Day 140 - 22 Jun 95 - Page 39


     
     1        see, we have a statement from the person who did the report
     2        a couple of days ago.  We have got some more information
     3        which we disclosed.  So we are contacting relevant people.
     4
     5   MR. JUSTICE BELL:  Just listen to me for a moment.  At some
     6        stage during your cross-examination -- and it matters not
     7        whether you or Ms. Steel does it -- if anti-union strategy
     8        in item 99 means more than the response to the PUP report,
     9        I would like you to put what it does mean to Mr. Stein, and
    10        I would like you to tip me the wink when you do so, so that
    11        I know that is what we are on.
    12
    13   MR. RAMPTON:  I must say, I would not mind knowing either, quite
    14        honestly.
    15
    16   MR. JUSTICE BELL:  I am going to wait and see.
    17
    18   MR. RAMPTON:  There have been no witness statements.
    19
    20   MR. JUSTICE BELL:  The thing is, if you do not do that, I will
    21        assume that anti-union strategy means response to the PUP
    22        report only.
    23
    24   MR. MORRIS:  Right, OK.
    25
    26   MR. JUSTICE BELL:  And there is nothing else I ought to have in
    27        my mind.
    28
    29   MR. RAMPTON:  My Lord, I will say this, if I may:  Mr. Morris
    30        has just said that his pleadings are not supposed to be
    31        comprehensive.  I do not accept that.  They are
    32        comprehensive, save in so far as they are expanded in the
    33        witness statements.
    34
    35   MR. JUSTICE BELL:  Yes.  I cannot remember -- and I am inviting
    36        you to remind me, if I have forgotten it -- that there is
    37        anything which might be considered to be an anti-union
    38        strategy in Philadelphia in or around 1989 or 1990, save to
    39        the response to the PUP report.  If I have forgotten or
    40        missed something, I want you by one route or another to
    41        tell me about it.  Five past two.
    42
    43                         (Luncheon Adjournment)
    44
    45   MS. STEEL:  If we go back to document 94?
    46
    47   MR. JUSTICE BELL:  In the second bundle?
    48
    49   MS. STEEL:  Pink XIV, I think it is.  (To the witness)  How long
    50        did you spend in Philadelphia on this matter? 
    51        A.  OK.  About, I would say, approximately eight days in 
    52        total. 
    53
    54   Q.   Was that around -- I think it was December when you were
    55        doing your internal verbal survey?
    56        A.  That would be -- the first occasion would not be the
    57        survey.  If you are asking me when was my first trip in
    58        there, my first trip did not include the survey.
    59
    60   Q.   What was the first occasion that you went down there?

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