Day 138 - 20 Jun 95 - Page 22
1 There is a good deal of detail, including some figures. On
2 the whole, Mr. Stein, unless his Lordship prefers
3 otherwise, I would rather you did not have ---
4 A. That is fine.
5
6 Q. -- any writing in front of you ---
7 A. Perfectly fine.
8
9 Q. -- except as necessary. I will, however, read you out the
10 various allegations that are made by the Defendants so that
11 you can deal with them.
12
13 MR. JUSTICE BELL: When Mr. Rampton reads it out, he is not
14 asking you just for a general comment. He will ask you
15 specific questions once he has read it to you.
16 A. Yes, my Lord.
17
18 MR. RAMPTON: I will just read it out so you know what it is we
19 are dealing with, Mr. Stein, then I will ask questions
20 about it, if I may.
21 A. The first allegation, if we may call it that,
22 Mr. Stein, is this, that in the United States in 1989 the
23 official minimum wage in Philadelphia was $3.70 per hour.
24 McDonald's pay $3.70 to $4. The first question, do you
25 recall what the Philadelphia minimum wage was in 1989?
26 A. My recollection would be that 3.70 would be correct.
27
28 Q. As a slight digression from that -- there is no need to
29 look at it -- the chart which you have supplied to us
30 giving the national minimums shows us, if it be right, that
31 the national or federal minimum at that time, 1989, was
32 3.35?
33 A. I believe that is correct.
34
35 Q. So the Philadelphia minimum was above the federal minimum?
36 A. Yes, it was.
37
38 Q. So that had been done by the city or by the state?
39 A. I believe that was the state of Pennsylvania.
40
41 Q. My question is what, in fact, was the average starting
42 rate, if you can remember, paid by McDonald's in
43 Philadelphia at that time?
44 A. It would be in the 3.90 area, I think, 92, 93,
45 something like that, up to 4.13, I believe.
46
47 Q. Would that have been the average starting rate?
48 A. That is correct, sir.
49
50 Q. So the average rate for the crew as a whole in Philadelphia
51 would have been the same, more or less?
52 A. It would be the same; it would be within that rate.
53
54 Q. That is for the starting rate; what about the average rate
55 for all workforce?
56 A. The average rate, oh, that would be higher.
57
58 Q. A bit more substantial: Again in Philadelphia in
59 1989 -- my Lord, this is on page 8, it is (ii), it is 99 of
60 the Abstract -- this reads, Mr. Stein, as follows: "In or
