Day 174 - 17 Oct 95 - Page 02

     1                                      Tuesday, 17th October, 1995
     3                       MICHAEL MEHIGAN, recalled
     4             Cross-examination by the Defendants, continued
     6   MS. STEEL:   Mr. Mehigan, you made your statement 14 years after
     7        the events of the strike.  Did you do it all from memory or
     8        did you refresh your memory by looking at all the
     9        documents?
    10        A.  I cannot recall exactly.  I certainly did a lot of it
    11        from memory, but I looked at many files, and I cannot
    12        recollect at this point.
    14   Q.   You disclosed these documents.  Why had you kept them all
    15        for this length of time?
    16        A.  For no other reason than we keep -- we have a habit of
    17        keeping files for a long, long time.
    19   Q.   So do you basically keep everything?
    20        A.  I would say yes.  We have too many files kept of many
    21        things.
    23   Q.   If you had a dispute, you would keep all the papers to do
    24        with that dispute?
    25        A.  We would keep papers on many aspects of the business
    26        for a long time, say, in relation to operations or in
    27        relation to records of the Company.  I mean, there is an
    28        obligation on us to retain employment records for quite a
    29        length of time, and payroll records, as well.
    31   Q.   But the records tht you kept would include all the records
    32        concerning a dispute -- concerning this dispute, for
    33        example?
    34        A.  Well, if that is what was in my records, yes, we would
    35        retain it.
    37   Q.   When you were giving evidence in chief, you added something
    38        to your statement about what happened to Anne Holmes.
    39        A.  Sorry, could you rephrase that?  When I added -----
    41   Q.   When you gave your evidence-in-chief, you added something
    42        to your statement concerning Anne Holmes; do you remember
    43        that?
    44        A.  Yes.  I believe I remember that she had gone to a
    45        Rights Commissioner.
    47   Q.   Why did you suddenly remember that?  Had you been looking
    48        at something which refreshed your memory about it?
    49        A.  I think I possibly had been looking at my statement.
    50        I cannot recall exactly.  I believe I was looking at my 
    51        statement. 
    53   Q.   You did not think of it when you were making your
    54        statement?
    55        A.  Well, obviously, I did not, if I did not put it in at
    56        that time.  As I said, I was going from memory.  It is a
    57        long time ago.
    59   Q.   What about Tom Caulfield; do you remember about him?
    60        A.  The only thing I remember about him was that he was on

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