Day 134 - 13 Jun 95 - Page 09


     
     1
     2   Q.   Just moving on to something else:  Can you get pink volume
     3        XII, please?  If you could turn to tab 40, please?
     4        A.  Yes, I have it.
     5
     6   Q.   If you turn to page 700, just because it is a bit easier to
     7        read?
     8        A.  Yes.
     9
    10   Q.   What are these documents compiled from?
    11        A.  Various records.  They will be from various different
    12        areas.  Do you want to ask me -----
    13
    14   Q.   Do you know which areas?
    15        A.  I do not know which specific pieces of paper, if that
    16        is what you mean.
    17
    18   MR. JUSTICE BELL:  First, let us start with this, would you know
    19        in 1990 (which is the page Ms. Steel has picked partly
    20        because of its legibility), just looking there, would you
    21        expect all that information to be on a computer somewhere?
    22        A.  Yes, it will have been then; whether it would be now, I
    23        do not know but it will have been then.
    24
    25   Q.   No.  But just deal with the questions as they are asked.
    26        Because if it is on computer it seems to me reasonable to
    27        assume that you have a program which meant that the source
    28        information having been put in somewhere or other, for
    29        instance, at individual stores throughout the country, and
    30        having been transferred either the moment it was put in or
    31        by some additional exercise later to the computer in
    32        central office, one can just program in, one can type in
    33        the appropriate code, and get a printout of that
    34        nature  ---
    35        A.  Yes, I would think so.
    36
    37   Q.   -- like that.  I mean, the program does it all for you.  If
    38        you put in the code it will acquire for you the information
    39        which is required to produce a hard copy in that tabulated
    40        form.  Do you know about this yourself or not?
    41        A.  What I know is that this information will have been
    42        taken from different sources.  It will not all have been in
    43        one report as it appears here.
    44
    45   Q.   No, what I am getting at, when you were asked where it came
    46        from, you made an answer which referred to not knowing
    47        which specific pieces of paper.  What I am doubting is that
    48        there would be any pieces of paper at all.
    49
    50   MR. RAMPTON:  There might be.  I am trying to be helpful again. 
    51        The last page of the F is in a different form.  The last 
    52        document at F is about turnover but has the appearance of a 
    53        computer printout.
    54
    55   MR. JUSTICE BELL:  What do you mean, at F?
    56
    57   MR. RAMPTON:   Under E, sorry, of the new documents with
    58        Ms. Mead's statement.  As I observed yesterday, this gives
    59        actual numbers as opposed to just percentages.  I do not
    60        know, of course, whether that is the foundation for the

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