Day 072 - 12 Jan 95 - Page 25
1 this diary, what you are recording; whether it is just
2 phone calls and verbal complaints or whether you are
3 recording all complaints?
4 A. If a letter arrived, we would keep the letter and --
5 I have not got a policy for recording it, so I have not
6 informed the managers to record it in the diary or myself
7 to record it in the diary, but we do keep the letters.
8
9 Q. Where do you keep the letters?
10 A. In the drawer in my office in the basement of the
11 store.
12
13 Q. So there is a separate file for them?
14 A. Yes, it is not only complaint but also "thank you"
15 letters and just any correspondence from customers and
16 local residents.
17
18 Q. Have you got your statement to hand?
19 A. I have not, no.
20
21 MR. JUSTICE BELL: It is in yellow III, divider 7.
22
23 MS. STEEL: You have got that now?
24 A. Yes, I have.
25
26 Q. If you look at paragraph 4 you have said: "We aim to
27 conduct regular trash walks every 30 minutes". Why have
28 you said "aim"?
29 A. How do you mean? Sorry, do you mean I should have
30 said: "We do complete trash walk every 30 minutes"?
31
32 Q. I just wondered why you put "aim".
33 A. I did not intend to put "aim". If I can remember, it
34 could be seen as a mistake. I do not believe I intended to
35 write "aim" or I did not intend to imply that we aim to do
36 it.
37
38 Q. Trash walks do not take place every 30 minutes, do they?
39 A. Well, I said before, if there was an extreme
40 circumstance like a thunder storm or hazardous conditions,
41 if it was snowing outside, then it would not be sensible to
42 send someone outside to do a trash walk.
43
44 Q. No, but when the weather is not extreme, it might be
45 raining or it might be sunshine, trash walks still do not
46 take place every 30 minutes, do they?
47 A. I believe they do, yes, a minimum of 30 minutes.
48
49 Q. They have not done for the last year, year and a half, have
50 they?
51 A. No, I disagree; they have, yes.
52
53 Q. Why are there so many complaints from residents about
54 environment/index.html">litter in that case?
55 A. Because a trash walk is not intended to pick up every
56 single piece of environment/index.html">litter in the streets. Some of the
57 problems we have had is the wind blows rubbish into
58 basements which has been mentioned before. The rubbish
59 collects underneath cars. Customers will park the car and
60 they will drop the environment/index.html">litter outside the car and cars will
