Day 149 - 06 Jul 95 - Page 31


     
     1        where their suppliers came from, or might have a reaction.
     2
     3   MR. RAMPTON:  He might or might not.  Anyhow, there is the
     4        list.  We will do a bit of work to find earlier lists as
     5        well.
     6
     7        My Lord, next -- again, I have no real objection to it,
     8        except that I do find having to produce documents which are
     9        then sort of looked at once and discarded really an awful
    10        waste of my client's time and money -- there is the US
    11        observation checklists.  If we had to, I think we would
    12        probably argue that these are not, in fact, relevant.  The
    13        English ones, the British ones are, because complaints are
    14        made by the Defendants witnesses about inadequate training,
    15        which is principally what the OCLs relate to.  There is no
    16        allegation to similar effect about the United States.  The
    17        Defendants do not, as far as I am aware, have any expert or
    18        current McDonald's witness from the United States, and
    19        certainly nothing in the abstract of the pleading.
    20
    21        My Lord, if I had to argue on strict legal grounds that
    22        these were irrelevant, I would do so.  The note I made to
    23        myself was, in effect, the first submission I made to your
    24        Lordship: just more pointless paper.
    25
    26   MR. MORRIS:  Does that mean he is saying he is going to provide
    27        them?
    28
    29   MR. RAMPTON:  No -- unless ordered to do so.  To help
    30        Mr. Morris, my submission is: not relevant and not
    31        necessary, in relation to that.
    32
    33   MS. STEEL:  It was just a bit confusing, because Mr. Rampton
    34        started off saying he did not know if he had any objection
    35        to it.
    36
    37   MR. JUSTICE BELL:  Do not worry.  Mr. Rampton has made it clear
    38        now.
    39
    40   MR. RAMPTON:  My Lord, my next one was documents referred to the
    41        in the Health and Safety Minutes.
    42
    43   MR. JUSTICE BELL:  Just pause a moment.  Yes, the response to
    44        the HSE report and the report on hustle.
    45
    46   MR. RAMPTON:  Yes.  We will certainly disclose them or such part
    47        of them as are relevant.  As your Lordship I think said at
    48        the time, it is likely that they mostly are, and I quite
    49        agree with that.  So we will get on to that straightaway.
    50 
    51        My Lord, the next one was the Dan Gallein letter to which 
    52        Mr. Stein referred to -- I did not refer to it, contrary to 
    53        what Mr. Morris said -- in re-examination.  I did not have
    54        a copy at the time.  I had not seen it at the time.  I do
    55        now have a copy, faxed to me actually -- it is not often
    56        I get one of these faxes -- by McDonald's lawyers in
    57        St. Louis, Missouri, at the request of Mr. Steve Brown, who
    58        was in court last week, as your Lordship may recall.
    59        Whether it is relevant or not -- and I very much doubt
    60        it -- I have no objection to disclosing it.  Your Lordship

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