Day 148 - 05 Jul 95 - Page 47


     
     1        tests etc., and she (Ms. Hovi) was responding to that when
     2        she went into further detail in her evidence.
     3
     4        No. 7, I am not quite sure why that is supposed to be
     5        something new that is raised by Ms. Hovi.  I do not know
     6        understand that.  It does not refer to a specific part of
     7        her evidence and I do not follow that.  That is up to the
     8        Plaintiffs to state how that comes in as a result of what
     9        Ms. Hovi said in evidence that was not in her statement.
    10
    11        The whole thing about the plan, I think, is particularly --
    12        well, I do not quite know how to describe it, to be
    13        honest.  But the Company produced a plan which they say was
    14        in response to her comment, the comment in her statement
    15        about a shortage of cleaning facilities.  If it was in
    16        response to that, why did they not put in all the cleaning
    17        facilities in the plant?  Why did they do a plan?  Why did
    18        they not put in all the cleaning facilities in the plan?
    19        Why did they do a half baked plan which only showed some of
    20        them?  Mr. Rampton said she had only made a generalised
    21        comment.  So they should have done a generalised plan which
    22        covered everything.
    23
    24        To me, there is something a bit suspicious about producing
    25        one plan and then changing the plan after a witness has
    26        given evidence.  We were told, when it was first produced,
    27        that this was an accurate plan of the premises.  It was
    28        brought in on that basis.
    29
    30        When Ms. Hovi went into more detail about where particular
    31        sterilizing and hand washing facilities were and there was
    32        something about stepping up on to a platform, that was in
    33        response to what was supposedly revealed in the plan.  She
    34        was saying, "No, the plan is inaccurate; you have to step
    35        up there; that one would not be accessible to that person";
    36        all that extra detail, that was in response to the
    37        Plaintiffs' plan that they put forward as the accurate
    38        representation of what went on at the plant.  So, again,
    39        that was not something new raised by her.  That was
    40        something raised by their introduction of a faulty plan -
    41        well, what they say is now a faulty plan.
    42
    43        The business about the clean and dirty side of the
    44        abattoir, which is paragraph 9 in Mr. Bone's statement.
    45        There is an implication that this was something that
    46        Ms. Hovi, although she mentioned in her statement she did
    47        not give the details about approaching, about people who
    48        work in the clean side of the abattoir having to come
    49        through the dirty side, but that is in response to what
    50        Mr. Bennett said when he was being examined on day 104, 
    51        page 29, where around about line 32 -- there is a bit 
    52        before that from line 24 onwards, where he talks about the 
    53        clean and the dirty sides being separate and being
    54        approached by different roads, and goes into some detail
    55        there.
    56
    57        Again, what Ms. Hovi said in evidence in the witness box,
    58        obviously she went into more detail to respond to what
    59        Mr. Bennett had said, because he had refuted her -- the
    60        statement that she had put in her statement in the first

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