Day 195 - 04 Dec 95 - Page 24
1 seriously by the crew.
2
3 3.3. Both Frank Stanton (FS) and Mark Davies (MD)
4 attribute to me certain statements which I never made.
5 Contrary to MD's suggestion (32), I never claimed that the
6 average close at the store was 3.00 to 4 a.m.. Similarly,
7 nowhere in my statement do I claim that staff had to work
8 all night when the Area Supervisor visited the store as
9 stated in the statements of MD (33) and FS (9).
10
11 3.4. MD (33) mentions that 'close' did not mean finishing
12 work at midnight. This may be so but, as I have pointed
13 out in my original statement (page 5), the breaks and the
14 amount of food given to each crew member were always
15 calculated on the basis of and proportional to the number
16 of hours she/he worked on that specific shift.
17
18 The 'close' shifts were always considered as midnight
19 finish for this purpose. So a 4 p.m. - close shift, for
20 example, was taken as an eight hour shift and the length of
21 break and amount of food was calculated accordingly. As
22 the closing time was almost always past midnight, the crew
23 on the close shifts were given shorter breaks and less food
24 than they were really entitled to.
25
26 3.5. I recall being told by Mark Davis to squeeze the fry
27 boxes when filling them up to increase the yield".
28
29 That is signed Siamak Alimi, dated 13th April 1994. Can
30 you just say, this statement, did you write this yourself
31 or was it prepared for you?
32 A. I wrote this myself.
33
34 Q. That was for this case, was it?
35 A. That is correct.
36
37 MR. MORRIS: Verify it.
38
39 MR. JUSTICE BELL: I have assumed that.
40
41 MS. STEEL: You stand by everything in the statement?
42 A. Yes, I do.
43
44 Q. If you could get out bundle -- it is document 117 behind
45 you on the lower shelves -- Defendants' list of documents
46 with the blue labels, document No. 117.
47
48 MR. JUSTICE BELL: It is in bundle No. 4 and it is on the top,
49 I think, divider 17. Does that start with your Contract of
50 Employment?
51 A. Yes, that is right.
52
53 MS. STEEL: It is really just to verify -- there is a series of
54 pay slips in here. Could you verify whether they are your
55 pay slips?
56 A. Yes, those ones which have got my name on it are mine.
57
58 Q. Right, OK. They do not cover the whole of the period that
59 you were working at McDonald's?
60 A. Yes.
