Day 130 - 26 May 95 - Page 10
1 to step over it?
2 A. I do not know.
3
4 Q. But you investigated -----
5 A. I did, but by the time I got to the restaurant the
6 Environmental Health Officer had sealed off the kitchen and
7 removed the machine, so it really was not possible for me
8 to see where it was.
9
10 Q. You must have known where the socket was, where the machine
11 was, and whether, because the wire would be trailing in a
12 taut manner, people would have to step over it. Would
13 people have to step over, whether they did or not, would
14 people have to, if they were in that area?
15 A. It was not something I was looking at at the time, so
16 I really cannot remember.
17
18 Q. You did not investigate that?
19 A. As I say, I did not think it was s pertinent to this
20 accident. Remember, no accident investigation will have
21 all the facts in there. Like everyone else, I am not
22 perfect. I cannot bring together all the facts. God only
23 knows what all the facts were at the time.
24
25 MR. JUSTICE BELL: Please. Look, leave -----
26
27 MR. MORRIS: It is a very important point, as far as I am
28 concerned. In fact, it is a fundamental point.
29
30 MR. JUSTICE BELL: To this accident?
31
32 MR. MORRIS: To this accident and to conditions, and whether the
33 Company takes that seriously.
34
35 MR. JUSTICE BELL: Are you actually going to call Mr. Chapman?
36
37 MR. MORRIS: Yes.
38
39 MR. RAMPTON: My Lord, may I have confirmation of that? I do
40 not believe it; he is not on the list of people either
41 spoken that we have spoken to or from whom a letter has
42 been received.
43
44 MR. JUSTICE BELL: That is another point. I am merely
45 asking ---
46
47 MR. MORRIS: He is not on the phone.
48
49 MR. JUSTICE BELL: -- because if Mr. Morris is going to call him
50 and has a reasonable expectation that he will say the
51 things -----
52
53 MR. RAMPTON: I would like to know what that is based on. He is
54 not on the telephone, we are told, and we are not told that
55 he has sent back the letter.
56
57 MR. JUSTICE BELL: I am not on that point, Mr. Rampton. What
58 I am on is that I find it very difficult to see the point
59 in not only asking the question once, but three or four
60 times, if you are reasonably expecting you will call
