Day 140 - 22 Jun 95 - Page 68


     
     1        A.  I also notice ----
     2
     3   Q.   You know the Baltimore area, do you?
     4        A.  Yes, I do.  Generally speaking, I know the Baltimore
     5        area.  Could you tell me when this was done?
     6
     7   Q.   I do not know.  I am going to check this out.
     8        A.  I do not know how I can start commenting on this thing
     9        if I have no idea when it was done.
    10
    11   Q.   If you look at the starting wage it is -- as a result of
    12        the survey of many of the stores it is 4.25; so it
    13        certainly indicates that it relates to after when the
    14        minimum wage was increased?
    15        A.  I am not sure of that, sir.  It could also be that they
    16        plugged in some numbers and it could also be that the
    17        minimum wage was a dollar less than that, and that is what
    18        the stores were paying.
    19
    20   Q.   Just by coincidence, all the stores happened to be
    21        paying----
    22        A.  I look at that as somebody plugged in some numbers,
    23        frankly.  But if you will take a look at our data, we are
    24        running at usually above the minimum wage.  So I do not
    25        know what we have in front of us.  I also notice that this
    26        document does not come from the group you mentioned.  At
    27        the top it says it comes from PUP which is in Philadelphia
    28        which is 150/160 miles away from the area it purports to
    29        cover.
    30
    31   Q.   Yes.  I got sent this about three days ago and I disclosed
    32        it immediately.
    33        A.  I also ----
    34
    35   Q.   If you note the conclusions of this -- you saw this
    36        document, did you?
    37        A.  I have seen it prior to today, yes; only because you
    38        handed it to the court.  So I saw it yesterday, the day
    39        before.  I cannot recall when.
    40
    41   Q.   But ----
    42        A.  Could I -- you drew my attention to a certain
    43        paragraph and I do not know if that means you expect me to
    44        adopt it or not.  But I just want to make reference to the
    45        same inadequacies of the PUP survey, and that is a claim
    46        they spoke with the Manager.  What manager is the Manager
    47        who has salary data?  If you recall correctly, we have
    48        varying starting rates in the stores based upon
    49        experience.  It appears they are asking for one rate and
    50        also appears that here, if the Manager did not give it to 
    51        him, they sent someone in.  Was that someone with a lot of 
    52        experience or very little experience?  How do I interpret 
    53        this thing?
    54
    55   Q.   Yes.  If you look at the conclusions -- this is the second
    56        paragraph -- "Of the 32 restaurants contacted for this
    57        survey" ----
    58        A.  Where are you reading from, please?
    59
    60   Q.   The first page.  "Of the 32 restaurants contacted for this

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