Day 197 - 07 Dec 95 - Page 40


     
       1      A.  I was either a Trainee Manager or Security at the
       2      time.  As I said earlier on, I cannot remember the exact
       3      position.  I know I was involved in it.  I know what
       4      actually happened.  I was there at the time.
       5      Unfortunately, I have got no records with me so I was
       6      actually doing it from memory.
       7
       8 Q.   I know.  I am not criticising you for that.  But, looking
       9      at that, you are disputing the accuracy of that document
      10      which was looked at?
      11      A.  I am not.  I am not saying that is wrong.  I am saying
      12      when I actually wrote my statement I had nothing to refer
      13      to.  I was doing it from memory as far as dates were
      14      concerned.
      15
      16 Q.   I understand that.  Do you remember that we sent to
      17      Mr. Morris, and he passed on to you, a request for further
      18      information about this incident, amongst others?
      19      A.  Yes.
      20
      21 Q.   You should find that as the third document in the section
      22      which contains your statement?
      23      A.  That is correct, yes.
      24
      25 Q.   We asked you under the heading "Trade unions" on page 9,
      26      yes?
      27      A.  Yes.
      28
      29 Q.   "Please state how you know" -- this is what you put in
      30      your first statement -- "that 'the Company took this'",
      31      the McDonald's Freedom Fighters, "very seriously".
      32      Mr. Morris has noted your response which you have signed
      33      and verified as being accurate:  "I was told we had to get
      34      rid of those involved, but to do it on pretexts.  It came
      35      up at a weekly Managers meeting I attended".  Do you see
      36      those words?
      37      A.  Yes.
      38
      39 Q.   Is that a true answer to our question?
      40      A.  Absolutely true.
      41
      42 Q.   When you were a Security Co-ordinator or at most a Trainee
      43      Manager?
      44      A.  Yes.  During my time as a Security Co-ordinator, I
      45      became increasingly involved with the managerial side of
      46      the store, which is why I was asked to become a Trainee
      47      Manager.
      48
      49 Q.   Then, if you turn over the page, we asked a further
      50      question on page 10 at the top, paragraph (3) in the
      51      brackets:  "Please state (A) who told you 'to sack some of
      52      those involved under the pretext that they were (a) 
      53      disruptive influence and (b) when and where you were told
      54      this and (c) what position you held at the time."   Your
      55      answer to (a) was:  "Would have been Mark Davis and Frank
      56      Stanton".  You did not answer (b).  In answer to (c), what
      57      position you held at the time, you said:  "Second,
      58      possibly First Assistant", which indicates, does it not,
      59      by reference to your career record, that it happened
      60      either at the beginning of 1985 or in 1986?

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