Day 149 - 06 Jul 95 - Page 31
1 where their suppliers came from, or might have a reaction.
2
3 MR. RAMPTON: He might or might not. Anyhow, there is the
4 list. We will do a bit of work to find earlier lists as
5 well.
6
7 My Lord, next -- again, I have no real objection to it,
8 except that I do find having to produce documents which are
9 then sort of looked at once and discarded really an awful
10 waste of my client's time and money -- there is the US
11 observation checklists. If we had to, I think we would
12 probably argue that these are not, in fact, relevant. The
13 English ones, the British ones are, because complaints are
14 made by the Defendants witnesses about inadequate training,
15 which is principally what the OCLs relate to. There is no
16 allegation to similar effect about the United States. The
17 Defendants do not, as far as I am aware, have any expert or
18 current McDonald's witness from the United States, and
19 certainly nothing in the abstract of the pleading.
20
21 My Lord, if I had to argue on strict legal grounds that
22 these were irrelevant, I would do so. The note I made to
23 myself was, in effect, the first submission I made to your
24 Lordship: just more pointless paper.
25
26 MR. MORRIS: Does that mean he is saying he is going to provide
27 them?
28
29 MR. RAMPTON: No -- unless ordered to do so. To help
30 Mr. Morris, my submission is: not relevant and not
31 necessary, in relation to that.
32
33 MS. STEEL: It was just a bit confusing, because Mr. Rampton
34 started off saying he did not know if he had any objection
35 to it.
36
37 MR. JUSTICE BELL: Do not worry. Mr. Rampton has made it clear
38 now.
39
40 MR. RAMPTON: My Lord, my next one was documents referred to the
41 in the Health and Safety Minutes.
42
43 MR. JUSTICE BELL: Just pause a moment. Yes, the response to
44 the HSE report and the report on hustle.
45
46 MR. RAMPTON: Yes. We will certainly disclose them or such part
47 of them as are relevant. As your Lordship I think said at
48 the time, it is likely that they mostly are, and I quite
49 agree with that. So we will get on to that straightaway.
50
51 My Lord, the next one was the Dan Gallein letter to which
52 Mr. Stein referred to -- I did not refer to it, contrary to
53 what Mr. Morris said -- in re-examination. I did not have
54 a copy at the time. I had not seen it at the time. I do
55 now have a copy, faxed to me actually -- it is not often
56 I get one of these faxes -- by McDonald's lawyers in
57 St. Louis, Missouri, at the request of Mr. Steve Brown, who
58 was in court last week, as your Lordship may recall.
59 Whether it is relevant or not -- and I very much doubt
60 it -- I have no objection to disclosing it. Your Lordship
