Day 164 - 26 Sep 95 - Page 17


     
     1        disappeared but I made a list for myself, you raised the
     2        question of some witness statements given in the course of
     3        an investigation in Lyons.  You raised the question of some
     4        documents in relation to the bar store, the Operations
     5        Manual, the Towers and Perrin full report, management and
     6        crew scheduling, disk and hard copy, and full Enquiry
     7        Agents' notes and any response to the HSE investigation
     8        unit report, if you do not accept Mrs. Brinley-Codd's
     9        answer about that.
    10
    11   MR. MORRIS:  If we can do those, not necessarily in that order
    12        because I have various letters at different times.
    13
    14        The Operations Manual, Mrs. Brinley-Codd said that we would
    15        get a copy of that tomorrow so that does not need to be
    16        discussed.
    17
    18   MR. RAMPTON:  No, I do not think that is right.
    19
    20   MS. STEEL:  I asked Mrs. Brinley-Codd for copies of documents
    21        yesterday and she said, well, I was asking about a number
    22        of matters in relation to the counterclaim and she said:
    23        "I cannot get them all to you tomorrow", i.e. today,
    24        "because the Operations Manual is very bulky, but is
    25        Wednesday OK?"  I said:  "Yes".
    26
    27   MR. RAMPTON:  Whatever Mrs. Brinley-Codd may have said or
    28        Ms. Steel may have thought Mrs. Brinley-Codd may have said,
    29        the position is this, that we will provide in our usual way
    30        copies of the discovery which we make in relation to the
    31        counterclaim.  That, I think, is what is coming tomorrow.
    32        We will provide the Defendants with their strict rights
    33        under the rules in relation to the Operations Manual.  We
    34        offered them at the beginning of August the opportunity to
    35        come and inspect it and to take such copies, or have taken
    36        such copies, of such parts of it that they may wish to have
    37        copied at their expense.  That is where we stand on the
    38        Operations Manual.
    39
    40   MS. STEEL:  It was not at the beginning of August though.
    41
    42   MR. RAMPTON:  It was on 7th August.
    43
    44   MR. MORRIS:  If the Plaintiffs want to bill the Defendants for
    45        providing copies of the Operations Manual that they were
    46        ordered to disclose, then, presumably, if that is the rule,
    47        that is their prerogative, but the Defendants could also
    48        take the same position with the provision of documents that
    49        we provide to the Plaintiffs.  I do not necessarily think
    50        that takes us much further.  It will be much more work for 
    51        us, more complication but I think that the court ----- 
    52 
    53   MR. RAMPTON:  May I say this about the Operations Manual so that
    54        we can get it out of the way?  It is a special case.  It is
    55        a very long document.  We have stapled a part of it which
    56        we do not think is in any sense relevant.  That has to do
    57        with security and insurance in the stores.  Much of the
    58        rest of it that we are willing that the Defendants should
    59        see that they have not already seen we think is of only
    60        marginal relevant, but we are willing for them to see it.

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