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
         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
         "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.