Day 057 - 29 Nov 94 - Page 47


     
     1        directly myself.  The UK statistics do exist and are
     2        coming.  They do not exist in the United States except in
     3        some form on a state to state basis.  This means that there
     4        is no central record kept at Oak Brook which further means
     5        that if the information were to be available to your
     6        Lordship in any comprehensible form, it would perforce be
     7        in the form of a summary which might take some considerable
     8        time to put together.  I have probably got that wrong
     9        too -- yes, and I add to that, in the United States records
    10        are kept for Social Security reasons only.  What
    11        implication that has, I really do not know.  The only basis
    12        on which they are kept in the United States is that they
    13        show what people might qualify for Social Security by
    14        reason of an industrial accident.
    15
    16        What they do not, of course, tell you is overall what the
    17        position is in relation to in-store accidents in the United
    18        States in the way that they do in this country.  In other
    19        words, they are not a McDonald's record kept for the
    20        purpose of the better running of its business, or in
    21        consequence of any government legislation.  So, how far
    22        those statistics, American ones, would actually help your
    23        Lordship, I do not know.
    24
    25   MR. JUSTICE BELL:  Let us take it step by step.  The UK
    26        statistics are going to be disclosed?
    27
    28   MR. RAMPTON:  They are, yes.
    29
    30   MR. JUSTICE BELL:  I am not doubting for a moment
    31        Mrs. Brinley-Codd's efficiency or her ability to summarise
    32        accurately what she has heard, but is it possible to get
    33        from -- I am not ordering you to do that; it is just a way
    34        of approaching it so we can see whether they would help or
    35        not -- a letter from someone in one of the states which
    36        might be taken as a typical example, just setting out what
    37        the nature of such statistics as there is, in other words,
    38        what they record and for what purpose?
    39
    40   MR. RAMPTON:  Mrs. Brinley-Codd has already asked them to send
    41        us an account of what they have and what they can do with
    42        it.  If it is not comprehensible, then we will ask for
    43        something like what your Lordship has suggested and see
    44        what happens.
    45
    46   MR. JUSTICE BELL:  If I might suggest, I think that whoever is
    47        going to write the letter should be told it is a letter
    48        which will be disclosed in open court, so that people can
    49        actually look at what its contents are and to spell out in
    50        as simple English or American as is possible just what the 
    51        statistics would reveal, then we can consider that again. 
    52 
    53   MR. RAMPTON:  Very well, we will do that.
    54
    55   MR. JUSTICE BELL:  That is what I suggest you do for the time
    56        being.
    57
    58   MR. RAMPTON:  My Lord, that is what we will do.
    59
    60   MR. MORRIS:  Just on that subject, our understanding is the

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