Day 057 - 29 Nov 94 - Page 46


     
     1        Langert from America -- I have not got him on my list --
     2        said, from my recollection, day 9 page 74.
     3
     4   MR. JUSTICE BELL:  Date again?
     5
     6   MR. MORRIS:  Day 9 which is 8th July, page 74 -- sorry, it was
     7        Mr. Kouchoukos saying about recycled content of their
     8        packaging.  Mr. Rampton asked him:  "Can you do, again,
     9        what you said you would do in relation to some figures of
    10        Mr. Kouchoukos" -- sorry, it is Mr. Langert.  "Can you when
    11        you get home have another look at this and tell us when you
    12        are satisfied for certain what those average recycled
    13        content figures mean, send a letter?"  I did not explain
    14        that very well, but there was a whole issue here about
    15        recycled content of packaging.  I think it was in terms of
    16        pre-consumer and post-consumer content.  That was five
    17        months ago.
    18
    19   MR. JUSTICE BELL:  Yes.  What are you asking for here, that you
    20        be given a statement as soon possible of such explanation
    21        as Mr. Kouchoukos now has?
    22
    23   MR. MORRIS:  Yes, in fact, it would be useful if it was before
    24        our witnesses on packaging; I mean, it is obviously
    25        preferably before Mr. Oakley came.  I am sorry I did not
    26        raise it beforehand, but the Plaintiffs were under the
    27        obligation to do that.  I only just noticed it when we were
    28        checking for today.
    29
    30   MR. JUSTICE BELL:  I am not prepared to say to Mr. Rampton that
    31        he cannot call one of his witnesses until that is dealt
    32        with.  I would have thought you could perfectly easily go
    33        ahead and call yours but, subject to anything Mr. Rampton
    34        says -----
    35
    36   MR. RAMPTON:  My Lord, I am not aware that the Defendants have
    37        any witness that would be capable of dealing with the
    38        information anyway.  But, my Lord, it is in hand.  We
    39        apologise to your Lordship for the fact that we are a bit
    40        late in getting the information -- I say "late" not because
    41        we are out of time, but simply because we like to keep up
    42        as far as we can.  In fact, Mrs. Brinley-Codd spoke to
    43        Chicago yesterday and the information will be here as soon
    44        it can be.
    45
    46   MR. JUSTICE BELL:  Yes, I think expedition should now be shown
    47        on that.
    48
    49   MR. RAMPTON:  Yes, my Lord.  We are well aware of that.  That is
    50        why she spoke to them.  While I am on my feet, I might say 
    51        the same also applies to the accident statistics at F.  We 
    52        are also conscious that those are due -- again I do not say 
    53        over due -- they are due and they are coming for both
    54        countries, this country and the United States.
    55
    56   MR. JUSTICE BELL:  So there is no dispute but that such accident
    57        statistics as they -----
    58
    59   MR. RAMPTON:  As usual, I have not given your Lordship the right
    60        account because obviously I do not deal with these things

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