Day 238 - 22 Apr 96 - Page 08


     
     1        A.   Yes, I have.
     2
     3   Q.   I have put the first statement behind the second two
     4        statements.  There is documentation behind that?
     5        A.   Yes.
     6
     7   Q.   In that file; is that correct?
     8        A.   Yes.
     9
    10   Q.   There is another file of documentation as well?
    11        A.   Yes.
    12
    13   MR. JUSTICE BELL:  Just think about where you are going, because
    14        I read all the papers in this section through again
    15        yesterday evening and I may have missed things, but it
    16        seems to me Miss Watson has got the essence in her two
    17        statements.
    18
    19   MR. MORRIS:  Yes.  I was not going to refer to hardly any of the
    20        documents except for maps really.
    21
    22   MR. JUSTICE BELL:  Yes.  Very well.  When Mr. Rampton comes to
    23        cross-examine, if he wishes to challenge anything, and if
    24        Miss Watson then wants to refer to any of the documents for
    25        support for what she has said, then that is another matter,
    26        but in taking her evidence in-chief to start with, it
    27        appears you have probably got the same view.  It seems to
    28        me that there is probably no need to refer to anything but
    29        the maps, and if you do not refer to anything but maps in
    30        evidence in-chief we avoid all sorts of arguments about
    31        what the status of the document is anyway.
    32
    33   MR. MORRIS:  Right.  I am just wondering whether it might be
    34        helpful to actually have the maps out in front of us while
    35        going through the statements.
    36
    37   MR. JUSTICE BELL:  Which map do you want to use?
    38
    39   MR. MORRIS:   Well, the map which is that one, if we can get
    40        that out.  I think it is right behind your statement in
    41        your witness file.  I put it right behind it and it has got
    42        the three pages -- Mr. Rampton referred to the three pages
    43         -- of a key to it.
    44
    45        Now, I am not sure still which file it is in.  That is in
    46        the Kingfisher file of supplementary documents we served a
    47        number of months ago.
    48
    49   MR. JUSTICE BELL:  In the papers behind Miss Watson's statement
    50        I have got this and the key to it.  Is that what was in 
    51        supplementary 8? 
    52 
    53   MR. MORRIS:   Have you got the 3-page key?
    54
    55   MR. JUSTICE BELL:   Yes, three pages.
    56
    57   MR. MORRIS:  That is the document that we want.
    58
    59   MR. JUSTICE BELL:  535 to 537?
    60

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