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Failed to advise the Second Defendants that the existing tu rn stile
facilities at the Leppings Lane end were inadequate to acccrrrnodate
a croud of 24,000 and that for such fa c ilitie s to be adequate they
should include the n a tte rs set out in sub-pa rag raph (a) above of
the Particulars of Negligence and Breach of Statutory Duty against
the Second Defendants;
Failed to advise the Second Defendants of th eir failu re v ith in the
ground to sign clearly the existence of and the way to pens
one/two and six/seven;
Failed (i ) to recognise the need to provide a sufficient means of
escape of the crowd from the pens in the event of emergency
(ii)
To advise the First, Second and Third Defendants and the
Football Association of the need to provide such means of
escape.
(iii) To heed that the gates provided were not such a sufficient
means of escape.
(iv)
To design a sufficient means of escape as above.