        correctly, so far as I know, that old document no longer
    34        existed and that it was now all done by computer.
    35
    36        On further enquiry we find, in fact, that the position is
    37        that it is now done partly manually.  When I say "partly
    38        manually" and partly by computer, I mean to say that there
    39        is a choice for the Manager whether he does the operation
    40        manually or by a use of the computer program.
    41
    42        What this document does is it is a sort of beginner's guide
    43        about how to go about scheduling, whether you want to do it
    44        manually or whether you want to use the computer program;
    45        the computer program being called ISP.  As your Lordship
    46        will see, this document falls more or less into two halves
    47        with those two objects or purposes in mind.
    48
    49        The virtue of this document, which we have numbered
    50        manually for the purpose of the case (and I take it that 
    51        this is the true relevance of the document, the mechanics 
    52        do not matter), is that it sets out, this is a McDonald's 
    53        document, the purposes and principles of crew scheduling.
    54        Your Lordship will see that on page 3, the objectives, on
    55        page 5, at the top of the page and, above all perhaps or
    56        just as importance perhaps, on pages 17 and 18, scheduling
    57        tips with the blobs or bullet points.  It is by this means
    58        that the Manager is enabled to understand what he is
    59        supposed to do and, more particularly, the reasons why he
    60        is supposed to do it.