Day 008 - 07 Jul 94 - Page 52


     
     1
         MISS STEEL:  Something indicating what percentage was used at
     2        the time; something indicating the percentage that was
              made from recycled content at the time.  Presumably, they
     3        have to find them to be able to work out the calculations
              anyway.
     4
         MR. JUSTICE BELL:  Maybe.  If in the summary which one gets one
     5        has a summary of the source of the information, then we
              can see what, if any, further discovery is required in
     6        relation to that.
 
     7   MR. MORRIS:  Maybe it would be useful if the documents that are
              perused to make the summary were attached to the summary.
     8
         MR. JUSTICE BELL:  If that can be done; I do not know what it
     9        involves looking at.  You have heard what the argument is?
              A.  It is perfectly clear to me.
    10
         MR. JUSTICE BELL:  We have figures in the right-hand column.
    11        It all looked nice and simple, if the figures in the
              right-hand column were correct.  Depending on how much one
    12        was interested, one could go back to the earlier columns
              and where you got those figures from to check them.  You
    13        are suggesting they are not accurate.  You have given your
              reasons for that.
    14
              If you and Mr. Kouchoukos come up with a common view of
    15        what the accurate figure is, you will obviously have to
              provide, if that is going to carry any weight, some kind
    16        of source documentation to show where you have your new
              view from, or your new figure from.
    17
              I am not suggesting at the moment that that needs vast
    18        paper work.  I suggest what you do is put in the hands of
              Barlows what you think is necessary to support the new
    19        view, whatever it is.  Then, if the defendants say they
              should have more documentation, I can decide whether that
    20        should be so or not.
 
    21   MR. RAMPTON:  Is that a relatively simple undertaking?
              A.  Yes.  This is a very simple thing.  I understand it
    22        completely.
 
    23   MR. JUSTICE BELL:  I assume you are not going to look at
              thousands of sheets of paper or we will not get something
    24        in the next week or two?
              A.  No.  All the information at hand.
    25
         MR. RAMPTON:  I do not want Miss Steel and Mr. Morris to think 
    26        that once again that anything is being covered up or 
              anything.  In what sort of form do you expect the 
    27        information will be?
              A.  We will have documents at Perseco related to the
    28        purchasing volumes at that point in time.  We will also
              have documentation of, for instance, napkins.  We will
    29        able to demonstrate that one or two suppliers use recycle
              napkins as part of their specification.
    30
         Q.   As his Lordship said, it would be helpful when you prepare

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