Day 187 - 13 Nov 95 - Page 07


     
     1   MR. JUSTICE BELL:  Where does that appear in his statement?
     2
     3   MR. MORRIS:  The hierarchy is on B2.
     4
     5   MR. JUSTICE BELL:  Where in his written statement does that
     6        appear?
     7
     8   MR. MORRIS:  It is related to the -- well, it is related to the
     9        petition, because in his paragraph, I think it is 6, of his
    10        English translation of his statement, he talks about
    11        petition amongst the employees.  Well, he says: "The
    12        Management refused to take notice of those serious problems
    13        and I decided to circulate the petition amongst the
    14        employees."  There are two things: one is, how did
    15        McDonald's and the Management refuse to take notice of
    16        these serious problems; and what is the character of the
    17        petition?  So here, just in front of him, he can say, "Yes,
    18        this is the petition; it had this character.  I did write
    19        to X, Y, Z and they fobbed me off", or whatever he is going
    20        to say -- because that is the only way to understand why
    21        the whole situation led to so many legal cases against the
    22        stores.  The letters to McDonald's France are -----
    23
    24   MR. JUSTICE BELL:  What answer do you expect Mr. Lamti to give
    25        to that?
    26
    27   MR. MORRIS:  He would just explain that:  "Yes" -- for
    28        example -- "this B3 is a letter I wrote on 18th May 1993,
    29        to the President of McDonald's France."
    30
    31   MR. JUSTICE BELL:  Where is that in his statement, you see, or
    32        in the extra notes you have?
    33
    34   MR. MORRIS:  That specific letter was not mentioned in the
    35        statement, but it is part of the process where he attempted
    36        to complain or seek responses from McDonald's France.  The
    37        letter on B4 is a reply by George Brown (who is a witness
    38        in this case) with quite an important sentence in it; and
    39        I was going to ask him just to explain what that sentence
    40        was.
    41
    42   MR. JUSTICE BELL:  No.  I am sorry.  You can take him through
    43        his -- you can put in his statement, which has been served
    44        for a very long time; you can ask him about the matters
    45        which are in the supplementary statement; but I am not
    46        having any extra evidence.  I gave a very clear ruling on
    47        this some time ago.  Now, you must abide by that.
    48
    49   MR. MORRIS:  I just think that it is helpful in terms of getting
    50        at the truth -- which is the whole purpose of us being 
    51        here -- that important documents, at least Mr. Lamti can 
    52        explain, even if the document is not relied on, he can just 
    53        say: "I wrote to George Brown, Vice President of Human
    54        Resources, and he replied, you know, what their position
    55        was."
    56
    57   MR. JUSTICE BELL:  I am sorry.  That is my ruling, Mr. Morris.
    58        You must follow it.  Have his statement put in, ask him
    59        about the matters which are on the note of extra topics;
    60        and there, in accordance with my previous ruling, it must

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