Day 138 - 20 Jun 95 - Page 27


     
     1        A.  No, this was the work of Towers, Perrin and the
     2        Professor.
     3
     4   Q.   There we see in graphic form the difference of 11 cents
     5        displayed for us, do we not?
     6        A.  Yes, we do.
     7
     8   MR. MORRIS:  Sorry,  can we just clarify that on this document?
     9        Is this actually a reprint of their document or is it a
    10        summary?
    11        A.  Do you want me to answer that?  I can get out of the
    12        controversy quickly.  This is a reprint of what they did.
    13
    14   MR. MORRIS:  A reprint, a photocopy ---
    15        A.  Photocopy.
    16
    17   Q.   -- of a page from their report?
    18        A.  That is correct.  It is identical to their report.  It
    19        is just a copy from their report.
    20
    21   MR. RAMPTON:  This was, was it, distributed with the document
    22        which we see in front of us?
    23        A.  Yes, sir.
    24
    25   Q.   Was this document, the three page typescript, intended for
    26        public consumption?
    27        A.  Yes, it was.
    28
    29   Q.   It was.  These graphs or tables, call them what you like,
    30        the four of them have exhibit numbers, do they not. 1, 2,
    31        3, 4 ---
    32        A.  Yes.
    33
    34   Q.   -- to the right-hand corner?
    35        A.  Yes.
    36
    37   Q.   It says at the bottom of 1475, which is Exhibit 1:  "TPF&C
    38        survey of the 33 McDonald's restaurants included in PUP's
    39        original survey, average entry level rates", that is
    40        starting rate, is it?
    41        A.  That is correct.
    42
    43   Q.   Then an asterisk on the 33:  "Data for five of the 33
    44        restaurants originally in the PUP's sample, 15 per cent,
    45        were not available at the time the McDonald's survey was
    46        conducted.  Two of these restaurants are closed".
    47        Mr. Stein, so far as your knowledge of the facts of the
    48        matter are concerned, does that absence of five restaurants
    49        from the 33 make any difference to the validity of these
    50        findings? 
    51        A.  No, and specifically I asked that question when we went 
    52        through this process and the answer was, no, it would not 
    53        affect it.
    54
    55   Q.   Then for the same 33 restaurants, subject to the same
    56        qualification, the next page, 1476, tells us, if it be
    57        right, that the median starting rates for the same
    58        restaurants was $4 exactly?
    59        A.  That is correct.
    60

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