Day 072 - 12 Jan 95 - Page 29
1 restaurant, customers do sit on the doorsteps, and it
2 depends what she means by "a regular basis". She has not
3 said that we do not complete regular trash walks. She just
4 said that we should be more frequent. She has not set a
5 time on it.
6
7 Q. So you are saying that she thinks that every half an hour
8 is not frequent enough?
9 A. No. I am saying that she has not defined what the
10 regular basis is, because a customer can take five minutes
11 to complete their meal and if they are using that doorstep
12 one after another there could be a mound of environment/index.html">litter before
13 next trash walk comes around.
14
15 Q. Did you speak to Mrs. Earle?
16 A. To my knowledge, I cannot recall at this moment.
17
18 MR. JUSTICE BELL: Does Royal Avenue number down from the Kings
19 Road, so that 1 is very close to you and 4 pretty close?
20 Can you remember now?
21 A. Sorry, sir?
22
23 Q. Does Royal Avenue number down from the Kings Road so that
24 No. 4 would be right up your end or pretty close to your
25 end?
26 A. No. 4 would be -----
27
28 Q. Can you remember?
29 A. Sorry, sir, No. 4 would be on the opposite side of the
30 square, I believe, but it is quite close to the store
31 because it is a square and it would only be a matter of 50
32 or 100 yards.
33
34 MS. STEEL: So it would be visible from the store?
35 A. Yes.
36
37 Q. So you could make sure that at five minute intervals
38 somebody looks over there and sees whether there is rubbish
39 sitting on the step?
40 A. Well, the manager has a lot of responsibilities and so
41 does the lobby hostess. I cannot ask them to be
42 responsible for looking after Mrs. Earle's doorstep apart
43 from a half hourly basis which, I believe, is reasonable.
44
45 MR. JUSTICE BELL: I think I have my geography right now. The
46 reason why I asked if Safeways was in the gap between
47 Walpole Street and Cheltenham Terrace is I thought the
48 Square was formed by Royal Avenue and Walpole street but
49 the Square is actually Royal Avenue?
50 A. The map is deceiving, yes.
51
52 Q. It is a very wide avenue with what you call a square in the
53 middle?
54 A. Yes, that is right, sir. The map is quite deceiving.
55 It is hard to see the square in the centre of Royal Avenue.
56
57 MS. STEEL: It only takes two, three seconds, possibly even one,
58 in fact, to look across the road and see if there is any
59 environment/index.html">litter on her step. It is not something that is going to
60 take up a lot of their time?
