Day 212 - 30 01 96 - Page 67

 
 

                                                                  DAY 212
 
                                             KIM MOFFATT, Cross-examined:
 
 
 
     1        there?
     2        A.  No.
     3
     4   Q.   If you kept bringing it up at every Managers meeting?
     5        A.  If there was it to bring it up at every Managers
     6        meeting, I would bring it up.
     7
     8   Q.   And you did bring it up at every Managers meeting?
     9        A.  No.  I must have got sentence wrong.
    10
    11   MS. STEEL:  You said in your statement that the restaurant had
    12        two or 3 accident books in use at that time.  I am not sure
    13        what "that time" means.  What does "that time" mean?
    14        A.  Whereabouts are we?
    15
    16   Q.   Bottom of page 4 and top of page 5.
    17        A.  Yes.
    18
    19   Q.   What time are you talking about, for the duration of when
    20        Mr. Beech was working there, or -----
    21        A.  I meant the duration I was there.
    22
    23   Q.   They were all in use at one go?
    24        A.  Well, I think it was due to error, because there were
    25        -- obviously, you keep the accident book that you are
    26        currently using with the date on the top that you are using
    27        it from, and any spare accident books would go underneath;
    28        and I can feel, I think it was due to error, people were
    29        just picking up the wrong one, that we had a couple in use
    30        at one time.
    31
    32   Q.   So, where were the accident books kept?
    33        A.  They are in a small cabinet in the Manager's office.
    34
    35   Q.   Was that an open cabinet, or -----
    36        A.  That was a drawer.
    37
    38   Q.   A drawer?
    39        A. Yes.
    40
    41   Q.   Was it locked?
    42        A.  No.
    43
    44   Q.   So, are you just saying that in these accident books that
    45        people picked up by mistake, there would have just been one
    46        or two accidents?
    47        A.  No.  I mean, obviously, I do not know where these
    48        accident books are, because we have not got them.  But
    49        I know for a fact that there is more than one.
    50 
    51   Q.   Did you have responsibility for the accident books?  Was 
    52        that part of your area of responsibility? 
    53        A.  To make sure it was there, yes, and it was in use.
    54
    55   Q.   Do you know why it was there were two or 3 put out at one
    56        go anyway, rather than sort of having spare ones in a
    57        cupboard somewhere else?
    58        A.  No.  You use -- they were all together.  So you have
    59        your current one on top, and any spares you keep in store
    60        underneath, in one drawer.
 
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