Day 148 - 05 Jul 95 - Page 47
1 tests etc., and she (Ms. Hovi) was responding to that when
2 she went into further detail in her evidence.
3
4 No. 7, I am not quite sure why that is supposed to be
5 something new that is raised by Ms. Hovi. I do not know
6 understand that. It does not refer to a specific part of
7 her evidence and I do not follow that. That is up to the
8 Plaintiffs to state how that comes in as a result of what
9 Ms. Hovi said in evidence that was not in her statement.
10
11 The whole thing about the plan, I think, is particularly --
12 well, I do not quite know how to describe it, to be
13 honest. But the Company produced a plan which they say was
14 in response to her comment, the comment in her statement
15 about a shortage of cleaning facilities. If it was in
16 response to that, why did they not put in all the cleaning
17 facilities in the plant? Why did they do a plan? Why did
18 they not put in all the cleaning facilities in the plan?
19 Why did they do a half baked plan which only showed some of
20 them? Mr. Rampton said she had only made a generalised
21 comment. So they should have done a generalised plan which
22 covered everything.
23
24 To me, there is something a bit suspicious about producing
25 one plan and then changing the plan after a witness has
26 given evidence. We were told, when it was first produced,
27 that this was an accurate plan of the premises. It was
28 brought in on that basis.
29
30 When Ms. Hovi went into more detail about where particular
31 sterilizing and hand washing facilities were and there was
32 something about stepping up on to a platform, that was in
33 response to what was supposedly revealed in the plan. She
34 was saying, "No, the plan is inaccurate; you have to step
35 up there; that one would not be accessible to that person";
36 all that extra detail, that was in response to the
37 Plaintiffs' plan that they put forward as the accurate
38 representation of what went on at the plant. So, again,
39 that was not something new raised by her. That was
40 something raised by their introduction of a faulty plan -
41 well, what they say is now a faulty plan.
42
43 The business about the clean and dirty side of the
44 abattoir, which is paragraph 9 in Mr. Bone's statement.
45 There is an implication that this was something that
46 Ms. Hovi, although she mentioned in her statement she did
47 not give the details about approaching, about people who
48 work in the clean side of the abattoir having to come
49 through the dirty side, but that is in response to what
50 Mr. Bennett said when he was being examined on day 104,
51 page 29, where around about line 32 -- there is a bit
52 before that from line 24 onwards, where he talks about the
53 clean and the dirty sides being separate and being
54 approached by different roads, and goes into some detail
55 there.
56
57 Again, what Ms. Hovi said in evidence in the witness box,
58 obviously she went into more detail to respond to what
59 Mr. Bennett had said, because he had refuted her -- the
60 statement that she had put in her statement in the first
