Day 177 - 26 Oct 95 - Page 11

     
     1        in operation during those three months -- which is, as
     2        I had understood it, really what your Lordship wanted to
     3        have.
     4
     5   MR. JUSTICE BELL:  I think Mrs. Brinley-Codd said in her
     6        letter -- was it the middle of next week it was expected?
     7
     8   MR. RAMPTON:  Yes.  I would hope it will be the middle of next
     9        week.  If I make a promise, somebody is bound to break it,
    10        possibly even me; but, yes.  We have the documents.  There
    11        is no question that they are disclosable; it is only a
    12        question that they have to be sorted into categories and
    13        into dates; and the way computers print things out means
    14        that a lot of the time sheets in different categories are
    15        attached to each other, so they have to separated and
    16        sorted, and so on and so forth.  But they should all be
    17        copied and neatly bundled by the middle of next week.
    18
    19        If we had the rest of the time between then and Mr. Logan
    20        free, then it might not be a problem, but we do not,
         because we have Mr. Yenson on Thursday, we have Sarah Baker
    22        on Friday, and we have our three Canadians witnesses on the
    23        next three days, Monday, Tuesday and Wednesday.  They are
    24        coming over, I think, that weekend.
    25
    26        There is an additional point, perhaps in its way just as
    27        powerful.  Having looked at the names on Mr. Morris'
    28        handwritten note of 2nd October and the documents, it would
    29        be our intention to seek your Lordship's leave to call some
    30        of the people from the Bath restaurant; not all, otherwise,
    31        as I have said, the case will never end.  But in order that
    32        your Lordship should get the picture of Bath in those three
    33        snapshot months, we earnestly believe that it is necessary
    34        that your Lordship should be able to see not only, for
    35        example, what the hours were that a person worked, but why.
    36
    37        If we had that leave -- and I will not apply for it now,
    38        because the names of the people we would like to call are
    39        not yet finalised.  As soon as they are, we will tell
    40        your Lordship.  We will then by then have statements which
         we will show your Lordship.  If your Lordship were to give
    42        leave, then my suggestion would be that Bath should be
    43        dealt with not as an isolated, but as a compact and single
    44        subject after the end of the week beginning 27th November.
    45
    46        Your Lordship will also see that we have written to the
    47        Defendants suggesting that two days for Sarah Ingliss is
    48        probably inadequate.
    49
    50   MR. JUSTICE BELL:  Yes, I read that. 
    51 
    52   MR. RAMPTON:  Given the amount of detail that has to be gone 
    53        through with her, it is taking an awful risk, with her
    54        being Canadian and wanting to go back, no doubt, to list
    55        her for only two days.
    56
    57        What I would like to be able to do is to deal with Bath,
    58        and perhaps anything that has to be added to Colchester,
    59        from the week beginning 4th December, so that, so far as
    60        possible, the employment issue is continuous.  If