Day 072 - 12 Jan 95 - Page 43


     
     1        Ms. Steel must propose what the American word means before
     2        she is ----
     3
     4   MS. STEEL:  "One block in every direction of the store".
     5
     6   MR. RAMPTON:  She most propose what it means in America, then we
     7        will see whether she is right when we call our next
     8        American witness.
     9
    10   MR. JUSTICE BELL:  Give your interpretation of what "one block"
    11        would mean in Chelsea?  It is fairly easy to do.  For
    12        instance, it would be one road north -- you might suggest,
    13        rather, that it might be one road north of the Kings Road,
    14        one road west, one road south and one road east, and then
    15        see whether Mr. Stump agrees with that or not and ask him
    16        about that.
    17
    18   MS. STEEL:  Would you agree with that?
    19        A.  Clarify what the road extends?
    20
    21   Q.   Look at your plan.  Let me just ask you.
    22
    23   MR. JUSTICE BELL:  It might be thought (and say what your own
    24        interpretation is because Mr. Rampton is right, it is an
    25        American expression), it might reasonably, if you said you
    26        went one block in every direction, you would go up to
    27        Elliston Place in the north, Smith Street and the east limb
    28        of Markham Square in the west, Woodfall Street in the south
    29        and certainly the other side of Royal Avenue and perhaps
    30        Walpole street to the east.  What do you say about that?
    31        A.  I would interpret it, "a block" as round Royal Avenue,
    32        down to Leonard Terrace, the section of Smith Street down
    33        to Leonard Terrace.
    34
    35   Q.   The point being put to you is really this:  Just as you
    36        would go to Walpole Street in the east, Smith Street in the
    37        west, and Woodfall Street and perhaps you said Leonards
    38        Terrace as well in the south, so if you were reaching an
    39        English equivalent of at least one block in every direction
    40        of the store you would go up to Elliston Place.  Whether we
    41        have a problem on that side or not, I will in due course
    42        hear, but that would be a fair interpretation of one block
    43        in every direction?
    44        A.  I would say, yes.
    45
    46   MS. STEEL:   Is this the training manual that is used in this
    47        country?
    48        A.  Yes.
    49
    50   Q.   It is?  So what happens when there is an Americanism in 
    51        there and you are perhaps not quite sure what it means?  Do 
    52        you just interpret it how you want or do you have to 
    53        contact head office and get guidance from them or what?
    54        A.  I would say common sense would prevail.  If it was an
    55        obvious Americanism that we could translate, then we would
    56        do so.  If there was a statement or jargon that we did not
    57        understand, then we would just contact the training
    58        department at head office.
    59
    60   Q.   So what does that mean to you?  What does that mean to you?

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