Day 171 - 11 Oct 95 - Page 09
1 MR. RAMPTON: It does not say that.
2
3 MR. MORRIS: It does say that in his note. I have written it
4 down.
5
6 MR. JUSTICE BELL: Whose note?
7
8 MR. RAMPTON: A memo sent to Bath on this subject, critical
9 of -----
10
11 MR. MORRIS: Oh, I am sorry about that. Critical of other
12 practices -- I did say last week that that applied to the
13 store audit, not to the memo.
14
15 MR. RAMPTON: Again, I do not want to argue it now, but I need
16 more specificity before I am willing to disclose a store
17 audit which might contain some criticism which Mr. Logan
18 was not (inaudible). If Mr. Logan wants to say what
19 criticism there are that he remembers, that is fine.
20 Anyway, that is to argue it once again.
21
22 There is no memo or letter from Head Office or Regional
23 Office about Bath PR practices. We cannot find number 6,
24 though I would like to be able to, which is Mr. Olive's
25 letter of complaint or resignation. We will go on looking,
26 but I am not very hopeful.
27
28 My Lord, can I take, please, 7, 8, 10 and 11 together?
29 I will come back to 9. All I will tell your Lordship about
30 9 is that we do have rap session note for 1993 and 1994.
31 I do not agree to give discovery of those notes as matters
32 presently stand. That will mean that Mr. Morris will have
33 to argue for those. But, my Lord, can I tell you about 7,
34 8, 10 and 11?
35
36 MR. JUSTICE BELL: You have them for 1993 and 1994?
37
38 MR. RAMPTON: I have some for 1993 and 1994; yes, we do have
39 them. We also have -- can I tell your Lordship what we do
40 have? It was taken in large part from what your Lordship
41 suggested might be a good idea. What we asked Bath to do
42 was to find the last complete month before Mr. Logan left,
43 which was November 1994, for which handwritten schedules
44 had been made. That was our first step. We made no
45 selection of the month, ourselves. We simply said: "Look
46 to see if you have a complete month of handwritten
47 schedules in 1994"; and the last month for which they have
48 a complete set of handwritten schedules is May 1994. So
49 what we then did, or what we did at the same time, was to
50 say to Bath: "Please also send us" -- we said we do not
51 want the weekly time sheets, we do not want those, because
52 the clock card sheets which are produced on a daily basis
53 will tell your Lordship who worked how many hours on every
54 single day of the week during that month.
55
56 MR. JUSTICE BELL: Just pause a moment. So, for instance, there
57 would be handwritten schedules -- can I pick it up from,
58 say, the summer season of 1993 -- there would be the
59 handwritten schedules, would there, for July, August and
60 September 1993?
