Day 049 - 09 Nov 94 - Page 03
1 MR. RAMPTON: The point is this, that the additional material --
2 which is not as substantial as Mr. Morris says, because
3 there are only parts of it which are relevant -- but, as a
4 counsel of prudence, I thought it right to serve more
5 rather than less. I do not want to be accused of being
6 selective. My understanding is that it is material which
7 any expert in the field would surely be familiar with.
8 That is the point of it.
9
10 MR. JUSTICE BELL: What I think you should do is ask Miss Dibb
11 to come tomorrow, anyway, and we will see what the position
12 is when Mr. Miles's evidence is finished. If you need time
13 to discuss it with her then, we will decide whether it
14 needs till Friday morning or whether we can have a window
15 tomorrow.
16
17 MR. RAMPTON: I am instructed to say -- I hope this is
18 helpful -- that if Miss Dibb is in London, if that is where
19 she lives or where her office is, we can "bike" round those
20 files to her at once.
21
22 MS. STEEL: I think that would be helpful, if that could be
23 done, but it still does not alter the problem that there
24 are two lever arch files for her to read through; and it
25 may be that only sections are going to be referred to, but
26 she is not going to know which sections.
27
28 MR. JUSTICE BELL: Can you give Mrs. Brinley-Codd a contact
29 number or address now, to try and deliver them? She does
30 not have one on her statement.
31
32 MR. MORRIS: Is there a spare set that could be -- do you have a
33 spare set that could go to her?
34
35 MR. JUSTICE BELL: They are offering to deliver it to her; and
36 you can hold on to what you have got there.
37
38 MR. MORRIS: That would be the witness, I presume. Would it be
39 okay if she made notes on it? It is only for her, is it
40 not?
41
42 MR. RAMPTON: I do not how many bundles there are. We can always
43 make another one. So, by all means, let her mark it, if it
44 helps.
45
46 MR. JUSTICE BELL: Let that be her bundle for any purpose she
47 cares to put it to, and a bundle will be prepared in case
48 it is required for the witness box.
49
50 MR. RAMPTON: There are 16 references in the first volume; they
51 are all taken from the 171.
52
53 MR. JUSTICE BELL: I think it is fair to assume that she is
54 aware, although she may wish to refresh her memory, of
55 anything she has referred to in her booklet. This is the
56 bundle of additional ones, is it not?
57
58 MR. MORRIS: We might as well send around both bundles.
59
60 MS. STEEL: There is a whole bundle that is not references that