Day 061 - 05 Dec 94 - Page 05

     
     1        challenge in evidence.  You can make any comment you want
     2        about dates in due course.
     3
     4   MR. MORRIS:  Yes.  (To the witness):  Just on the carry-out
     5        bags, you have seen the document?  It says between 60 and
     6        80 per cent.  So, who do we believe, the documents or Paul
     7        Edwards?
     8        A.  I think he must, you must take -- I have already said
     9        that 80 per cent was the situation in 1992 and is the
    10        situation today.
    11
    12   Q.   Between 60 and 80?
    13        A.  60, I do not understand and you must ask Mr. Van Erp
    14        about that; that is his figure.
    15
    16   MR. JUSTICE BELL:  One thing I would like to know, I see that
    17        the first page of the additional documents which
    18        Mr. Rampton handed in is dated 3rd January 1991.  So,
    19        I assume that is contemporaneous to the beginning of 1991
    20        anyway?
         A.  Yes.
    22
    23   Q.   And then the second page is a table "Source Reduction
    24        Projects in 1991".  Is that a 1991 document or do you not
    25        know, should someone from Perseco be asked that?
    26
    27   MR. RAMPTON:  My Lord, Mr. Van Erp does know.  It is a Perseco
    28        document; he knows when that document was made because he
    29        made it himself.
    30
    31   MR. JUSTICE BELL:  Yes, very well.  Most of the others have
    32        dates on them.
    33
    34   MR. MORRIS:  The only thing about those documents I want to
    35        bring up on the front page is, are these documents the only
    36        documents you can find that are relevant to this whole
    37        issue about the recycled content of packaging; is that
    38        correct?
    39        A.  No.  Mr. Rampton mentioned earlier that there were
    40        three disclosed documents in the files.
    41
    42   Q.   Yes.  Were they numbered 25 and 56?
    43
    44   MR. JUSTICE BELL:  27 of pink V.
    45
    46   MR. MORRIS:  I have had a quick look at them.  They do not
    47        really take us much further, in my opinion, so there are no
    48        other materials in your possession, are there?
    49        A.  No other materials, no.
    50 
    51   Q.   So this front document is a supplier from Austria, yes? 
    52        A.  I am not familiar with the document you are looking at. 
    53
    54   MR. RAMPTON:  My Lord, I should have handed one in earlier.
    55        There is one for the witness.  (Handed).
    56
    57   MR. MORRIS:  It says manufactured at the top by a company in
    58        Austria, yes?
    59        A.  The company is actually in Germany.  That is why I was
    60         -- I am confused by this.  The name of the company is