Day 070 - 20 Dec 94 - Page 24


     
     1   MR. JUSTICE BELL:  That will be inserted where?
     2
     3   MR. RAMPTON:  That is in tab 2.
     4
     5   MS. STEEL:  We do want to bring up about these documents in a
     6        while, but we have them on the list already.  There are
     7        some things we want to say, but if Mr. Rampton just goes
     8        through them anyway.
     9
    10   MR. JUSTICE BELL:  You are at the moment describing what is in
    11        this bundle?
    12
    13   MR. RAMPTON:  I am just telling your Lordship what is in this
    14        bundle.
    15
    16        The third document is Spanish discovery relating to Madrid
    17        or -- it is the nutrition squabble that there was between
    18        McDonald's in Spain and some consumer body.  That is
    19        tab 3.
    20
    21        Tab 4 is 4, 5, 6, the issue with trade unions.  7, which is
    22        the reason why I stood up originally, is the UK accident
    23        statistics, done I hope in the form which your Lordship
    24        asked for, which is in summary form.  8 is -----
    25
    26   MR. JUSTICE BELL:  This?
    27
    28   MR. RAMPTON:  Yes, my Lord.  Your Lordship will know that the
    29        RIDDOR accidents are those which are reportable by
    30        statute.  Those, therefore, are the more serious ones.
    31
    32   MR. JUSTICE BELL:  Yes.  I cannot for the life of me remember
    33        what the definition is of what has to be reported and what
    34        has not.
    35
    36   MR. RAMPTON:  I do not know either, but there will be evidence
    37        about that.
    38
    39        Then 8 is the decision of one of the United States courts
    40        striking out the claim of Mr. Jeffery Miller, the judgment.
    41        That is the judgment; United States judges call them
    42        "opinions".  All the rest of it, 9, 10 and 11 relates to
    43        the question of publication and the injunction and no doubt
    44        to the counterclaims.
    45
    46        My Lord, what is missing from there are the United States
    47        accident statistics.  There is a reason for that which, put
    48        shortly, is that, to do what the English company has been
    49        able to do, that is to say, provide your Lordship with
    50        annual statistics over a period of time for accidents which 
    51        matter -- I am not talking about stubbed toes or scratched 
    52        fingers, but accidents which have to be reported -- I am 
    53        reliably informed that it would take six weeks, ten hours a
    54        day, to produce a similar document.
    55
    56        My Lord, it is not sufficient for me just to say that.
    57        There is being prepared, so that your Lordship can see it,
    58        a statement from the person in the United States who knows
    59        how the system works there, explaining why that would be
    60        so.

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