Day 206 - 22 Jan 96 - Page 53


     
     1
     2   Q.   You do not recall complaint from her?
     3        A.  No.
     4
     5   Q.   Jane, you say, shared a house with the Store Manager; that
     6        was for a short time, was it not?
     7        A.  It was the period in which Dave Wynn was the restaurant
     8        Manager and until he got promoted and then they stayed
     9        within the house afterwards.
    10
    11   Q.   Why should being friendly with the Store Manager put her in
    12        a good position to resolve any problems?
    13        A.  Well, the Store Manager is, basically, the head of the
    14        store.  So, if she could not resolve by per chance her
    15        grievance with me, then she could, in theory, take it to
    16        the Store Manager and leave it with the Store Manager.  She
    17        would have more immediate access than anybody else.
    18
    19   Q.   You say she left the restaurant when David Wynn left.  When
    20        did David Wynn leave?  You said February 94.  Yes?
    21        A.  Yes.
    22
    23   Q.   How do you know she left the restaurant at that time?
    24        A.  I believe it would be from her employee record or
    25        subsequent clock card.
    26
    27   Q.   Are you basing this statement on documents that you have
    28        seen when you wrote the statement or are you basing it from
    29        your memory or both or either or what?
    30        A.  Both the documents I have reviewed and my memory.
    31        Obviously, such circumstances that -- personal
    32        circumstances would not be recorded in anybody's personnel
    33        file.
    34
    35   Q.   Just going back to Paul Scott Shepherd; you say it is
    36        correct that he worked a lot of shifts.  Would that be
    37        based upon documents that you reviewed when you were
    38        writing the statement?
    39        A.  It would be of my personal recollection of Paul's
    40        shifts and review of so many hours that he has worked?
    41
    42   Q.   In documents?
    43        A.  Yes.
    44
    45   Q.   This was in 1993, the allegation about very many shifts in
    46        a row.  So did you go through the records of 1993?
    47        A.  I have not gone through the entire records.  I have got
    48        records that are supplied in this document, yes, that I
    49        have reviewed.
    50 
    51   Q.   So, did you see other documents, though, from 1993 apart 
    52        from, I cannot remember what it was, May 1993 and August 
    53        1993, did you see other documents as well when you were
    54        writing your statement?
    55
    56   MR. JUSTICE BELL:  I thought it was August 93, May 94 and August
    57        94.
    58
    59   MR. MORRIS:  That is right.  It is August 93.  Did you see other
    60        months as well from 93 -----

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