Day 212 - 30 01 96 - Page 3
2 MS. STEEL: Yes. I am happy to accept that, but the only thing
3 I would like to say is that where their witnesses say it
4 does not happen as often as our witness has said or, for
5 example, that nobody could possibly work a 16 hour shift,
6 there should be borne in mind they have not disclosed the
7 documents, and that I am sure they would have done if they
8 were in their own interests.
10 MR. JUSTICE BELL: I do not know. I mean, the trouble with that
11 is what you have to do is to have a whole lot of people for
12 a lot of period of time. It is one of the disadvantages of
13 a long case that, really, if you pursue matters in that
14 detail you just never get to the end of it.
16 This discussion started with the fact that what your
17 instructing solicitors described as the relevant documents
18 from Mr. Beech's personnel file being disclosed. It might
19 be helpful if you, as they have only just arrived,
20 Mr. Rampton, just skated through them quickly and said what
21 their relevance as opposed to any other documents is.
23 MR. RAMPTON: My Lord, they all arise, this latest discovery, it
24 is really only the -- we have disclosed a plan of the
25 Heathrow store, just for ease of reference really.
27 MR. JUSTICE BELL: You need not deal with that.
29 MR. RAMPTON: That may have some relevance, if any, to where the
30 waste bins are to be found. But the point about the
31 personnel file is that until I first saw, or yesterday
32 morning, Mr. Beech's new allegations, there was nothing in
33 the personnel file that seemed to us to be relevant. For
34 example, the reference to holiday pay, to the Crew
35 Handbook, and so on and so forth, arise out of the new
36 allegations. References to those matters are to be found
37 in these pages of the personnel file. It so happens, as a
38 matter of chance, that Mr. Beech was hired and orientated
39 by Kim Moffatt who is our first witness.
41 MR. JUSTICE BELL: Right. Are there any documents in the
42 personnel file which throw light on what Mr. Beech says
43 about his holiday pay?
45 MR. RAMPTON: Yes, there are.
47 MR. JUSTICE BELL: Could you just direct us to those?
49 MR. RAMPTON: There is a thing called an orientation checklist,
50 my Lord. I will get Miss Moffatt to explain it, but it is
51 the third page. I am a bit chary about giving evidence in
52 advance on this topic, but what this tells you is what the
53 employee, the new employee, is told about it on their first
54 day. She will explain what the ticks mean and what the
55 various entries mean.
57 Your Lordship will see there references to the Handbook,
58 and she will explain what that means too.
60 This arises because Mr. Beech now says for the first time