Day 140 - 22 Jun 95 - Page 43


     
     1        on Towers Perrin Foster & Crosby, but an attack on behalf
     2        of what McDonald's produced as a summary from the Towers
     3        report.  But there we are.  You put it fair and square, and
     4        you have Mr. Stein's answer to it.
     5
     6   MR. MORRIS:  Mr. Stein, McDonald's extracted summary which was
     7        allegedly based on the unavailable survey, in your third
     8        paragraph in your summary, page 1472 ---
     9        A.  Third paragraph, yes.
    10
    11   Q.   Yes -- "TPF & C's research indicated" -- it did not say
    12        "found" -- "indicated that the average differential
    13        between city" -----
    14
    15   MR. JUSTICE BELL:  Are you suggesting there is -----
    16
    17   MR. MORRIS:  There is a slight difference.
    18
    19   MR. JUSTICE BELL:  Where?
    20
    21   MR. MORRIS:  Indication can be what the person reading it has
    22        concluded, rather than the person who actually did the
    23        actual study.
    24
    25   MR. JUSTICE BELL:  I interpreted it as meaning "showed".
    26
    27   MR. MORRIS: "....indicated that the average differential between
    28        city and suburban starting wage rates for McDonald's
    29        restaurants included in the PUP survey is actually 11
    30        cents."  That does not say "was", does it?
    31        A.  You have to go back to the time period that they were
    32        using.  They were trying to mirror what they thought the
    33        time period was that PUP had used, and they are trying to
    34        emphatically say there that when matching up apples to
    35        apples, this is what it is.
    36
    37   Q.   There is nothing anywhere, is there -- can you find
    38        anything in your executive, whatever you call it, in your
    39        statement here, this document, that says that period
    40        surveyed was, in fact, something that was
    41        pre-November 1989?
    42        A.  The document speaks for itself.
    43
    44   Q.   You cannot find anything in there, then?
    45        A.  You want me to start reading the entire thing and
    46        wasting even more time than we have wasted since we have
    47        come back from lunch?
    48
    49   MR. JUSTICE BELL:  I am sorry, Mr. Stein, but I have to say
    50        I find it unattractive when you make comments like that. 
    51        You may be subject to all sorts of frustrations, but you 
    52        just have to grin and bear it.  For better or worse, the 
    53        Corporation of which you are an executive started this
    54        litigation.  If it wants to see it through, it must do so
    55        with forbearance.
    56        A.  Yes, my Lord.
    57
    58   MR. MORRIS:  As Ms. Steel pointed out, the second to last
    59        paragraph: "Commissioned an independent survey of starting
    60        wage rates at Philadelphia McDonald's restaurants in May."

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