Day 106 - 23 Mar 95 - Page 32

     
     1
     2   MR. JUSTICE BELL:  I think it would be helpful, yes.  Then
     3        Mr. Morris and Ms. Steel can ask you any more about it
     4        before you go into the witness, and Mr. Rampton will have
     5        better notice of just how you put the matter.
     6
     7   MR. MORRIS (To the witness):  You made visits on our behalf to
     8        various premises to do an expert report; is that correct?
     9        A.  Yes.
    10
    11   Q.   In August last year?
    12        A.  Yes.
    13
    14   Q.   So on 16th August it was Sun Valley ---
    15        A.  Yes.
    16
    17   Q.   -- poultry plant, and on 19th August it was McKey's; is
    18        that correct?
    19        A.  Yes.  The dates -- I cannot recall personally when the
    20        dates were.
    21
    22   MR. JUSTICE BELL:  Do you have your second -----
    23        A.  I have it in front of me, yes, so as read, yes.
    24
    25   MR. MORRIS:  I cannot find the date you visited the shop.  It
    26        does not matter.
    27
    28   MR. JUSTICE BELL:  You said not long afterwards; I do not think
    29        you gave a date for the shop.
    30        A.  As I recall, I think it was done at very short notice
    31        and I did not enter it in my diary, so when I went back to
    32        look I did not have a date other than it was very
    33        shortly  .....
    34
    35   Q.   But it was soon after 19th August 1994?
    36        A.  Quite so.
    37
    38   Q.   Shortly thereafter, yes.
    39
    40   MR. MORRIS:  Let us just take all the sites together.  When you
         visited the three sites, at any of the sites were you shown
    42        relevant paper work?
    43        A.  I had already been informed, prior to attending the
    44        sites, that I would be not be shown the paper work I think
    45        by yourself and, therefore, I did not ask and I was not
    46        shown.
    47
    48   Q.   In particular -----
    49
    50   MR. JUSTICE BELL:  Mr. Morris, can I make a suggestion?  Quite 
    51        apart from deciding what goes in here, if you have further 
    52        discovery in your mind, I suggest you seek with Mr. North 
    53        to lay the ground of how it would be relevant and how it
    54        would be helpful.  I do not know what Mr. North will say
    55        about that, but an example would be, you have raised the
    56        question of salmonella in beef, and Mr. North has said that
    57        it very much depends upon the methodology used at the
    58        bacterial testing.
    59
    60        If you are going to persuade me that documentation in