Day 212 - 30 01 96 - Page 3

                                                                  DAY 212
     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