Day 083 - 06 Feb 95 - Page 63
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2 MR. RAMPTON: I am still on day 70, and that was pages 22 to 23.
3 My Lord, the next thing was the UK and US accident
4 statistics. I have got the missing bits, if I may call
5 them that, of the UK statistics now. I do not invite
6 anybody to say anything about those at the moment. Maybe
7 it is best they consider them overnight.
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9 MR. JUSTICE BELL: Where do these go?
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11 MR. RAMPTON: Mrs. Brinley-Codd will do a list of direction so
12 far as that is concerned.
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14 MR. JUSTICE BELL: I will hand it back. If Mrs. Brinley-Codd
15 will be kind enough to write on her post-it where they are
16 going. I know I had a very short summary but I have
17 forgotten which bundle it is in.
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19 MR. RAMPTON: That is right. Your Lordship thought it was
20 inadequate. That was just an error because there had
21 originally been three sheets, and now we have the
22 succeeding two sheets which were omitted. I should say
23 about these UK statistics that they only relate to the
24 reportable accidents, the Ridor statistics.
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26 MR. JUSTICE BELL: The notifiable ones.
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28 MR. RAMPTON: My Lord, I also have, and I would invite your
29 Lordship not now but in due course to say whether this is
30 sufficient, two sheets of statistics for the company-owned
31 restaurants in the United States for the year 1994,
32 breaking the statistics down (if that is not an unfortunate
33 pun) into areas where the accidents happen and where known
34 the type of injury. It gives the total number in each case
35 which is something similar, though it is not exact, to what
36 was in those charts in I think it was the Operations
37 Manual.
38
39 What I would invite your Lordship to say is whether or not,
40 and I am entirely open minded about this at the moment, the
41 statistics for the last year would be sufficient, given
42 that they are going to be as the size of the operation
43 increases greater in number, though it may not be in
44 proportion, and it may be that it will be sufficient if
45 I get somebody in the United States to make a statement
46 saying, well, in fact they bear about the same proportion
47 to the number of employees overall as they have for the
48 last five years or whatever, rather than putting somebody
49 to the task of doing the same job for a series of years.
50
51 My Lord, your Lordship did say on that day, Day 70 last
52 year, 20th December last year, that the statement of
53 Ms. Link, the paper-making expert for the Defendants,
54 should be served by 31st January. We have not seen any
55 sign of that yet. I just wonder what is happening about
56 that. Maybe that is something the Defendants might like to
57 come back to tomorrow.
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59 MR. MORRIS: We have a draft statement and we are expecting it
60 to be ready by the end of the week.
