Day 127 - 23 May 95 - Page 44
1 A. Yes.
2
3 Q. You tell us. The accident happened on 25th July 1992; do
4 you see that?
5 A. I do.
6
7 Q. Right at the bottom two paragraphs; first there is a
8 paragraph about liaison and then it says, "Keith Smith sent
9 out a memo to all stores." Is it that that you think may
10 be the Keith Smith's memo we looked at earlier?
11 A. Yes, the September one.
12
13 Q. September 1992?
14 A. Yes.
15
16 Q. Then pass on, please, three pages. There is a drawing of a
17 plug; do you see?
18 A. I do.
19
20 Q. What does that represent?
21 A. This was the plug that was on the machine at Manchester
22 Arndale that caused ----
23
24 Q. Who drew that?
25 A. I drew that.
26
27 Q. So you based that on the information you have been given?
28 A. I did, yes.
29
30 Q. Did you ever actually see the plug yourself?
31 A. I did not, no, because the EHO took it.
32
33 Q. Then we have one of your charts on the next page; do you
34 see that?
35 A. I do.
36
37 Q. I do not, myself, believe it needs any explanation. What
38 is the purpose of it?
39 A. It is just referring to that, the cost benefit analysis
40 we went through earlier. This gives a status report in
41 December to senior management as to where we were with
42 complying with those recommendations.
43
44 Q. At the back of the document there are two pages of tables,
45 do you see? The document before that looks like a family
46 tree?
47 A. OK. That one is not in here, but that is the fault
48 tree analysis that I referred to.
49
50 Q. The fault tree analysis. I could not remember what you
51 called it. Yes, thank you.
52
53 MR. MORRIS: That is not part of the document.
54
55 MR. JUSTICE BELL: No, it does not look familiar to me.
56
57 MR. RAMPTON: That is an error in the copying only. There is no
58 secrecy or anything like that involved.
59
60 MR. JUSTICE BELL: Has that effectively got through your dealing
