Day 212 - 30 01 96 - Page 69

 
 

                                                                  DAY 212
 
                                             KIM MOFFATT, Cross-examined:
 
 
 
     1        A.  I do not know -- just 12 foot.  I would not -----
     2
     3   Q.   The car park is only 12 foot -----
     4        A.  I could not say how far.  It a couple of steps.  I have
     5        never measured it.
     6
     7   MR. JUSTICE BELL:  Where would you go for your plasters if you
     8        cut yourself, or something like that?  Was there a place
     9        where there was a First Aid box?
    10        A.  Yes.  First Aid box in the Manager's office.
    11
    12   Q.   Someone simple minded, like myself, might think it sensible
    13        to keep the accident book near the First Aid box.
    14        A.  Yes, they are pretty near.
    15
    16   Q.   So you tape yourself up and then write it in the book?
    17        A.  Yes.  They are near each other.
    18
    19   Q.   But I thought you said it was in a different room or
    20        building?
    21        A.  No.
    22
    23   MS. STEEL:   That is paperwork.
    24
    25   MR. JUSTICE BELL:  That is not the accident book?
    26        A.  No, no.  The accident book is in a small cabinet on the
    27        deck, and opposite is the First Aid box.
    28
    29   MS. STEEL:  When you became aware that people had started
    30        filling in the wrong accident book, or when the first entry
    31        was made in the wrong accident book, you did not think it
    32        was appropriate to take steps and, you know, either
    33        transfer the entry or put the spare accident book somewhere
    34        else, so that the confusion did not continue?
    35        A.  No.  I mean, I could not transfer anything because,
    36        obviously, some of them are signed, so you cannot transfer
    37        it, really; it is in their handwriting.  No, just left
    38        them.  I cannot recall what I did with them, but they were
    39        both in the drawer.
    40
    41   Q.   You spent most of your time on admin?
    42        A.  Yes.
    43
    44   Q.   So where did you work?
    45        A.  What, in the store?
    46
    47   Q.   Yes.
    48        A.  In the Manager's office.
    49
    50   Q.   In the Manager's office.  So, generally, you cannot really 
    51        see what is going on on the floor in the kitchen area? 
    52        A.  Depends.  At what time of the day? 
    53
    54   Q.   When you leave the office you might do; but when you are
    55        sat in the office doing your admin work, you do not really
    56        know what is going on on the floor?
    57        A.  Not when I am in the office.  When I am working the
    58        floor, I do.
    59
    60   Q.   So, accidents could be going on and you would not know
 
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