Day 141 - 23 Jun 95 - Page 06
1
2 MR. JUSTICE BELL: -- of something which has been numbered by
3 someone 1 to 7 at the bottom, and is now stamped 14.72 to
4 14.78 by automatic page number. All I am asking is: where
5 are the six pages of which this is a photocopy?
6
7 MR. RAMPTON: My Lord, I cannot answer that. I have no idea.
8 I will answer it.
9
10 MR. JUSTICE BELL: You see, if there is going to be a challenge
11 to Mr. Stein's good faith on this, I would like to see this
12 document, the original document, if it can be readily
13 obtained. (To the witness) Mr. Stein ---
14 A. Yes, my Lord?
15
16 Q. -- what you said a few minutes ago was that TPF&C did hand
17 you that document in that form ---
18 A. Yes, my Lord.
19
20 Q. -- which I understand to be, i.e., a document of seven
21 pages, as this is?
22 A. I am assuming it is seven pages, yes, my Lord.
23
24 Q. You have it in front of you, have you not?
25 A. Yes.
26
27 Q. Have you put it away now -- pink XIV?
28 A. No. I have it right here, my Lord. Yes, my Lord.
29
30 Q. Whether at the end of the day it makes any difference or
31 not, what is being put to you is that yesterday, when
32 I asked who actually prepared the summary, you said
33 McDonald's prepared the summary from extracts from their
34 documents. I have to say that what I thought you were
35 saying at that time was, although the words on these pages
36 were "TPF&C" words, they had been taken out of another
37 report and put together by McDonald's to make these six
38 pages. Do you understand?
39 A. I understand what you are saying, my Lord. If you
40 will, these pages -- I do not want to use the word
41 "extracted" -- were taken from, verbatim, are photocopies
42 of the TPF&C report. There was more to it; there was
43 detail -----
44
45 Q. I understand that. Can someone give me the reference for
46 the HSE report, please? Is it tab 55?
47
48 (To the witness) It is pink XIII, please, Mr. Stein. That
49 is a report which was prepared by the Health & Safety
50 Executive in this country on McDonald's in this country.
51 In due course, a copy of it would have been sent to
52 McDonald's in this country. If one had taken a photocopy
53 of the first four pages, that is, Summary and Introduction,
54 and then pinned those together, you would have a new
55 document?
56 A. That is correct.
57
58 Q. It would be HSE words, but it might be said that the new
59 four-page document had been prepared by McDonald's?
60 A. OK.