Day 048 - 08 Nov 94 - Page 64


     
     1
     2   MR. MORRIS: Well yes, but as far as I understood it, if the
     3        Statement of Claim was amended, we would then have a quite
     4        dramatic development, as we would see it, that would
     5        necessitate both cross examining the plaintiffs' witnesses
     6        and examining or re-examining our own witnesses on the new
     7        position. So I don't know that we would be ready, even if
     8        we did have the argument successfully.  I mean, it was
     9        dealt with before that time which we are not happy with
    10        anyway, we don't think it's enough time, but even if it was
    11        before that time I don't know if we would be ready for
    12        that, if that is what we are able to do or we should do.
    13
    14   MR. JUSTICE BELL: What I suggest we do is, we have at some stage
    15        the question of amendment.  If need to amend is granted in
    16        whatever terms, you can think to what extent you feel you
    17        need to ask Professor Crawford further questions. I may
    18        well have missed something. I can't myself think of what
    19        you might want to ask him further in examination in chief
    20        because he spoke really in quite positive terms, but you
    21        may well have thought of something which I have not thought
    22        of, so I will certainly give you the opportunity to deal
    23        with that.
    24
    25   MS. STEEL: I think obviously we would have to spend some time
    26        going through the transcripts of Mr. Crawford's evidence in
    27        chief.
    28
    29   MR. JUSTICE BELL: It was not just whether the plaintiffs obtain
    30        leave to amend in respect of that. It was, you will
    31        remember, whether in the course of the argument, because
    32        argument often focuses often ones mind on aspects which one
    33        hasn't thought about, whether that turned up something else
    34        that you wanted to ask Professor Crawford about.  The
    35        longest discussions we have had in this case have all been
    36        on a hypothetical basis, so I would like to deal at an
    37        appropriate time with the question of the amendment to the
    38        Statement of Claim. If I give leave to the plaintiffs to
    39        amend in any respect in relation to nutrition, I will give
    40        you time to think about the consequences so far as
    41        witnesses are concerned.
    42
    43   MR. MORRIS: I mean, you see there is also the concern or the
    44        issue that if the Statement of Claim, leave to amend is
    45        granted, the issues raised of whether the plaintiffs'
    46        witnesses should be recalled before our witnesses are
    47        further examined - sorry, cross-examined on the new
    48        Statement of Claim.
    49
    50   MR. JUSTICE BELL: Well, I do not think it is particularly useful 
    51        to talk in these hypothetical terms. I mean, just to give 
    52        you an example.  If I did grant the plaintiffs leave, that 
    53        might be just because I thought that it is better that the
    54        matter is out in the open and what the issues are are
    55        clarified so one can focus on them, it might or might not
    56        be because I had reached a view, if I did reach a view,
    57        that everyone had, in fact, been treated, linked with as
    58        meaning causally linked with. I don't know.  We have not
    59        had the argument yet.  So I think it is rather unproductive
    60        to start worrying about what the consequences are until I

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