Day 140 - 22 Jun 95 - Page 23

     
     1        A.  "Philadelphia and suburbs", to me -- I am not an expert
     2        on that.  What we did, my Lord, was, we took the furthest
     3        extent to which a store was out from Philadelphia, as they
     4        did in their survey.  So they went out as far as 24 miles
     5        -- because you can debate:  when does the suburban area
     6        stop or when does it begin?
     7
     8        My point here, my Lord, is that the region contains
     9        approximately 200 stores.  What we did, when we did our
    10        analysis, we said: "OK, you can debate what suburban is, so
    11        let us go out as far as the furthest store that they went
    12        out"; and then you draw a circle, if you will, my Lord, as
    13        to the geographical -----
    14
    15   Q.   If you look at pages 1431?
    16        A.  Yes, my Lord.
    17
    18   Q.   Presumably, if you know Philadelphia, you have only to
    19        glance down there to see the sort of area it is covering?
    20        A.  Yes.
    21
    22   MR. RAMPTON:  The document is a bit muddly.  1430 and 1431,
    23        I think, are duplicates.
    24
    25   THE WITNESS:   They are.
    26
    27   MR. RAMPTON:   One needs 1431 and 1432, which are the inner city
    28        pages.
    29
    30   MS. STEEL:  There are some other duplicates as well.
    31
    32   MR. RAMPTON:  The suburban pages go to 1433.
    33
    34   MR. JUSTICE BELL:  That is very helpful.  (To the witness)  What
    35        I would like you to do is to look through 1430 to 1435.
    36        A.  Yes, my Lord.
    37
    38   Q.   For instance, on 1435, what are places like -- if they are
    39        indeed places -- Bristol, Chatsford, and so on?
    40        A.  I would recognise those as -----
    41
    42   Q.   What are they?
    43        A.  As far as city versus suburban, my Lord?
    44
    45   Q.   No.  What actually -----
    46        A.  Those are names of towns or communities.
    47
    48   Q.   What I really want to know is what your figure of 200
    49        covered, that is, is it the same area or a larger area?
    50        A.  A larger area, my Lord. 
    51 
    52   Q.   Your greater ----- 
    53        A.  Yes.  If I can help try to clarify this.  There are
    54        three geographical areas that I believe are in question:
    55        the first is the city area; the second goes out a radius of
    56        24 miles; and then, beyond that, you still have the region.
    57
    58   Q.   But the radius of 24 miles, does that include all of what
    59        you would call suburbs?
    60        A.  Using the definition that PUP used, my Lord, you can