Day 171 - 11 Oct 95 - Page 17


     
     1
     2   MR. JUSTICE BELL: A documented complaint.
     3
     4   MR. MORRIS:  I mean, if the store has a letter from him,
     5        I presume it would go in his PR file.  If for some reason
     6        that was kept in the manager's file, if he made a written
     7        complaint, or it was noted, then I do not know where that
     8        would be kept.  I presume it would be kept in his personnel
     9        file.
    10
    11   MR. JUSTICE BELL: Is it a personnel file or a personal file?
    12
    13   MR. RAMPTON:  My Lord, I do not know.  I have never seen one.
    14        The answer is that Mrs. Brinley-Codd does not know, either.
    15
    16   MR. JUSTICE BELL:  No.
    17
    18   MR. MORRIS:  I do not think the employee has control over what
    19        goes in that file; that is my understanding, that the
    20        management control what goes in and, presumably, what comes
    21        out.
    22
    23   MR. JUSTICE BELL: Then you say anything else of relevance.
    24        Mr. Rampton has volunteered that anything he sees as
    25        relevant will be disclosed, but what I would like to know
    26        from you is, is there any particular document, apart from
    27        the ones you have mentioned -- the performance reviews and
    28        letters, for instance, of complaint -- which you have in
    29        mind?
    30
    31   MR. MORRIS:  Never having seen one of these files, I do not
    32        really know what goes into them.  But, obviously, there may
    33        be comments by managers about any of the issues that are
    34        relevant in the Bath evidence.  Unfortunately, we are in
    35        Mr. Rampton's hands as to whether it is.
    36
    37   MR. JUSTICE BELL:  That may be so, if you cannot identify a
    38        particular document to me.  But I am giving you an
    39        opportunity to do that, if you have one in mind.
    40
    41   MR. MORRIS:  There may be something about his promotion, his
    42        offer to be promoted which he eventually turned down.
    43
    44        Number 2.  2A are the ones specified relating to PR forms,
    45        and 2B -- incidentally, it is our understanding that
    46        personnel files are kept for seven years from when
    47        employees leave.
    48
    49   MR. JUSTICE BELL:  That is what Mr. Richards said.
    50 
    51   MR. MORRIS:  Yes.  2B relates to all the names that were put on 
    52        the supplementary list of names which I provided to the 
    53        court, not just the names in 2A; and if any of those staff
    54        made a complaint and it is in their PR form -- and
    55        Mr. Rampton goes through them -- which relate to the
    56        issues, then it must be relevant and should be disclosed.
    57
    58   MR. JUSTICE BELL:  Why do you say it is relevant ---
    59
    60   MR. MORRIS:  Well -----

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