Day 173 - 16 Oct 95 - Page 21


     
     1        other way short of actually losing employment; and there is
     2        the question of low pay.
     3
     4        I would urge you to consider whether, having had all the
     5        evidence we have had so far, it is really worth
     6        cross-examining Mr. Mehigan about that when you are coming
     7        very soon, actually, to call active evidence of your own on
     8        the topics.  Think about how much you add to your case by
     9        asking Mr. Mehigan questions like that, when you have quite
    10        a lot of evidence and McDonald's witnesses have said what
    11        they have to say about it.  I am literally waiting to hear
    12        what your witnesses have to say.
    13
    14   MS. STEEL:   That was all I was going to ask about breaks, but
    15        there is a specific reason for performance reviews, and
    16        I will be coming back to it shortly.
    17
    18   MR. JUSTICE BELL: I have said it now before the break, because
    19        it seems to me that you could restrict your
    20        cross-examination to those three topics which I have
    21        enumerated to good effect, without losing anything, and
    22        probably to more effect so far as the advancements of the
    23        proceedings are concerned.  Then I will hear what your
    24        witnesses have to say.  I will come back at five to 12.
    25
    26                          (Short adjournment)
    27
    28   MS. STEEL:   If you could find the new documents that were
    29        served last week, they should be in pink volume XIII B at
    30        the back of tab 59A.
    31        A.  Excuse me, 59?
    32
    33   Q.   59A, tab 59A.  The first page, O'Connell Street, three
    34        months before the strike.  Is that what you have got?
    35        A.  Yes.
    36
    37   Q.   Where were these documents found?
    38        A.  In one of our files in our office.
    39
    40   Q.   What, at Head Office in Ireland?
    41        A.  At my office.
    42
    43   Q.   In your office in Ireland?
    44        A.  Correct.
    45
    46   Q.   Sorry?
    47        A.  Sorry, yes, that is correct.
    48
    49   Q.   Were they in a file relating to the dispute?
    50        A.  No, they were in a file that -- we were looking for 
    51        something else and we found it. 
    52 
    53   Q.   When was that, that you found them?
    54        A.  Last week.
    55
    56   Q.   What, the beginning of last week or the end of last week?
    57        A.  No, the end of last week.
    58
    59   Q.   You were not looking for these, you say?
    60        A.  No.  My secretary was looking for something which

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