Day 212 - 30 01 96 - Page 68

 
 

                                                                  DAY 212
 
                                             KIM MOFFATT, Cross-examined:
 
 
 
     1
     2   Q.   Why?
     3        A.  Just storage space.
     4
     5   Q.   Do you not think that is really a recipe for confusion and
     6        people making a mistake?
     7        A.  No.
     8
     9   Q.   You do not think that is a problem?
    10        A.  No.
    11
    12   Q.   Are you aware it is a legal requirement to keep an accident
    13        book and to ---
    14        A.  Yes.
    15
    16   Q.  -- to keep it until -- I think it is five years ---
    17        A.  I am not sure of the legal requirements.  I just know
    18        that -----
    19
    20   Q.   -- the last entry.  What was this accident book doing in
    21        the corral?
    22        A.  What accident book, sorry?  Where is that?
    23
    24   Q.   You said you thought it might have got destroyed in a fire.
    25
    26   MR. JUSTICE BELL:  She said there was a fire, but she did not
    27        think it was destroyed in the fire because the dates did
    28        not tally.
    29
    30   MS. STEEL:   Right.  I thought she went on and said -----
    31
    32   MR. JUSTICE BELL:  The gap was from March to October, and she
    33        thought the fire was before that, while John Nevison was
    34        there, which would only be up to February.
    35
    36        (To the witness) Is that what you meant to say?
    37        A.  That is what I meant, yes.
    38
    39   MS. STEEL:  What kind of paperwork was kept in this corral,
    40        then?
    41        A.  In the corral?
    42
    43   Q.   Yes.
    44        A.  Anything that we needed to keep; so, schedules, clock
    45        card files, spare pieces of paperwork.  Obviously, we did
    46        not have much room for storage in the offices, so we used
    47        the corral.  We could lock it up; there is a filing cabinet
    48        in.
    49
    50   Q.   The corral was where the rubbish was kept, was it not? 
    51        A.  No.  The rubbish was kept ----- 
    52 
    53   Q.   Or the rubbish area?
    54        A.  You could say that.  There was a compactor with a
    55        rubbish area there.  The corral is a separate building.
    56
    57   Q.   Yes.  It is across the car park?
    58        A.  Yes.
    59
    60   Q.   How far away from the main building?
 
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