Witness Statement of Damon Barry.
You have been working for McAndrew’s for 5 years, havent you ?
And for the Muswell Hill branch for 2 years, haven’t you ?
This is reasonably big size restaurant, isnt it ?
The length of the corridor from the counter to the entrance is approximately 50 to 60 feet, isn’t it ?
Your duties include serving food and cleaning up the restaurant, doesn’t it ?
It is generally busy restaurant, isn’t it ?
So, you have to work fast ? haven’t you ?
On 6th April 2002 in the afternoon, you were cleaning the corridor the central part of the restaurant, weren’t you ?
You took a bucket and mop to clean the floor, didn’t you ?
And you mixed floor cleaners with water to clean the floor properly, didn’t you ?
So it makes the floor soapy, doesn’t it ?
And slippery ?
So, it will be hard for anyone to walk on the floor once its slippery, isnt it ?
Therefore you took a cloth to dry the floor, didn’t you ?
Which you attached to the mop, didn’t you ?
As you have to attach the cloth to the mop, it is generally a small cloth, isnt it ?
And this is a long corridor to clean, isnt it ?
So, you have to clean and dry the floor fast, haven’t you ?
And you use the same cloth to dry the whole corridor, don’t you ?
So, the cloth becomes wet after certain time, doesn’t it ?
Sometimes some part of the floor does not dry properly, does it ?
And it generally takes time to dry the floor, doesn’t it ?
So,there was a patch of the floor was wet, wasn’t it ?
squeeze the mop out before cleaning
not get same energy to mop the whole floor.
However, you used warning sign to warn the people, didn’t you ?
There were three yellow plastic ‘slippery floor’ sign on the whole floor, werent there ?
And you put three of them in a triangle formation around a patch when you clean, don’t you ?
When Mrs Anne Taylor slipped on the floor you were cleaning near to the entrance, werent you ?
And she slipped over on her way back from the toilet, didn’t she ?
And the toilet was near the counter, wasn’t it ?
And the stairway was far from the toilet, wasn’t it ?
So, the area of the floor she slipped was far from the stairway, didn’t she ?
I think you can remember that you left a warning sign in the area of the floor which is about level with the stairway, didnt you ?
So, there was no warning sign where she slipped over the floor, wasn’t there ?
When Mrs Taylor slipped over the floor you , your manager and Jenny Horner came to assist her, didn’t you ?
And You found her landed on the floor with her legs across the path, didn’t you ?
So she skated when she fell over, didn’t she?
And you didn’t found her exactly where she fell on, did you ?
And the next minute you called the ambulance, didn’t you ?
So it was obvious that she sustained serious injury, wasn’t she ?