Day 171 - 11 Oct 95 - Page 17
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2 MR. JUSTICE BELL: A documented complaint.
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4 MR. MORRIS: I mean, if the store has a letter from him,
5 I presume it would go in his PR file. If for some reason
6 that was kept in the manager's file, if he made a written
7 complaint, or it was noted, then I do not know where that
8 would be kept. I presume it would be kept in his personnel
9 file.
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11 MR. JUSTICE BELL: Is it a personnel file or a personal file?
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13 MR. RAMPTON: My Lord, I do not know. I have never seen one.
14 The answer is that Mrs. Brinley-Codd does not know, either.
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16 MR. JUSTICE BELL: No.
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18 MR. MORRIS: I do not think the employee has control over what
19 goes in that file; that is my understanding, that the
20 management control what goes in and, presumably, what comes
21 out.
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23 MR. JUSTICE BELL: Then you say anything else of relevance.
24 Mr. Rampton has volunteered that anything he sees as
25 relevant will be disclosed, but what I would like to know
26 from you is, is there any particular document, apart from
27 the ones you have mentioned -- the performance reviews and
28 letters, for instance, of complaint -- which you have in
29 mind?
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31 MR. MORRIS: Never having seen one of these files, I do not
32 really know what goes into them. But, obviously, there may
33 be comments by managers about any of the issues that are
34 relevant in the Bath evidence. Unfortunately, we are in
35 Mr. Rampton's hands as to whether it is.
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37 MR. JUSTICE BELL: That may be so, if you cannot identify a
38 particular document to me. But I am giving you an
39 opportunity to do that, if you have one in mind.
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41 MR. MORRIS: There may be something about his promotion, his
42 offer to be promoted which he eventually turned down.
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44 Number 2. 2A are the ones specified relating to PR forms,
45 and 2B -- incidentally, it is our understanding that
46 personnel files are kept for seven years from when
47 employees leave.
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49 MR. JUSTICE BELL: That is what Mr. Richards said.
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51 MR. MORRIS: Yes. 2B relates to all the names that were put on
52 the supplementary list of names which I provided to the
53 court, not just the names in 2A; and if any of those staff
54 made a complaint and it is in their PR form -- and
55 Mr. Rampton goes through them -- which relate to the
56 issues, then it must be relevant and should be disclosed.
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58 MR. JUSTICE BELL: Why do you say it is relevant ---
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60 MR. MORRIS: Well -----
