Day 173 - 16 Oct 95 - Page 54


     
     1   Q.   That is another two.  So that is five more.  While we are
     2        on that page, M. Boyle (number 13) was not mentioned at all
     3        at being O'Connell Street so he would be another name for
     4        the first page.  So what I am saying is, if we take
     5        something like 20 for O'Connell Street and something like
     6        12 -- this is the names we actually know from the actual
     7        documents -- we see something like 32 specific, or 30 to 32
     8        specific names identified.
     9        A.  I would not agree with that, Mr. Morris.
    10
    11   Q.   OK.
    12        A.  Have you counted them to that number, may I ask?
    13        Sorry, have you counted to that number?
    14
    15   Q.   I am accepting what you have said about O'Connell Street
    16        and I have gone into detail on Graphton Street and the
    17        court can draw its conclusions.
    18        A.  For example, may I draw your attention to the Graphton
    19        Street type list, Grainne Healy is on the type list but she
    20        is also on the handwritten list.
    21
    22   Q.   I understand that; I appreciate that.
    23        A.  So, I think there is duplication of names in some
    24        cases.
    25
    26   Q.   We have established that the vast majority of the names
    27        that you have actually typed up on those first two pages, 1
    28        and 2, were full-timers.  If we accept, the total number of
    29        workers you said in your affidavit which I referred to
    30        before was something over 150, yes, of employees in the
    31        Company?
    32        A.  Yes.
    33
    34   Q.   Do you remember?  You would accept something like between
    35        150 and 160, something like that, would you?
    36        A.  I think my affidavit said 150; in excess of 150.
    37
    38   Q.   Something near 150 but over 150?
    39        A.  Well, it is a long time ago.
    40
    41   MR. JUSTICE BELL:  He said "in excess of", and somewhere you
    42        have said 202.
    43
    44   MR. RAMPTON:  My Lord, that is a figure in the statement, but it
    45        also appears somewhere in the documents, I think.  I cannot
    46        remember where it is at the moment.
    47
    48   MR. MORRIS:  But you wrote your affidavit at the time that we
    49        are referring to, that was written at the time of the
    50        actual dispute, was it not? 
    51        A.  Yes, the one that is quoting 150. 
    52 
    53   Q.   Yes.
    54        A.  Yes.
    55
    56   Q.   OK.  If we accept that out of, say, 150 or 160 employees
    57        something like -- sorry, let me just -- based on your
    58        figures you said earlier this morning that it was something
    59        like six to eight were managers, two to three admin people
    60        ----

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