Day 164 - 26 Sep 95 - Page 17
1 disappeared but I made a list for myself, you raised the
2 question of some witness statements given in the course of
3 an investigation in Lyons. You raised the question of some
4 documents in relation to the bar store, the Operations
5 Manual, the Towers and Perrin full report, management and
6 crew scheduling, disk and hard copy, and full Enquiry
7 Agents' notes and any response to the HSE investigation
8 unit report, if you do not accept Mrs. Brinley-Codd's
9 answer about that.
10
11 MR. MORRIS: If we can do those, not necessarily in that order
12 because I have various letters at different times.
13
14 The Operations Manual, Mrs. Brinley-Codd said that we would
15 get a copy of that tomorrow so that does not need to be
16 discussed.
17
18 MR. RAMPTON: No, I do not think that is right.
19
20 MS. STEEL: I asked Mrs. Brinley-Codd for copies of documents
21 yesterday and she said, well, I was asking about a number
22 of matters in relation to the counterclaim and she said:
23 "I cannot get them all to you tomorrow", i.e. today,
24 "because the Operations Manual is very bulky, but is
25 Wednesday OK?" I said: "Yes".
26
27 MR. RAMPTON: Whatever Mrs. Brinley-Codd may have said or
28 Ms. Steel may have thought Mrs. Brinley-Codd may have said,
29 the position is this, that we will provide in our usual way
30 copies of the discovery which we make in relation to the
31 counterclaim. That, I think, is what is coming tomorrow.
32 We will provide the Defendants with their strict rights
33 under the rules in relation to the Operations Manual. We
34 offered them at the beginning of August the opportunity to
35 come and inspect it and to take such copies, or have taken
36 such copies, of such parts of it that they may wish to have
37 copied at their expense. That is where we stand on the
38 Operations Manual.
39
40 MS. STEEL: It was not at the beginning of August though.
41
42 MR. RAMPTON: It was on 7th August.
43
44 MR. MORRIS: If the Plaintiffs want to bill the Defendants for
45 providing copies of the Operations Manual that they were
46 ordered to disclose, then, presumably, if that is the rule,
47 that is their prerogative, but the Defendants could also
48 take the same position with the provision of documents that
49 we provide to the Plaintiffs. I do not necessarily think
50 that takes us much further. It will be much more work for
51 us, more complication but I think that the court -----
52
53 MR. RAMPTON: May I say this about the Operations Manual so that
54 we can get it out of the way? It is a special case. It is
55 a very long document. We have stapled a part of it which
56 we do not think is in any sense relevant. That has to do
57 with security and insurance in the stores. Much of the
58 rest of it that we are willing that the Defendants should
59 see that they have not already seen we think is of only
60 marginal relevant, but we are willing for them to see it.
