Day 067 - 15 Dec 94 - Page 31


     
     1
     2   MR. JUSTICE BELL:  -- which dates from some twenty months ago
     3        which is not the point which Ms. Steel is on at the moment;
     4        that is not to say that it may not be a valuable document
     5        in the case.  That is the only document you had in mind
     6        when you gave your answers a few moments ago, is it?
     7        A.  Yes.
     8
     9   Q.   Let us press on to five to one.
    10
    11   MR. RAMPTON:  I would like to find out a bit more about this.
    12
    13   MR. JUSTICE BELL:  When I rise at five to one, let it be handed
    14        to Ms. Steel and Mr. Morris.  They can read it through
    15        before 1 o'clock.
    16
    17   MR. RAMPTON:  My Lord, I am somewhat hesitant about that.  I do
    18        not know what its status is.  I do not think it is a
    19        privileged document, but here it is.
    20
    21   MR. JUSTICE BELL:  It did not look like a privileged document to
    22        me.
    23
    24   MR. RAMPTON:  No, I think it probably is not.  It has some
    25        handwriting on it; I do not know whose that is.
    26
    27   THE WITNESS:  That handwriting is, the signatures is from, that
    28        it says "Paul", that is Paul Simmonds, and he is providing
    29        copies to myself and other people in the meat area.
    30
    31   MR. JUSTICE BELL:  Carry on with your cross-examination for the
    32        moment.  At five to one I will rise.  By then -- it is not
    33        a long document -- you should have been able to see whether
    34        there is any possibility of privilege.  I have to say
    35        I cannot see it myself from what I looked at.
    36
    37   MR. MORRIS:  That document (which we have not seen yet), when
    38        you were trying to ascertain what animal welfare policy
    39        would be, guidelines, that is something which Paul Simmonds
    40        gave to you, is it, as the best available document?
    41        A.  That document?
    42
    43   Q.   Yes.
    44        A.  That particular document?  This is only a part of our
    45        discussions that we had.  We had a lot of conversation
    46        about the intent of the Humane Slaughter Act, about our
    47        policies and interpretation of those policies and the
    48        things that are within our control.  So, that is one of the
    49        papers that he gave me a copy so that I could have -- we
    50        could discuss in more detail the policy. 
    51 
    52        I hope you understand that it is very difficult to produce 
    53        a form which will contain all of the details of the Humane
    54        Slaughter Act.  If you have not -- I believe you have seen
    55        the book, it is a very thick book.  We could not use, we
    56        can spend an entire life just trying to answer every single
    57        detail that is included there so we can verify everything
    58        that is included there.  For that reason, I developed the
    59        form, thinking in the concept and again trying to address
    60        the specific allegations that were made in this case.

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