Day 188 - 15 Nov 95 - Page 39


     
     1        A.  I do not know that I know anything about that
     2        particularly.  If she says so, then it does not surprise
     3        me.  I did not investigate the storage process of stuff at
     4        McDonald's, so I cannot say with any authority at all.
     5
     6   MR. MORRIS:   Right.  I am just seeing if there is any other
     7        questions.  No further questions.
     8
     9   MR. JUSTICE BELL:  Thank you.
    10
    11
    12                    Cross-examined by MR. RAMPTON Q.C.
    13
    14   MR. RAMPTON:  Miss Tobin, can I be clear about the status of the
    15        notes which we have, your word processed notes, of which
    16        I think we have 19 pages?
    17        A.  Yes.
    18
    19   Q.   May I understand, so that I have it right.  These are notes
    20        which you made at various times -- not necessarily actually
    21        while you were in the store, because it would be difficult
    22        with a word processor, but soon afterwards, and then passed
    23        them on to the producer, Jane Gabriel?
    24        A.  That is correct, yes.
    25
    26   Q.   Am I also right that you did not make notes at the time
    27        when you were actually working in the store?
    28        A.  Yes.  I carried a notebook.  When I was actually
    29        working on the shift pattern, no, I did not make notes
    30        during that period.
    31
    32   Q.   That is what I thought.  So when, for example, you got
    33        notes of the night close, that is when you are there as an
    34        observer?
    35        A.  That is correct, yes.
    36
    37   Q.   And not as a worker?
    38        A.  That is correct.
    39
    40   Q.   If you would not mind finding your statement, which is in
    41        volume II at, I think, tab 14 -- have you got it there?
    42        A.  My statement?
    43
    44   Q.   Your written statement.
    45
    46   MR. JUSTICE BELL:  Yes.  She has that separate.
    47
    48   MR. RAMPTON:  What you say there in the third paragraph, for
    49        example, about the lettuce -- yes?
    50        A.  This is the third paragraph, yes. 
    51 
    52   Q.   About the lettuce? 
    53        A.  Yes.
    54
    55   Q.   The reason we do not find that in any of your notes is that
    56        it was not something you made a note of at the time?
    57        A.  That is correct.  I mean,, these notes that you have
    58        here, pages 1 to 19, are not all the notes that I took and
    59        wrote up at the time; they are the notes that I could
    60        find.  So they are not every single note that I ever made.

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