Day 072 - 12 Jan 95 - Page 29


     
     1        restaurant, customers do sit on the doorsteps, and it
     2        depends what she means by "a regular basis".  She has not
     3        said that we do not complete regular trash walks.  She just
     4        said that we should be more frequent.  She has not set a
     5        time on it.
     6
     7   Q.   So you are saying that she thinks that every half an hour
     8        is not frequent enough?
     9        A.  No.  I am saying that she has not defined what the
    10        regular basis is, because a customer can take five minutes
    11        to complete their meal and if they are using that doorstep
    12        one after another there could be a mound of environment/index.html">litter before
    13        next trash walk comes around.
    14
    15   Q.   Did you speak to Mrs. Earle?
    16        A.  To my knowledge, I cannot recall at this moment.
    17
    18   MR. JUSTICE BELL:  Does Royal Avenue number down from the Kings
    19        Road, so that 1 is very close to you and 4 pretty close?
    20        Can you remember now?
    21        A.  Sorry, sir?
    22
    23   Q.   Does Royal Avenue number down from the Kings Road so that
    24        No. 4 would be right up your end or pretty close to your
    25        end?
    26        A.  No. 4 would be -----
    27
    28   Q.   Can you remember?
    29        A.  Sorry, sir, No. 4 would be on the opposite side of the
    30        square, I believe, but it is quite close to the store
    31        because it is a square and it would only be a matter of 50
    32        or 100 yards.
    33
    34   MS. STEEL:  So it would be visible from the store?
    35        A.  Yes.
    36
    37   Q.   So you could make sure that at five minute intervals
    38        somebody looks over there and sees whether there is rubbish
    39        sitting on the step?
    40        A.  Well, the manager has a lot of responsibilities and so
    41        does the lobby hostess.  I cannot ask them to be
    42        responsible for looking after Mrs. Earle's doorstep apart
    43        from a half hourly basis which, I believe, is reasonable.
    44
    45   MR. JUSTICE BELL:  I think I have my geography right now.  The
    46        reason why I asked if Safeways was in the gap between
    47        Walpole Street and Cheltenham Terrace is I thought the
    48        Square was formed by Royal Avenue and Walpole street but
    49        the Square is actually Royal Avenue?
    50        A.  The map is deceiving, yes. 
    51 
    52   Q.   It is a very wide avenue with what you call a square in the 
    53        middle?
    54        A.  Yes, that is right, sir.  The map is quite deceiving.
    55        It is hard to see the square in the centre of Royal Avenue.
    56
    57   MS. STEEL:  It only takes two, three seconds, possibly even one,
    58        in fact, to look across the road and see if there is any
    59        environment/index.html">litter on her step.  It is not something that is going to
    60        take up a lot of their time?

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