Day 188 - 15 Nov 95 - Page 27


     
     1   Q.   Right. "In my view, the reason for this poor quality food
     2        was that staff were so wary of the abuse they would receive
     3        from the floor and shift managers if the production line
     4        was ever halted, that they simply ignored bad or rotting
     5        food.  This wariness extended from the lowliest crew
     6        members working on their first shifts up to and including
     7        shift managers who were subjected to similar abuse from
     8        store managers.  The abuse of staff was constant."
     9
    10        When you say "constant", do you mean during high pressure
    11        periods or all the time?
    12        A.  I think during high pressure periods it was at its most
    13        intense, but during the calmer periods there was a kind of
    14        a watching over of the staff to make sure they were kind of
    15        aware that they were -- you know, they had to work hard for
    16        their living, so if there was a lull and there were no
    17        customers, rather than kind of, you know, just being able
    18        to stand by the grill and have a couple of seconds chat,
    19        somebody would make sure that they would go and sweep the
    20        floor in the restaurant, whether the floor had just been
    21        swept five minutes earlier or not.  It was that kind of,
    22        you know, just keep people moving and working.  So there
    23        was that kind of pressure going on all the time.  But the
    24        real abuse kind of happened during the peak hours of
    25        demand.
    26
    27   Q.   Right.  In your notes on page 11, in the second to last
    28        full paragraph -- this is during the close -- you have, in
    29        the middle of that paragraph: "As people are queuing
    30        outside waiting for the restaurant to open, Almaz starts
    31        shouting more and more."  Do you remember that?  Were you
    32        there at that time?
    33        A.  Yes.  This is the record of when I was watching the
    34        night close.  I think what happened -- I mean, this kind of
    35        stunning operation of the whole store when it closes, it is
    36        stripped down and cleaned from top to bottom and put back
    37        together again, and has to be put back together again in
    38        time for the first breakfast to be served when it opens;
    39        and, you know, I sat there looking at it, thinking, "How
    40        are they ever going to get it ready"; and, quite clearly,
    41        the manager must have that experience on a daily basis of
    42        looking at it about 5.30 and thinking, "Oh, my God, are we
    43        actually" -- so the response is just to keep yelling,
    44        yelling and yelling, and keeping people -- I mean, people
    45        have been working all through the night, so energy is
    46        flagging, so it is a real, keep yelling at people and keep
    47        their energy going and keep them to keep going.  So the
    48        shouting started in that kind of getting at people just to
    49        keep going, keep going, keep going, because the store had
    50        to be open at six and breakfast had to be ready. 
    51 
    52   Q.   So what was the real problem, then, in terms of being able 
    53        to get ready in time during the night?
    54        A.  I mean, what I would think was happening -- I mean, on
    55        that night, I think, a couple of the people who were
    56        working through the night close had actually stayed on
    57        after their day shift.  So I think, from my memory, I think
    58        probably because a couple of the people that were supposed
    59        to do the night close had not turned up.  They were --
    60        Pervase, I think, was the one who worked all the way

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