Day 203 - 12 Jan 96 - Page 54


     
     1   Q.   I do not think you heard that view, did you, commonly
     2        expressed by McDonald's workers, hourly paid workers, that
     3        they feel that they are not getting paid for all the hours
     4        they have worked?
     5        A.  No, and I have done quite a lot of rap sessions.  There
     6        have been odd incidents, odd incidents, where -- no, I
     7        mean, odd incidents where small payroll administration
     8        problems have come up at rap sessions, which it is then
     9        recommended, as a result of the rap session action plan and
    10        the restaurant Manager takes action on this, that they put
    11        systems in place to ensure that mistakes with the
    12        administration of people's pay do not occur.
    13
    14   Q.   Are you aware of the result of the crew questionnaire that
    15        have come out each year?
    16        A.  The Crew Opinion Survey?
    17
    18   Q.   Opinion Survey, sorry, yes.
    19        A.  I was not party to the last set of results.  I cannot
    20        recall much detail of the previous set of results.  They
    21        would not have concerned me on the last occasion.
    22
    23   Q.   Would it surprise you if a substantial percentage felt they
    24        were not being paid for all the hours that they worked?
    25        A.  Yes, that would surprise me, because there are a lot of
    26        systems in place to ensure that crew get their pay for the
    27        hours they have worked.  Most of the complaints I have ever
    28        heard about crew not being paid, it is usually because they
    29        omit to use the Hunter correctly, like they forget to clock
    30        in after a break, or something like that.
    31
    32   Q.   Do you remember who you consulted in the region of Human
    33        Resources Departments about investigating clock cards?
    34        A.  Yes, I believe the name of the person is Carol Sellers.
    35
    36   Q.   In the notes for your statement, before you actually wrote
    37        and signed the statement, under "Labour costs" it says:
    38         "Labour costs:  Ray Coton was under no greater pressure
    39        than other managers"?
    40        A.  Which particular notes are you referring to?
    41
    42   Q.   These were the notes that were provided by the Plaintiffs.
    43
    44   MR. RAMPTON:  My Lord, I rise to remind Mr. Morris that I gave
    45        an explicit warning ---
    46
    47   MR. MORRIS:  Yes, that is why I am asking the witness.
    48
    49   MR. RAMPTON:  -- when these notes were handed in that they did
    50        not represent necessarily an accurate version of what the 
    51        witness had said. 
    52 
    53   MR. MORRIS:  Was Ray Coton under greater pressure than other
    54        managers or was that normal?
    55        A.  Sorry, could you repeat the question, please?
    56
    57   Q.   It says here, "Ray Coton was under no" ------
    58
    59   MR. JUSTICE BELL:  Just put the factual basis, do not bother
    60        with -----

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