Day 171 - 11 Oct 95 - Page 16


     
     1        blanked out by the Plaintiffs, that all the matters on the
     2        documents are relevant, and whether it helps or does not
     3        help the Plaintiffs is the way things are.  Basically, if
     4        they are relevant to the evidence, then they should be
     5        disclosed.  If there is any enquiry into that, then --
     6        I give you an example:  Mr. Logan, on page 2 of his
     7        statement.
     8
     9   MR. JUSTICE BELL:  I have got your point
    10
    11   MR. MORRIS:  You have got the general point, OK.  He also refers
    12        in the statement not just to the scheduling used as a tool
    13        of discipline, common practice for that; he also refers to
    14        breaks, for example:  "Employees' rights to a break were
    15        often abused especially during periods of high volume", and
    16        he makes various allegations about breaks.  I do not know
    17        if the breaks are shown on clock cards but, in any
    18        event -----
    19
    20   MR. JUSTICE BELL:   Mr. Rampton has suggested that they will be
    21        shown on the clock card sheets.
    22
    23   MR. RAMPTON:  They are.  I have seen them.
    24
    25   MR. JUSTICE BELL: So you -----
    26
    27   MR. MORRIS:  I will come to that in a minute, about the
    28        specifics, yes.  I am just making the general case that all
    29        the information contained in the documents that we are
    30        applying for goes to issues that are in dispute in this
    31        case and in dispute in these witnesses.  It is not just
    32        thrown in because it might be helpful.  I mean, the breaks
    33        are part of the evidence.
    34
    35        Also, in his letter he wrote to the employment office on
    36        his resignation, he also refers to understaffing occurring
    37        frequently in order to reduce the labour percentage; and,
    38        therefore, the time that people are scheduled -- when
    39        Mr. Logan comes to give his evidence and he looks at the
    40        documents, he will be able to point to us and explain to
    41        the court how he says these documents back up what he says
    42        about understaffing in general.  So the all the information
    43        on the schedules and clock card sheets and weekly time
    44        sheets, or any other documents relevant to when people
    45        worked, for all of the staff named on them, is relevant.
    46        So that is the sort of kind of background.
    47
    48   MR. JUSTICE BELL:  Just pause there.  Yes.
    49
    50   MR. MORRIS:  Going through the 14 categories sought:  the 
    51        personnel file of Michael Logan, off the top of my head, 
    52        apart from his PRs (performance reviews), details of any 
    53        complaints he made about matters raised.
    54
    55   MR. JUSTICE BELL:  It has to be a document.  So you are
    56        suggesting there might be a complaint letter or copy of
    57        that, are you?  You say details of any complaints -----
    58
    59   MR. MORRIS:  It would be have to be something in a document in
    60        his file, yes.

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