Day 134 - 13 Jun 95 - Page 09
1
2 Q. Just moving on to something else: Can you get pink volume
3 XII, please? If you could turn to tab 40, please?
4 A. Yes, I have it.
5
6 Q. If you turn to page 700, just because it is a bit easier to
7 read?
8 A. Yes.
9
10 Q. What are these documents compiled from?
11 A. Various records. They will be from various different
12 areas. Do you want to ask me -----
13
14 Q. Do you know which areas?
15 A. I do not know which specific pieces of paper, if that
16 is what you mean.
17
18 MR. JUSTICE BELL: First, let us start with this, would you know
19 in 1990 (which is the page Ms. Steel has picked partly
20 because of its legibility), just looking there, would you
21 expect all that information to be on a computer somewhere?
22 A. Yes, it will have been then; whether it would be now, I
23 do not know but it will have been then.
24
25 Q. No. But just deal with the questions as they are asked.
26 Because if it is on computer it seems to me reasonable to
27 assume that you have a program which meant that the source
28 information having been put in somewhere or other, for
29 instance, at individual stores throughout the country, and
30 having been transferred either the moment it was put in or
31 by some additional exercise later to the computer in
32 central office, one can just program in, one can type in
33 the appropriate code, and get a printout of that
34 nature ---
35 A. Yes, I would think so.
36
37 Q. -- like that. I mean, the program does it all for you. If
38 you put in the code it will acquire for you the information
39 which is required to produce a hard copy in that tabulated
40 form. Do you know about this yourself or not?
41 A. What I know is that this information will have been
42 taken from different sources. It will not all have been in
43 one report as it appears here.
44
45 Q. No, what I am getting at, when you were asked where it came
46 from, you made an answer which referred to not knowing
47 which specific pieces of paper. What I am doubting is that
48 there would be any pieces of paper at all.
49
50 MR. RAMPTON: There might be. I am trying to be helpful again.
51 The last page of the F is in a different form. The last
52 document at F is about turnover but has the appearance of a
53 computer printout.
54
55 MR. JUSTICE BELL: What do you mean, at F?
56
57 MR. RAMPTON: Under E, sorry, of the new documents with
58 Ms. Mead's statement. As I observed yesterday, this gives
59 actual numbers as opposed to just percentages. I do not
60 know, of course, whether that is the foundation for the
