P – You were recruitment consultant at Personnel Selection in April 1998?

GH – Yes.

P – You interviewed Simon Jones in April 1998 and asked him if he had had experience of dock work?

GH – He said he had worked for a couple of days at Newhaven as a casual labourer.

P – You went through the normal procedures?

GH – Yes.

J – Did you ask what work he had done in docks?

GH – He said labouring.

P – On the evening of 23 rd April 1998 you had a request from Euromin for workers?

GH – Yes.

P – (refers to document) It says here, “send Simon Jones to docks for 8.30”, is that your writing?

GH – Yes.

P – Was the request for 1 or more than 1 worker?

GH – It was for 2.

P – Was it Grant who made the request?

GH – Yes.

P – Did you find 2 workers at short notice?

GH – No.

P – So Simon was given a hat etc and sent by taxi at 7.45?

GH – Yes.

D – You went through the normal procedures including discussing health and safety with regard to dock work – form GA1?

GH – Yes.

D – This form was tailor made for docks?

GH – Yes.

D – This was part of the Company's literature?

GH – Yes.

D – You went through this form with Simon Jones?

GH – Yes.

D – On the 4 th line up it says,” always stand clear of the load being lifted”?

GH – Yes.

D – So you were providing him with safety notes?

GH – This form was produced by the Company when dealing with Cocoa boats at Shoreham and was for labourers unloading on the quay side.

D – Did it contain specific advice for labourers working in the ship's hold?

GH – inaudible.

D – You were satisfied that Simon Jones was suitable to send to Euromin?

GH – Yes.