Day 130 - 26 May 95 - Page 26


     
     1        electric from wires and simply recorded it as an electric
     2        shock.
     3
     4   MR. JUSTICE BELL:  Very well, thank you.
     5
     6   MR. MORRIS:  Just a few other related bits and pieces really,
     7        this fatal accident status report chart we looked at in
     8        your report ---
     9        A.  Yes.
    10
    11   Q.   -- what was the purpose of doing that?
    12        A.  I put it together so that senior management could see
    13        how we had progressed.
    14
    15   Q.   So it was how things were progressing, an internal thing?
    16        A.  An internal update form.
    17
    18   Q.   This report memorandum, what is the purpose of a
    19        memorandum?
    20        A.  Well, in general, a communication document.
    21
    22   MR. JUSTICE BELL:  Bringing information to someone else's or
    23        other people's attention?
    24        A.  Yes.
    25
    26   MR. MORRIS:  Yes.  (To the witness):  The summary of the Main
    27        Points For Action was part of the memorandum.  All those
    28        people that are named in the memorandum, are they people
    29        from all over the country?
    30        A.  The regional managers cover the whole country, yes.
    31        David Richards is head of construction for the whole
    32        country, or was at the time; Richard Ogden reported to him
    33        and also had corporate responsibilities; Richard Rowley,
    34        the Equipment Manager,, for the whole country.
    35
    36   MR. JUSTICE BELL:  Do not go through them all.
    37        A.  Yes, they were corporate people.
    38
    39   MR. MORRIS:  Anyone who could have been concerned about the
    40        action to be taken as a result of the accident, and what
    41        the causes were, and things like that?
    42        A.  They were the senior people involved and the technical
    43        people involved, yes.
    44
    45   Q.   So, in fact, there is nothing in this report that is
    46        privileged at all, is there?
    47        A.  I do not think I am qualified to comment on that.
    48
    49   Q.   No.  It should have been disclosed two years ago, should it
    50        not? 
    51 
    52   MR. RAMPTON:  Who said it was privileged?  I never said it was 
    53        privileged.
    54
    55   MR. MORRIS:  You did not want to release this report, did you,
    56        because it it is a damning report against the Company?
    57        A.  It is really not up to me whether it was released or
    58        not. I am afraid I am not fully conversant with the legal
    59        technicalities.
    60

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