Day 102 - 13 Mar 95 - Page 34


     
     1        A.  I do not know specifically, certainly, I mean, their
     2        contracts were terminated.  Whether it is right to say they
     3        were sacked because I think some of them went to work for
     4        the contractors, so -- but certainly they were taken out of
     5        Sun Valley employment.
     6
     7   Q.   Have you still got the yellow bundle IX there, please?
     8        Could you turn to your appendix four on page 59?
     9        A.  Yes.
    10
    11   Q.   Under No. 12, "Chicken Loading", can you just explain the
    12        figures?  It has "27 per drawer 5 x 4/hand x 3"; can you
    13        just explain what that means?
    14        A.  Well, "4 per hand" means that they have four in each
    15        hand.
    16
    17   Q.   So four in each hand is quite standard because most of
    18        those, well, two-thirds of those are four in a hand?
    19        A.  Yes.
    20
    21   Q.   Then what does the "5 x 4/hand", four to a hand mean?
    22
    23   MR. JUSTICE BELL:  Are you sure that is right?  How do you make
    24        up to 27.  If you do the arithmetic backwards, what does it
    25        mean?
    26        A.  I cannot work it out either, my Lord.
    27
    28   Q.   If, for instance, it was five in one hand and four in
    29        another three times over it would be 27?
    30        A.  Yes.  I think probably the only way it could work out
    31        is if you have five in one hand and four in the other hand
    32        and you put three, that would make 27.  That is the only
    33        way it can be.
    34
    35   MS. STEEL:   So some of them would carry six in a hand?
    36        A.  That is what it would appear from the instruction,
    37        although I have never seen that personally.
    38
    39   Q.   Have you never seen anyone carrying six or seven birds in a
    40        hand at all?
    41        A.  When I am watching catching it is not something
    42        I specifically would have noticed, and the actual number of
    43        birds in a hand, I am not specifically counting them all
    44        the time so .....  Certainly, I have never observed seven
    45        and I cannot honestly say I have observed six.
    46
    47   Q.   You cannot say you are aware of having observed it?
    48        A.  I was not aware of it, no.
    49
    50   Q.   Can you just describe what would be the ideal method that 
    51        the catchers would pick up the birds and get them into the 
    52        drawers? 
    53        A.  Well, I think with this procedure the important thing
    54        is that it is done with care.  It can be done with care if
    55        it is not done in a tearing hurry.  I cannot describe any
    56        more than you can imagine, that you pick up birds by hand
    57        and you put them in the drawer.  You do not throw them; you
    58        place them in the drawer.
    59
    60   Q.   They are upside-down, are they not?

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