Day 196 - 06 Dec 95 - Page 06

     
     1        comply due to the pressures from those in the management
     2        grades above."
     3
     4        Do you stand by that evidence which you gave in that
     5        statement?
     6        A.  I do.
     7
     8   Q.   I cannot remember when that was actually signed -- 25th
     9        October this year.  I will move straight on to the next
    10        statement.  I wonder if I can ask the opinion of the court
    11        here?
    12
    13   MR. JUSTICE BELL:  Yes.
    14
    15   MR. MORRIS:  If he is verifying somebody else's statement, would
    16        it be proper that he looks at that statement as it is in
    17        the bundles?
    18
    19   MR. JUSTICE BELL:  No.  All you need to do is read it, read the
    20        statement of Mr. Coton dated 28th October 1995.  I will
         assume that it is the copy of Mr. Gibney's statement which
    22        I have, and the same applies to Adrian Brett, Kevin
    23        Harrison, etc.
    24
    25   MR. MORRIS:  "Continuation Statement of Ray Coton, signed 28th
    26        October 195.  I have read the statement made by Simon
    27        Gibney, 15th July 1993." That was written for the purposes
    28        of this case. "I can confirm the facts as stated as true
    29        with regards to Section (1) Operational Targets; (2)
    30        Collective Activity; (3) Scheduling Staff Hours; (4) Under
    31        18 year old males working past midnight; (5) Working with
    32        sewage under foot; (6) Overtime payments, and (8) all night
    33        closes.
    34
    35        With regard to Section (7) on burns, although commonplace,
    36        action or correct action as regards this, in my view, was
    37        always taken, and although I remember the case stated,
    38        there was no form of hush money."   We will come back to
    39        that.
    40
         "During my early time under training, many of my shifts
    42        were spent working with Simon and much cross-training
    43        between us went on, and I was present or have knowledge of
    44        all cases stated.  I have also read the statements made by
    45        Adrian Brett, Kevin Harrison, C. Harrison," that is
    46        Catherine Harrison?
    47        A.  Yes.
    48
    49   Q.   "Siamak Alimi and Omid Shafibeik, all people that I worked
    50        with at the Colchester store during my time there from 
    51        Security to Store Manager.  I can confirm the facts in 
    52        those statements as true or being correct to the best of my 
    53        knowledge."
    54
    55        Can I just ask you one question about that.  Are you saying
    56        you can confirm every single point in every one of those
    57        statements?
    58        A.  I am unable to confirm definitely all points, but the
    59        actual statements or cases they have talked about I either
    60        know of or heard of.  Obviously, I was not actually