Day 140 - 22 Jun 95 - Page 67


     
     1        A.  That is correct, my Lord.  I do have disagreements with
     2        it as I read it, but I do not know if that is what you are
     3        ----
     4
     5   Q.   What was PUP's last word on this as far as you can remember
     6        when it came to your attention?
     7        A.  My Lord, if I am interpreting the question correctly,
     8        their first word and their last word were the same and that
     9        is that they had done their survey and they were sticking
    10        by their survey versus ours, and I do not believe -- I am
    11        positive -- that their viewpoint did not change; we did not
    12        speak directly with them; they did not request that.
    13        Instead, as I mentioned, we spoke with community leaders
    14        about this matter.  But I, you know, look at this and
    15        I look at words that are probably accurate, probably
    16        valid.  I would have liked a larger sample.  Those are the
    17        larger samples exactly, my Lord, what we were talking about
    18        earlier, that they chose 33 stores out of 118 etcetera.
    19        I guess we would really be going back over what we have
    20        talked about up until now, so ....
    21
    22   MR. MORRIS:  You also note the more than adequate base from
    23        which to generalise a statement?
    24        A.  I do not know how he can reach that conclusion because
    25        if you look at PUP survey it would appear on its face that
    26        they selected all the stores in the area.  If I was getting
    27        that report, I would make that assumption.  On the
    28        contrary, they did not even pick all the stores that were
    29        in the city area, and they clearly did not pick the stores
    30        in the suburban area.  So I do not know how he can reach a
    31        conclusion based upon incomplete information.
    32
    33   Q.   Of course, we do not have any information really from the
    34        TFP&C survey, do we?
    35        A.  You have their survey.  I will also suggest to you that
    36        Mr. Davidson's letter and the PUP survey completely
    37        contradict one other, and I would assume that that
    38        contradictory information, or the correct information, was
    39        not supplied to Mr. Bartell.  So I would not put a whole
    40        lot of faith in something that had PUP's incomplete data
    41        and information.  If you take a look at PUP's survey it --
    42        for anything it answers it raises 50 questions.
    43
    44   Q.   Behind that letter, that evaluation, can you see this thing
    45        headed "McDonald's Survey"?
    46        A.  Yes.
    47
    48   Q.   This is from the Baltimore Metropolitan area and says at
    49        the last but one paragraph on that page, "The data was
    50        collected by the mid-Atlantic coalition for responsible 
    51        investment through a conversation with restaurant 
    52        managers.  In some cases where the manager was unwilling to 
    53        disclose the wage rates someone filled out an application
    54        in order to obtain information."
    55
    56        Are you aware of this having been done in the Baltimore
    57        area?
    58        A.  No, sir, not at all.
    59
    60   Q.   If you look over the page ----

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