Day 057 - 29 Nov 94 - Page 46
1 Langert from America -- I have not got him on my list --
2 said, from my recollection, day 9 page 74.
3
4 MR. JUSTICE BELL: Date again?
5
6 MR. MORRIS: Day 9 which is 8th July, page 74 -- sorry, it was
7 Mr. Kouchoukos saying about recycled content of their
8 packaging. Mr. Rampton asked him: "Can you do, again,
9 what you said you would do in relation to some figures of
10 Mr. Kouchoukos" -- sorry, it is Mr. Langert. "Can you when
11 you get home have another look at this and tell us when you
12 are satisfied for certain what those average recycled
13 content figures mean, send a letter?" I did not explain
14 that very well, but there was a whole issue here about
15 recycled content of packaging. I think it was in terms of
16 pre-consumer and post-consumer content. That was five
17 months ago.
18
19 MR. JUSTICE BELL: Yes. What are you asking for here, that you
20 be given a statement as soon possible of such explanation
21 as Mr. Kouchoukos now has?
22
23 MR. MORRIS: Yes, in fact, it would be useful if it was before
24 our witnesses on packaging; I mean, it is obviously
25 preferably before Mr. Oakley came. I am sorry I did not
26 raise it beforehand, but the Plaintiffs were under the
27 obligation to do that. I only just noticed it when we were
28 checking for today.
29
30 MR. JUSTICE BELL: I am not prepared to say to Mr. Rampton that
31 he cannot call one of his witnesses until that is dealt
32 with. I would have thought you could perfectly easily go
33 ahead and call yours but, subject to anything Mr. Rampton
34 says -----
35
36 MR. RAMPTON: My Lord, I am not aware that the Defendants have
37 any witness that would be capable of dealing with the
38 information anyway. But, my Lord, it is in hand. We
39 apologise to your Lordship for the fact that we are a bit
40 late in getting the information -- I say "late" not because
41 we are out of time, but simply because we like to keep up
42 as far as we can. In fact, Mrs. Brinley-Codd spoke to
43 Chicago yesterday and the information will be here as soon
44 it can be.
45
46 MR. JUSTICE BELL: Yes, I think expedition should now be shown
47 on that.
48
49 MR. RAMPTON: Yes, my Lord. We are well aware of that. That is
50 why she spoke to them. While I am on my feet, I might say
51 the same also applies to the accident statistics at F. We
52 are also conscious that those are due -- again I do not say
53 over due -- they are due and they are coming for both
54 countries, this country and the United States.
55
56 MR. JUSTICE BELL: So there is no dispute but that such accident
57 statistics as they -----
58
59 MR. RAMPTON: As usual, I have not given your Lordship the right
60 account because obviously I do not deal with these things
