Day 247 - 10 May 96 - Page 29


     
     1        put to me when you come to make your submissions and I will
     2        make of it what I will.  I really do not think asking Mr.
     3        Preston about it advances the matter at all.
     4
     5   MR. MORRIS:  Well, if you remember, we had a lot of documents
     6        served after Jill Barnes left the witness box and they
     7        included -- and I do not have them in front of me
     8        although ----
     9
    10   MR. JUSTICE BELL:  I really do not think Mr. Preston can help in
    11        the face of experts in this particular field we have had
    12        and people who are working in the field.
    13
    14   MR. MORRIS:  Right.  You did say that we could invite you to
    15        draw conclusions from the documents themselves.
    16
    17   MR. JUSTICE BELL:  You are going to refer me, or you may do,
    18        either in shorthand by saying, "Remember the comments, the
    19        matters we put in cross-examination of the Plaintiffs'
    20        witnesses on the HSE Report", or you may point to specific
    21        parts of it and then you say, "That shows they were not
    22        taking health and safety seriously".  Then when we get on
    23        to Mr. Rampton, he will put another point of view perhaps,
    24        and I will have to decide about it.
    25
    26   MR. MORRIS: It is just that the documents that we got since Miss
    27        Barnes left the witness box we were going to recall her for
    28        questioning her, and you said that that may not be
    29        necessary and we were entitled to point you to various
    30        parts of the those documents.
    31
    32   MR. JUSTICE BELL:  Yes, but you need not do it through the
    33        formula of Mr. Preston.
    34
    35   MR. MORRIS:  OK, let us leave that then.  You can leave that
    36        document then, Mr. Preston.
    37
    38   MR. JUSTICE BELL: What I will do is I will hand those back, not
    39        because I am not interested in them ultimately, but by the
    40        time you come to make any comment on it, no doubt the place
    41        in the bundle will be identified and I do not want too much
    42        loose paper around.
    43
    44   MR. MORRIS:  It should be there somewhere.
    45
    46        We have had a great deal of evidence, I am sure we do not
    47        want to go into again, about the turnover of staff at
    48        McDonald's stores which was running like something 195 per
    49        cent in December, I think it was December 1989 according to
    50        your figures, your Company figures, in the UK stores and 
    51        has been progressively brought down since then. 
    52 
    53        Was there any monitoring -- do you know, if you do not
    54        know, you do not know -- of the turnover rates before 1989?
    55        A.  There may have been.  If you want a number I could not
    56        tell you what the number was.
    57
    58   Q.   I want to know if there was any monitoring of turnover
    59        rate?
    60        A.  In the British company?

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