Day 312 - 11 Dec 96 - Page 04


     
     1        particularly, the Defence to Counterclaim, and in
     2        particular the Defendants' reaction to the complaints in
     3        September 1990, I hope I gave your Lordship the letter of
     4        20th September 1990.  We have now, as it were,
     5        completed ----
     6
     7   MR. JUSTICE BELL:  You referred to it.
     8
     9   MR. RAMPTON:  Did I just read it out?
    10
    11   MR. JUSTICE BELL: I think you did, and I have assumed that
    12        I have it in the papers somewhere, though I do not have the
    13        reference to hand.  If there is any doubt, maybe it would
    14        be better to hand me a copy.
    15
    16   MR. RAMPTON:  It certainly would.  I do not have that letter
    17        here, but what I do have is all the succeeding
    18        correspondence which your Lordship certainly ought to have,
    19        and which I say now confirms that the Defendants' reaction
    20        was in private, as it were, to the solicitors although more
    21        dignified in essence no different from what it was in their
    22        public document.
    23
    24   MR. JUSTICE BELL: Yes.  What I will-----
    25
    26   MR. MORRIS:  Is this new stuff?
    27
    28   MR. RAMPTON:  No, it is correspondence.
    29
    30   MR. MORRIS:  Yes, but is it stuff that has been disclosed
    31        before?
    32
    33   MR. RAMPTON:  All correspondence will have been disclosed, I am
    34        perfectly certain.
    35
    36   MR. MORRIS:  I do not know.
    37
    38   MR. RAMPTON:  I suspect it was disclosed by the Defendants.
    39
    40   MR. MORRIS:  I doubt it.
    41
    42   MS. STEEL:  There are some attendance notes in here that we have
    43        never seen before.  I do not know whether there is any ----
    44
    45   MR. JUSTICE BELL:  I will look at that.  If you want to make an
    46        objection make it within the next few days.
    47
    48   MS. STEEL:   If we could read them first.
    49
    50   MR. JUSTICE BELL:  Yes.  If it does go in, if I could be given a
    51        copy of 20th September letter.
    52
    53   MR. RAMPTON:  Yes, my Lord.
    54
    55   MR. JUSTICE BELL:  Because it will be convenient to put it on
    56        top of that bundle anyway, so it is all in one piece.
    57
    58   MR. MORRIS:  Can we ask where the Plaintiffs got these documents
    59        from?
    60

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