Day 276 - 09 Jul 96 - Page 28


     
     1   Q.   When you say 'rather than the fold over', you mean rather
     2        than pull out do you?
     3        A.  Yes.
     4
     5   Q.   Which ever way you describe it?
     6        A.  Yes.  Two sheets of A4 folded together into A5 rather
     7        than one sheet of A3 folded into A5.
     8
     9   Q.   Yes?
    10        A.  Okay.  If we go on to the counterclaim.  I have done
    11        this from the bundle that actually appears in the
    12        counterclaim bundle behind our original defence and
    13        counterclaim.
    14
    15   Q.   You have done them from what?
    16        A.  I wanted to refer to the press releases.  I mean, they
    17        are probably in more than one bundle.
    18
    19   Q.   Well, you can choose which ever one you want.  They are
    20        behind?
    21        A.  They were behind the defence to counterclaim pleading
    22         -- no, sorry, the defence and counterclaim when we
    23        originally served them.
    24
    25   Q.   What, in the pleadings bundle?
    26        A.  Yes.
    27
    28   Q.   Well?
    29        A.  They are not in there?
    30
    31   Q.   No.
    32        A.  Well, the other place they will be is our supplementary
    33        list of documents, the most recent one that was served.
    34        With the ones with Ken Livingston in, which I want to refer
    35        to later anyway.  I think it is about supplementary bundle
    36        8, or something like that.
    37
    38   MR. RAMPTON:  My Lord, your Lordship will find them, I hope, if
    39        it is the release documents that are sought as the first 3
    40        or 4 tabs of counterclaim documents 1, the white and pink
    41        one.
    42
    43   MR. JUSTICE BELL:  Yes.
    44        A.  If they are in that bundle that I have just referred to
    45        -- I mean, I do want to refer to other ones in there
    46        anyway.  They appear in tab 1 of the bundle that I have
    47        just referred to.
    48
    49   MR. JUSTICE BELL:  Which is the bundle that you have in mind
    50        they are not in supplementary 8?
    51        A.  I know it was the last one that we served and it was
    52        the one with Ken Livingston's letter in it, and it should
    53        be a thin bundle.  Is that it in tab 1?
    54
    55   Q.   Yes.  Well, it is supplementary now.  I have them in a
    56        variety of places but it does not matter which ones you use
    57        as long as we are clear which ones you are referring to.
    58        A.  Yes, okay.  Turning to tab 1, it starts -- this is a
    59        page with the fax at the bottom, 14th March 1994, 17.20 and
    60        then Barlow Lyde & Gilbert's fax number.

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