Day 070 - 20 Dec 94 - Page 24
1 MR. JUSTICE BELL: That will be inserted where?
2
3 MR. RAMPTON: That is in tab 2.
4
5 MS. STEEL: We do want to bring up about these documents in a
6 while, but we have them on the list already. There are
7 some things we want to say, but if Mr. Rampton just goes
8 through them anyway.
9
10 MR. JUSTICE BELL: You are at the moment describing what is in
11 this bundle?
12
13 MR. RAMPTON: I am just telling your Lordship what is in this
14 bundle.
15
16 The third document is Spanish discovery relating to Madrid
17 or -- it is the nutrition squabble that there was between
18 McDonald's in Spain and some consumer body. That is
19 tab 3.
20
21 Tab 4 is 4, 5, 6, the issue with trade unions. 7, which is
22 the reason why I stood up originally, is the UK accident
23 statistics, done I hope in the form which your Lordship
24 asked for, which is in summary form. 8 is -----
25
26 MR. JUSTICE BELL: This?
27
28 MR. RAMPTON: Yes, my Lord. Your Lordship will know that the
29 RIDDOR accidents are those which are reportable by
30 statute. Those, therefore, are the more serious ones.
31
32 MR. JUSTICE BELL: Yes. I cannot for the life of me remember
33 what the definition is of what has to be reported and what
34 has not.
35
36 MR. RAMPTON: I do not know either, but there will be evidence
37 about that.
38
39 Then 8 is the decision of one of the United States courts
40 striking out the claim of Mr. Jeffery Miller, the judgment.
41 That is the judgment; United States judges call them
42 "opinions". All the rest of it, 9, 10 and 11 relates to
43 the question of publication and the injunction and no doubt
44 to the counterclaims.
45
46 My Lord, what is missing from there are the United States
47 accident statistics. There is a reason for that which, put
48 shortly, is that, to do what the English company has been
49 able to do, that is to say, provide your Lordship with
50 annual statistics over a period of time for accidents which
51 matter -- I am not talking about stubbed toes or scratched
52 fingers, but accidents which have to be reported -- I am
53 reliably informed that it would take six weeks, ten hours a
54 day, to produce a similar document.
55
56 My Lord, it is not sufficient for me just to say that.
57 There is being prepared, so that your Lordship can see it,
58 a statement from the person in the United States who knows
59 how the system works there, explaining why that would be
60 so.
