Day 134 - 13 Jun 95 - Page 19
1 three percentages, 16 per cent -- because of the weighting
2 of those percentages I have averaged that out about one
3 month, about 16 per cent stay one month -----
4
5 MR. JUSTICE BELL: I do not see how you get that, quite frankly.
6
7 MR. RAMPTON: I do believe this is a completely valueless
8 exercise.
9
10 MR. MORRIS: It is not at all.
11
12 MR. RAMPTON: If Mr. Morris wants to make a speech about this at
13 the end of the case or sometime at the end of this year or
14 the beginning of next, let him do so. This is a witness
15 who has a job to do. She is a busy person. She should not
16 be stood there while Mr. Morris makes wild assumptions
17 about what these figures mean.
18
19 MR. MORRIS: I am not making any wild assumptions.
20
21 MR. JUSTICE BELL: Just listen to me. I do not want you to say
22 what this means to you now. You can say what it means to
23 you when you are commenting at the end of the case and
24 I will either accept it or reject or accept it in part and
25 reject it in part -- just listen -- Ms. Mead is in the
26 witness box. You are to ask her questions. If she says:
27 "I cannot help you", in effect, as she has said about
28 this, "from my own experience", you must move on to
29 something else.
30
31 MR. MORRIS: All right. From my calculations on that first
32 column, it represents a turnover of 272 per cent a year.
33 The second column represents a turnover of 440 per cent.
34 That is the previous quarter to that one. I did not work
35 out the previous one. I will be submitting -- I just
36 thought I would give you the opportunity -- that the
37 turnover rate is in fact even higher -----
38
39 MR. JUSTICE BELL: Stop. Put it as a question.
40
41 MR. MORRIS (To the witness): That these figures which are a
42 reliable indicator, as you have said, on adducing turnover
43 and length of stay of staff represents a turnover rate of
44 the first quarter of 272 per cent, or thereabouts, and 440
45 per cent for the previous quarter. Have you made that
46 calculation? Have you tried to make that calculation to
47 understand these figures?
48 A. No, certainly not. I have no idea what you are
49 referring to.
50
51 Q. You can calculate, I mean, anyone can do that -- I am sure
52 everyone will.
53
54 MR. JUSTICE BELL: Then calculate it in due course.
55 A. I do not think you can calculate it from what you are
56 saying.
57
58 MR. JUSTICE BELL: I do not follow at the moment how you come to
59 that.
60
