Cross Examination-Witness Statement of Damon Barry.

Cross Examination

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

busy restaurant

long corridor

not get same energy to mop the whole floor.

become tired

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 ?