Day 195 - 04 Dec 95 - Page 49


     
     1   Q.   Yes.  I thought that might be the case.  The same is true
     2        of the next paragraph, is it not?  It is what Simon Warr
     3        told you, is it not?
     4        A.  There was no reason to assume they are lying when they
     5        are telling me that.
     6
     7   Q.   I forgive you, Mr. Alimi, for not being ----
     8
     9   MR. JUSTICE BELL:  You are being asked for a specific reason,
    10        you see, due to our laws of evidence.  You are not being
    11        asked to excuse the fact that you put it in your statement
    12        at the moment.  You are being asked for the basis of the
    13        information in your statement.
    14
    15   MR. RAMPTON:  We find the same thing, Mr. Alimi, at the bottom
    16        of the page, do we not:  "No prior warning".  This is prior
    17        notice of being asked to do late closes, is it not?
    18        A.  Where are we, sorry?
    19
    20   Q.   No. 2 on the same page on page 2:  "No prior warning"?
    21        A.  OK.
    22
    23   Q.   Is this what you are talking about?  "95 per cent of the
    24        time we were not given any prior notice"?
    25        A.  That is right.  Prior notice, yes, of when late closes
    26        were happening.
    27
    28   Q.   Do you mean by the "late" closes the all night closes?
    29        A.  No, I mean something like 3.00 to 4 o'clock in the
    30        morning.
    31
    32   Q.   So if your diary has 4.00 till close, what you are telling
    33        us is that it might turn out when you got there that it
    34        would be 3.00 or 4.00 in the morning as opposed to half
    35        past 12 or 1.00?
    36        A.  That is correct.
    37
    38   Q.   Then you say this:  "I do not have any dates and this did
    39        not refer to me because I was not on the telephone so they
    40        could not ring me to come in."
    41        A.  Yes.
    42
    43   Q.   In fact, what you are talking about is people being brought
    44        in when there was a staff shortage?
    45        A.  That is right.  That is how it has been put in there.
    46        It should not be really connected in that way.
    47
    48   Q.   That ringing people at the last moment to get them to come
    49        in if they were willing did not happen to you?
    50        A.  No, because I was not on the phone.  I would have been 
    51        told the day before on my shift that, you know, the next 
    52        day:  "Your shift has changed" but not -- they would not 
    53        have rung me up.
    54
    55   Q.   This last paragraph and the first paragraph on the next
    56        page are all what other people have told you, are they not?
    57
    58   MR. JUSTICE BELL:  Which one are we looking at now?
    59
    60   MR. RAMPTON:  Sorry, my Lord, the last paragraph:  "I do not

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