Day 279 - 12 Jul 96 - Page 08


     
     1   MR. JUSTICE BELL:  Yes.
     2
     3   MS. STEEL:  Obviously, it is a matter for you what weight is
     4        attached to it at the end of the day but, as I understand
     5        it, we are entitled to put Civil Evidence Act notices on
     6        statements made by -- these are first hand witnesses, they
     7        are people that work in the plant, they have seen the
     8        conditions in there and, you know, they are giving their
     9        own effective testimony.
    10
    11   MR. JUSTICE BELL:  Yes.  Well, you develop your argument on it.
    12
    13   MS. STEEL:  Okay.  The first part in the article is page 34.
    14        The first paragraph in the right hand column, where it
    15        says, "In the back of the store are boxes of frozen premade
    16        burger patties supplied largely by...".
    17
    18   MR. JUSTICE BELL:  Sorry, I have not found that.
    19
    20   MS. STEEL:  It is at the end of the first paragraph, "a large
    21        Chicago-based beef processing operation".  That is
    22        something that she witnessed with her own eyes.  She does
    23        say it in the--
    24
    25   MR. JUSTICE BELL:  I am sorry, I am no doubt being very stupid,
    26        I cannot find where you are.  In which paragraph?
    27
    28   MS. STEEL:  Page 34, first paragraph on the right hand column,
    29        second to last sentence.
    30
    31   MR. JUSTICE BELL: "In the back of the store..."?
    32
    33   MS. STEEL:  That's the one, yes.  She does refer to that in the
    34        last paragraph of her own statement, it is just that it is
    35        a little bit more detailed.  Actually, it is probably
    36        covered anyway, but then this is a little bit complicated.
    37
    38   MR. JUSTICE BELL:  I am sorry, just pause a moment please?  Does
    39        someone have a spare copy of her statement, I think I must
    40        have left mine up in my room upstairs.
    41
    42   MR. MORRIS:  I have not got one at all, I am sorry, otherwise I
    43        would pass it up.
    44
    45   MR. RAMPTON:  My Lord, I have one that was filed.
    46        Unfortunately, it has got some writing by me.
    47
    48   MR. MORRIS:  I tell you what might help actually is if we put
    49        this one back for a bit and Miss Steel can copy it and
    50        maybe underline the bit that we want to rely on.  It would
    51        probably help everybody and get through it much quicker.
    52
    53   MR. JUSTICE BELL:  Well, what I suggest is -- I have got it
    54        stowed away somewhere in a volume.  What I suggest is Miss
    55        Steel carries on with her references to the parts in the
    56        article so I can see that.
    57
    58   MS. STEEL:  I mean, you could check the last paragraph of her
    59        statement anyway later.  I have actually got notes on my
    60        statement, so.  I mean, I have no doubt got a clean copy at

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