Day 067 - 15 Dec 94 - Page 31
1
2 MR. JUSTICE BELL: -- which dates from some twenty months ago
3 which is not the point which Ms. Steel is on at the moment;
4 that is not to say that it may not be a valuable document
5 in the case. That is the only document you had in mind
6 when you gave your answers a few moments ago, is it?
7 A. Yes.
8
9 Q. Let us press on to five to one.
10
11 MR. RAMPTON: I would like to find out a bit more about this.
12
13 MR. JUSTICE BELL: When I rise at five to one, let it be handed
14 to Ms. Steel and Mr. Morris. They can read it through
15 before 1 o'clock.
16
17 MR. RAMPTON: My Lord, I am somewhat hesitant about that. I do
18 not know what its status is. I do not think it is a
19 privileged document, but here it is.
20
21 MR. JUSTICE BELL: It did not look like a privileged document to
22 me.
23
24 MR. RAMPTON: No, I think it probably is not. It has some
25 handwriting on it; I do not know whose that is.
26
27 THE WITNESS: That handwriting is, the signatures is from, that
28 it says "Paul", that is Paul Simmonds, and he is providing
29 copies to myself and other people in the meat area.
30
31 MR. JUSTICE BELL: Carry on with your cross-examination for the
32 moment. At five to one I will rise. By then -- it is not
33 a long document -- you should have been able to see whether
34 there is any possibility of privilege. I have to say
35 I cannot see it myself from what I looked at.
36
37 MR. MORRIS: That document (which we have not seen yet), when
38 you were trying to ascertain what animal welfare policy
39 would be, guidelines, that is something which Paul Simmonds
40 gave to you, is it, as the best available document?
41 A. That document?
42
43 Q. Yes.
44 A. That particular document? This is only a part of our
45 discussions that we had. We had a lot of conversation
46 about the intent of the Humane Slaughter Act, about our
47 policies and interpretation of those policies and the
48 things that are within our control. So, that is one of the
49 papers that he gave me a copy so that I could have -- we
50 could discuss in more detail the policy.
51
52 I hope you understand that it is very difficult to produce
53 a form which will contain all of the details of the Humane
54 Slaughter Act. If you have not -- I believe you have seen
55 the book, it is a very thick book. We could not use, we
56 can spend an entire life just trying to answer every single
57 detail that is included there so we can verify everything
58 that is included there. For that reason, I developed the
59 form, thinking in the concept and again trying to address
60 the specific allegations that were made in this case.
