Day 153 - 12 Jul 95 - Page 33


     
     1        A.  Yes, I am.
     2
     3   Q.   You can recollect it clearly now then, can you?
     4        A.  I can recollect clearly that the store did not get out
     5        on closes regularly at 3.00 or 4.00 in the morning.  I can
     6        recollect clearly that 3.00 or 4.00 in the morning would
     7        have been in absolute exception.  I cannot imagine the
     8        circumstances, to be honest, where it would take that long
     9        to get out of the restaurant, unless there was some major
    10        emergency.
    11
    12   Q.   If the store was under-staffed and you could not manage to
    13        get any volunteers to come in to help out, it might take
    14        longer than usual to clear up?
    15        A.  Very rare.
    16
    17   Q.   But it happened?
    18        A.  It might have happened on an odd occasion, as I have
    19        already said.
    20
    21   Q.   You said you would have known from the clock cards.
    22        A.  Yes.
    23
    24   Q.   Is that from looking at the clock cards, whenever it was,
    25        seven or eight years ago, well, eight, nine, 10 years ago,
    26        or is that from looking at the clock cards before you made
    27        your statement?
    28        A.  I have not looked at the clock cards sort of recently.
    29
    30   Q.   So you are doing it from memory from 10 years ago?
    31        A.  No, when I used to come in -- say, I came in in the
    32        morning, the first thing I would probably do is find out
    33        what time the close would get out, and we would encourage
    34        people to get out as early as possible on a close.  The
    35        closes were set up so that it took us the least time as
    36        possible to get out on a close.  We did not want them to
    37        drag on at all.
    38
    39   Q.   Yes, but if you were not there at the time -- you mentioned
    40        that you would have known from the clock cards?
    41        A.  Yes, sure.
    42
    43   Q.   What I am asking you is when you said that, were you
    44        referring to your memory of the clock cards that you saw 10
    45        years ago, or eight, nine or 10 years ago, or are you
    46        referring to you have seen them more recently than that,
    47        i.e. prior to making your statement or something like that?
    48        A.  No, I have not seen them.
    49
    50   Q.   So you are relying on your memory of the clock cards from 
    51        eight or 10 years ago? 
    52        A.  I am relying on my memory of the clock cards -- my 
    53        memory of doing closes at that time.
    54
    55   MR. MORRIS:   When you made this statement in January 1994 ---
    56        A.  Yes.
    57
    58   Q.   -- did you go and check the records in the Colchester
    59        store?
    60        A.  No, I have not been in Colchester store for probably

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