Day 047 - 07 Nov 94 - Page 51


     
     1
     2   Q.   And are you aware that they published research where they
     3        tracked -- .
     4
     5   MR. RAMPTON: I am sorry My Lord, this will not do, with the
     6        greatest possible respect. If this is material which has
     7        come from Miss Dibbs, on which she intends to rely, I
     8        should have had it before this witness gave evidence. It is
     9        not good enough for Mr. Morris, yet again, to be pulling
    10        undisclosed documents from out of his back pocket in cross
    11        examination.
    12
    13   MR. MORRIS: This is not the survey, and I am asking a cross
    14        examination question to see if the witness has heard of
    15        this survey.
    16
    17   MR. JUSTICE BELL: What is it?
    18
    19   MR. MORRIS: Well, Millwood Brown, I was going to ask the
    20        witness...
    21
    22   MR. JUSTICE BELL: Yes, but if it is based on a document, it
    23        should have been disclosed. Is it based on a document or
    24        just something which someone is saying?
    25
    26   MR. MORRIS: It is a reference to a survey in another document
    27        and it is not the actual survey itself, but I am sure the
    28        witness, because of his position will know -- .
    29
    30   MR. JUSTICE BELL: Is this a document which is going to be
    31        produced?
    32
    33   MR. MORRIS: Yes, it can be. It can be.
    34
    35   MR. JUSTICE BELL: Well, if you are going to put it to the
    36        witness, presumably it is going to be? Is it something Miss
    37        Dibbs is going to rely on, is it something which you expect
    38        -- .
    39
    40   MR. MORRIS: Apparently it is one of the references from her
    41        pamphlet which -- .
    42
    43   MR. JUSTICE BELL: It is one the ones you mentioned first thing
    44        this morning you were trying to get together?
    45
    46   MR. MORRIS: Yes, you know, it is 60 pages or something.
    47
    48   MR. JUSTICE BELL: Are you familiar with the survey?
    49        A.  Not in detail My Lord.
    50 
    51   MR. JUSTICE BELL: Are you going to finish cross examining of Mr. 
    52        Miles this afternoon? 
    53
    54   MR. MORRIS: It does not really look like it. We do not think so,
    55        no.
    56
    57   MR. JUSTICE BELL: Well, put it to the witness, identify which
    58        page and paragraph you are on, so that when Mr. Miles comes
    59        back. I think it was Thursday, was it, that you can come
    60        back, provided you can get away for the middle of the day.

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