Day 128 - 24 May 95 - Page 55


     
     1        years, an application for specific discovery of them, and
     2        we have it argued out the question of what they might
     3        contain and whether that is relevant is one of the matters
     4        which has to be considered.
     5
     6   MR. RAMPTON:  Of course, if I may say so, that is entirely how
     7        I see it myself.  No enquiry, I doubt, has been made about
     8        these documents because none of the lawyers knew about the
     9        existence, nobody thought to ask because nobody could see
    10        how they could be relevant.  No order, as far as I am aware
    11         -- this is all from memory -- has ever been made in
    12        relation to any such documents.
    13
    14   MR. JUSTICE BELL:  I do not remember them being raised.
    15
    16   MR. RAMPTON:  I do not either.
    17
    18   MR. JUSTICE BELL:  Thank you Mr. Rampton.  Ms. Steel, the point
    19        is, if you think that you or Mr. Morris may be making an
    20        application for specific discovery at some stage in the
    21        future, near or far, what I suggest you do know (and then
    22        we can adjourn, subject to me asking a little bit about
    23        timing) is take the opportunity to ask Mrs. Barnes whether
    24        they contain matters which you will suggest are relevant,
    25        do you see?
    26
    27        It is merely a suggestion on my part, because if
    28        Mr. Rampton is going to argue in due course the mere fact
    29        that there are minutes of Health and Safety Task Force
    30        quarter meetings does not necessarily mean that they are
    31        relevant, in case he is going to argue that, you might take
    32        the opportunity to put to Mrs. Barnes or ask her about some
    33        of the things they might contain so that in due course, if
    34        you see fit, you can say to me:  "Well, that will be
    35        relevant to this issue in such and such a way", do you
    36        follow?
    37
    38   MS. STEEL:   OK.
    39
    40   MR. JUSTICE BELL:  I do not know whether you have some specific
    41        matter you want further information on in mind or whether
    42        it is just a general enquiry.
    43
    44   MS. STEEL:  I think I asked about electric shocks, although I am
    45        not sure.
    46
    47   MR. JUSTICE BELL:  Pursue that then.
    48
    49   MS. STEEL (To the witness):  Did you say that incidents of
    50        electric shocks have been discussed at these Task Force 
    51        meetings and ways of preventing, cutting down the number of 
    52        electric shocks? 
    53        A.  I am not sure any more of the exact conversations that
    54        went on in the meeting, but certainly electric shocks would
    55        have been raised.  I am not sure to your second point,
    56        whether that information would be there.
    57
    58   Q.   Whether that information would be what, sorry?
    59        A.  You are asking whether there was information there
    60        about how the Company would react in terms of preventing

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