Day 137 - 19 Jun 95 - Page 18


     
     1        20, and you should find, I hope, marked B a specimen copy
     2        of some part of what we believe to be the Corporation's
     3        licence agreement used in the United States?
     4        A.  Yes.
     5
     6   Q.   Is that what it is?
     7        A.  Yes, it is.
     8
     9   Q.   Thank you.  Do not bother with document C which are some
    10        statistics about the National Labour Relations Board's
    11        activities.  Pass please to document D1 which should be a
    12        three-page document consisting of tables of percentages, is
    13        it?
    14        A.  Yes, it is.
    15
    16   Q.   Is it headed:  "1990 EEO 1 data"?
    17        A.  Yes, it is.
    18
    19   Q.   Before I draw your attention to different parts of this
    20        document, can you tell us how this document came into
    21        being, please?
    22        A.  Yes, I had it prepared.
    23
    24   Q.   You had it prepared for this case?
    25        A.  Yes.
    26
    27   Q.   What are the data on which these tables are based?
    28        A.  There are two types of data here.  One is McDonald's
    29        information, and that information comes from a report.
    30
    31   Q.   You will find that, perhaps, at D2?
    32        A.  Yes, I have it.
    33
    34   Q.   Tell us about this report.
    35        A.  These are commonly known in the United States as EEO 1
    36        reports.  One thing the government does require, the
    37        Federal Government of the United States, is that annually
    38        every employer submits statistical information, if you
    39        will, dealing with their employment, what the numbers of
    40        minorities, women and whites are and males and females,
    41        within their organisation at very specific levels.  If you
    42        notice on D2, on the left-hand side it specifies the
    43        classifications.
    44
    45   Q.   Yes, if you look at D2 -- this a government form then,
    46        Mr. Stein?
    47        A.  It is, yes.
    48
    49   Q.   It is filled on or completed by somebody called Melvin C.
    50        Hopson who is described as a Director of Affirmative 
    51        Action.  Is he a McDonald's person? 
    52        A.  Yes, he is. 
    53
    54   Q.   He or his secretary or one of his minions has written the
    55        numbers in in handwriting, is that what it is?
    56        A.  Yes, once in a while -- I am sorry, once in a while an
    57        English word has a different connotation in American
    58        English.
    59
    60   Q.   Not for the first or the last time, Mr. Stein, I am sure.

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