Day 142 - 26 Jun 95 - Page 39


     
     1        A.  Excuse me?
     2
     3   Q.   With Germany there are a lot of different allegations so it
     4        is a bit difficult to co-ordinate the questioning on this.
     5
     6   MR. JUSTICE BELL:  Do you have it clear in your mind what you
     7        want to achieve in relation to Germany?
     8
     9   MR. MORRIS:  I think with Germany there are a number of
    10        different pleadings.  I am finding it difficult to
    11        cross-reference all the different documents on this
    12        subject.  I cannot remember if the Plaintiffs were actually
    13        going to call someone from Germany, Eva Marie Sachse?
    14
    15   MR. JUSTICE BELL:  There was Miss or Frau Sachse.
    16
    17   MR. RAMPTON:  Eva Marie Sachse.  The position was that we said
    18        that if we -----
    19
    20   MR. JUSTICE BELL:  You were hoping to but then there was a query
    21        over her health or something, was there not?
    22
    23   MR. RAMPTON:  No, my Lord, it was this, that your Lordship said
    24        that if we were not going to call her we should answer the
    25        interrogatories.
    26
    27   MR. JUSTICE BELL:  That is right.
    28
    29   MR. RAMPTON:  That is what we did, so she is not being called.
    30
    31   MR. JUSTICE BELL:  Yes.  Work on the basis she is not coming,
    32        Mr. Morris.
    33
    34   MR. MORRIS (To the witness):  You have some knowledge of the
    35        German situation?
    36        A.  Yes, I do.
    37
    38   Q.   Have you visited Germany over a number of years?
    39        A.  Yes, I have.
    40
    41   Q.   Including at times when there were negotiations with the
    42        union, NGG union?
    43        A.  I would be there at times when negotiations were taking
    44        place.  I was not participating in the negotiations, if
    45        that is what you are asking.
    46
    47   Q.   I am trying to find the pleadings.
    48
    49   MR. JUSTICE BELL:  There is one at 20.
    50 
    51   MR. MORRIS:  I know there are a number of different ones. 
    52 
    53   MR. JUSTICE BELL:  Yes.  Can you not just recall without
    54        necessarily looking at the pleading what the point is on
    55        which you think Mr. Stein might be able to give you some
    56        information which is helpful to your case?
    57
    58   MR. MORRIS:  Yes, it is not 20 or 45.  I think there is one at
    59        the end.
    60

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