Day 140 - 22 Jun 95 - Page 67
1 A. That is correct, my Lord. I do have disagreements with
2 it as I read it, but I do not know if that is what you are
3 ----
4
5 Q. What was PUP's last word on this as far as you can remember
6 when it came to your attention?
7 A. My Lord, if I am interpreting the question correctly,
8 their first word and their last word were the same and that
9 is that they had done their survey and they were sticking
10 by their survey versus ours, and I do not believe -- I am
11 positive -- that their viewpoint did not change; we did not
12 speak directly with them; they did not request that.
13 Instead, as I mentioned, we spoke with community leaders
14 about this matter. But I, you know, look at this and
15 I look at words that are probably accurate, probably
16 valid. I would have liked a larger sample. Those are the
17 larger samples exactly, my Lord, what we were talking about
18 earlier, that they chose 33 stores out of 118 etcetera.
19 I guess we would really be going back over what we have
20 talked about up until now, so ....
21
22 MR. MORRIS: You also note the more than adequate base from
23 which to generalise a statement?
24 A. I do not know how he can reach that conclusion because
25 if you look at PUP survey it would appear on its face that
26 they selected all the stores in the area. If I was getting
27 that report, I would make that assumption. On the
28 contrary, they did not even pick all the stores that were
29 in the city area, and they clearly did not pick the stores
30 in the suburban area. So I do not know how he can reach a
31 conclusion based upon incomplete information.
32
33 Q. Of course, we do not have any information really from the
34 TFP&C survey, do we?
35 A. You have their survey. I will also suggest to you that
36 Mr. Davidson's letter and the PUP survey completely
37 contradict one other, and I would assume that that
38 contradictory information, or the correct information, was
39 not supplied to Mr. Bartell. So I would not put a whole
40 lot of faith in something that had PUP's incomplete data
41 and information. If you take a look at PUP's survey it --
42 for anything it answers it raises 50 questions.
43
44 Q. Behind that letter, that evaluation, can you see this thing
45 headed "McDonald's Survey"?
46 A. Yes.
47
48 Q. This is from the Baltimore Metropolitan area and says at
49 the last but one paragraph on that page, "The data was
50 collected by the mid-Atlantic coalition for responsible
51 investment through a conversation with restaurant
52 managers. In some cases where the manager was unwilling to
53 disclose the wage rates someone filled out an application
54 in order to obtain information."
55
56 Are you aware of this having been done in the Baltimore
57 area?
58 A. No, sir, not at all.
59
60 Q. If you look over the page ----
