Day 146 - 03 Jul 95 - Page 17


     
     1        procedures which are carried out at Jarretts from 5 through
     2        to the end of 7.
     3
     4        My Lord, 8 explains why it is that the original plan which
     5        was produced in a hurry does not give all the detail that
     6        it would have done if Ms. Hovi's statement had been
     7        sufficient and adequate, and tells your Lordship what is in
     8        the new plan, including every sterilization and washing
     9        apron facility, the location of all the important people
    10        and the areas in which the washing of carcasses, in fact,
    11        takes place.
    12
    13   MR. MORRIS:  Sorry, I am lost here.  What are we referring to?
    14
    15   MR. RAMPTON:  Page 5.
    16
    17   MS. STEEL:  Can I just say, you know, there are a lot of things
    18        that obviously we want to say about a lot of things, but I
    19        just think it is completely ridiculous to blame Ms. Hovi
    20        for their inaccurate plan.  They are the ones responsible
    21        for drawing it.
    22
    23   MR. JUSTICE BELL:  Listen to Mr. Rampton and then you will have
    24        an opportunity to say whatever you wish in answer.
    25
    26   MR. RAMPTON:  My Lord, I do not actually blame Ms. Hovi; I blame
    27        the Defendants because ---
    28
    29   MR. MORRIS:  It is our fault for an inaccurate plan!
    30
    31   MR. RAMPTON:  -- if the Defendants had taken the opportunity,
    32        which Ms. Hovi evidently offered them, to provide the
    33        detail to us in advance of her giving evidence, the full
    34        plan would have been provided in advance of that time.  It
    35        is not Ms. Hovi's plan.
    36
    37   MS. STEEL:  So they were just drawing the plan to suit the
    38        evidence.
    39
    40   MR. JUSTICE BELL:  No, please, we must follow the normal course
    41        of events; you know it perfectly well.  Just wait your time
    42        and then you can say whatever you wish to me.
    43
    44   MR. RAMPTON:  The fact is that the plan was drawn to meet the
    45        evidence which, on the face of her statement, it was
    46        believed that Ms. Hovi could give and not some new,
    47        improved story.
    48
    49        My Lord, if one looks at paragraph 9 on page 6, here again,
    50        though there is a generalisation about clean and dirty 
    51        side, from here on for several pages one gets an answer to 
    52        detailed matters of criticism of which the statement was 
    53        completely devoid.
    54
    55        The first thing one notices is the mention of the lack of
    56        boot washing facilities.  There is nothing about that in
    57        Ms. Hovi's statement.  There are certainly several pages of
    58        it in her examination-in-chief.  At the bottom of page 6,
    59        my Lord, and the top of page 7, the allegation made by
    60        Ms. Hovi in-chief, but not in her statement, that "... men

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