Day 171 - 11 Oct 95 - Page 26


     
     1        statement he refers to the tripping out and the continuous
     2        problem with the chicken vats leading to food safety
     3        problems, and Mr. Richards initially thought that he was
     4        referring to them being affected by the RCD system, whereas
     5        Mr. Logan was specifically referring to a chicken vat that
     6        had continuous problems separate from the RCD problems.  So
     7        I think that if that is in the service history file, which
     8        Mr. Richards could not remember any of the vats having a
     9        problem, then I think that is an important thing to
    10        disclose.
    11
    12   MR. JUSTICE BELL:  Let me look at his longhand statement again.
    13
    14   MR. MORRIS:  It is point 22 in his statement about chicken.
    15
    16   MR. JUSTICE BELL:  I am looking at Mr. Logan -- yes.
    17
    18   MR. MORRIS:  He says: The vats were continually being repaired
    19        by service engineers approximately once every month or
    20        two.  The vats dripped out as often as two or three times a
    21        week."  That was not referring to -----
    22
    23   MR. JUSTICE BELL: If you were to succeed on this in relation to
    24        -- let us leave tripping RCD on one side, because I do not
    25        think there is any dispute that if there is documentation
    26        about that you should see it -- but toasters, the grease
    27        trough and the chicken vats, where no dates are given, any
    28        documentation about repairs of those, the years 1992, 1993
    29        and 1994 would be sufficient for your purposes, would they
    30        not?
    31
    32   MR. MORRIS:  Yes, I think so.
    33
    34   MR. JUSTICE BELL: Where you cannot give any dates.
    35
    36   MR. MORRIS:  It may be helpful to know that Mr. Richards says
    37        that the vats have now been replaced by a different model,
    38        which does indicate that there was some concern about them.
    39
    40   MR. JUSTICE BELL:  Well, not necessarily.
    41
    42   MR. MORRIS:  Well.
    43
    44   MR. JUSTICE BELL:  Even I replace my motor car every now and
    45        again.
    46
    47        Is there anything more you want to say about the report
    48        forms?  That is complete two-edged, from your point of
    49        view, because the less of those you find the better, from
    50        your point of view, is it not? 
    51 
    52   MR. MORRIS:  Yes, OK, I will accept that. 
    53
    54   MR. JUSTICE BELL:  So far, you have two allegations there of
    55        food poisoning; and your case is that they were not made
    56        out if there were complaints of undercooked food.  So what
    57        you what you want to wait and see is if you do get any
    58        incident report form in relation to undercooked food.
    59
    60   MR. MORRIS:  Yes.  I think that is our application completed.

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