Day 049 - 09 Nov 94 - Page 03

     1   MR. RAMPTON:  The point is this, that the additional material --
     2        which is not as substantial as Mr. Morris says, because
     3        there are only parts of it which are relevant -- but, as a
     4        counsel of prudence, I thought it right to serve more
     5        rather than less.  I do not want to be accused of being
     6        selective.  My understanding is that it is material which
     7        any expert in the field would surely be familiar with.
     8        That is the point of it.
    10   MR. JUSTICE BELL:  What I think you should do is ask Miss Dibb
    11        to come tomorrow, anyway, and we will see what the position
    12        is when Mr. Miles's evidence is finished.  If you need time
    13        to discuss it with her then, we will decide whether it
    14        needs till Friday morning or whether we can have a window
    15        tomorrow.
    17   MR. RAMPTON:  I am instructed to say -- I hope this is
    18        helpful -- that if Miss Dibb is in London, if that is where
    19        she lives or where her office is, we can "bike" round those
    20        files to her at once.
    22   MS. STEEL:  I think that would be helpful, if that could be
    23        done, but it still does not alter the problem that there
    24        are two lever arch files for her to read through; and it
    25        may be that only sections are going to be referred to, but
    26        she is not going to know which sections.
    28   MR. JUSTICE BELL:  Can you give Mrs. Brinley-Codd a contact
    29        number or address now, to try and deliver them?  She does
    30        not have one on her statement.
    32   MR. MORRIS:  Is there a spare set that could be -- do you have a
    33        spare set that could go to her?
    35   MR. JUSTICE BELL:  They are offering to deliver it to her; and
    36        you can hold on to what you have got there.
    38   MR. MORRIS:  That would be the witness, I presume.  Would it be
    39        okay if she made notes on it?  It is only for her, is it
    40        not?
    42   MR. RAMPTON: I do not how many bundles there are.  We can always
    43        make another one.  So, by all means, let her mark it, if it
    44        helps.
    46   MR. JUSTICE BELL:  Let that be her bundle for any purpose she
    47        cares to put it to, and a bundle will be prepared in case
    48        it is required for the witness box.
    50   MR. RAMPTON:  There are 16 references in the first volume; they 
    51        are all taken from the 171. 
    53   MR. JUSTICE BELL:  I think it is fair to assume that she is
    54        aware, although she may wish to refresh her memory, of
    55        anything she has referred to in her booklet.  This is the
    56        bundle of additional ones, is it not?
    58   MR. MORRIS:  We might as well send around both bundles.
    60   MS. STEEL:  There is a whole bundle that is not references that

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