Day 209 - 25 Jan 96 - Page 72


     
     1        upon the clock cards.  The document was headed:
     2         "Mistreated by schedule" and I served it this morning.
     3        I do not know if you have a copy of it there?
     4        A.  I gave you my only -- the thing I wrote out last night.
     5
     6   Q.   Here is your original.  Without going to all the clock
     7        cards, if you can just explain what you are trying to say
     8        there and how you chose John Gore or whatever?
     9        A.  Right.  Well, I read in the statements that, you know,
    10        people -- it was very difficult to prove whether people
    11        were getting unsocial shifts, et cetera, and I just took
    12        John Gore's name and checked him out because he was the top
    13        one on what I had said.  He is the one I knew most that
    14        used to complain about it.
    15
    16   Q.   You said he had been mistreated by schedule?
    17        A.  Yes.  We only had these five weeks and I just put it --
    18        all his actual schedules down, not the clock card reports,
    19        but the schedules down, for each day, and did a break down
    20        of them and ----
    21
    22   Q.   Based on those page numbers on the left in the second
    23        volume, yes?
    24        A.  Yes.
    25
    26   Q.   Yes.
    27        A.  And I just found a few.  I was not -- I did not really
    28        know what I was looking for.
    29
    30   Q.   What are the ones that say "my schedules"?
    31        A.  They were the -- the time you picked to look at a time,
    32        a section in time in McDonald's in Bath, at that time,
    33        I happened to be doing some of the schedules.  I think
    34        there were four of them, but I am unsure, because I do not
    35        remember the dates, but they look like my handwriting; two
    36        or three of them definitely are.  Anyway, what I found was
    37        that in that whole time he had not a single whole weekend
    38        off, you know, in all those periods we checked, which was a
    39        common problem with people like John Gore, the fully flexed
    40        full-timers who, you know, always seemed to end up working
    41        Saturdays and stuff.  So that he did not have a single
    42        weekend off out of the ones we checked.  Out of 10
    43        Saturdays, he did eight night shifts, one day shift and one
    44        requested day off.  I think it was already agreed that
    45        Saturday nights are very unsocial shifts.  It is the
    46        busiest shift of the week; it is the shift that nobody
    47        wants to do, because you are having to clean up from the
    48        busiest day shift of the week.  So you have not only got
    49        extra business; you have also got extra dirt from the day
    50        shift.  So people just do not like to do it. 
    51 
    52        Then I just checked out the total of his shifts.  I just 
    53        wanted to see how many of them -----
    54
    55   MR. JUSTICE BELL:  Just pause a moment.
    56        A.  Sorry, yes.  Out of all the shifts -----
    57
    58   Q.   Just pause.
    59        A.  Sorry.
    60

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