Day 257 - 06 Jun 96 - Page 14
1
2 Q. If we add that to the 22 million and a bit that eat
3 elsewhere do we get 43,815?
4 A. Yes, we do.
5
6 Q. My Lord, I do not think, unless your Lordship would want
7 further clarification from me, at least I understand it
8 now, I ought to ask any further questions really unless
9 your Lordship would like me to.
10
11 MR. JUSTICE BELL: No.
12
13 MS. STEEL: Can we have a couple of minutes to digest that?
14
15 MR. JUSTICE BELL: Yes, you should. In fact, what I suggest is
16 that you take until half past 11. If you need more ask for
17 it. Try and do it by then, but it is so you can think
18 about where that may take you.
19
20 MS. STEEL: OK.
21
22 (Short adjournment)
23
24 MR. RAMPTON: My Lord, I have asked Mr. Riley to put on your
25 Lordship's desk a copy of the earlier draft. I have to
26 observe, which we did not think of at the time, as
27 Mrs. Brinley-Codd points out it is a privileged document
28 since it was produced for the purposes of this case, it is
29 not a pre-existing document.
30
31 MR. JUSTICE BELL: Yes, you are prepared to waiver?
32
33 MR. RAMPTON: I am prepared to waiver it on this single
34 occasion.
35
36 MR. JUSTICE BELL: Yes.
37
38 Cross-examined by the Defendants
39
40 MS. STEEL: When we were looking at AF3, the original AF3, the
41 first time you came you said that it was primarily based on
42 AF2. Is that the fast track research?
43 A. Yes, that is correct. Yes.
44
45 Q. So, is that the same for the document that you have just
46 created?
47 A. No, the document that I have just created is based upon
48 the database from AF1, which is Taylor Nelson, so they are
49 customer profiles from 2 different sources of information.
50
51 Q. Now, on the sheet that we have just been looking at, AF3,
52 the second page, the total is 8,763 but lower down in the
53 stars it is referred to as being a quarterly sample, and
54 basically just over 2,000 people were interviewed four
55 times throughout the year?
56 A. Yes, we analysed four quarters of data, which, on
57 average, would give us 8,400, but when you interview people
58 you sometimes get more than you expect or less than you
59 expect so the number of people you eventually get will
60 approximate to your target, but not always the same.