Day 188 - 15 Nov 95 - Page 34
1 A. Yes.
2
3 Q. Do you stand by it?
4 A. Yes.
5
6 Q. There were just a few points in the notes that I was going
7 to refer to, ask you about. If you can go to page 10,
8 please, of the notes, in the first paragraph on that page,
9 it is talking about buns, at two in the morning, being left
10 in the lobby throughout the night until the cleaning is
11 almost finished. Is that something you witnessed?
12 A. Yes.
13
14 Q. Further on down that page, in the fourth paragraph, the
15 third line, you say: "The kitchen is indescribable chaos.
16 The floor is sopping wet with fat and water, a lethal
17 mixture if crew members stepped into it, to be about.
18 There are vague attempts to mop the floor from time to
19 time, but it is wasted energy and not taken seriously,
20 because the floor would swiftly become a mess again."
21
22 Is that something you witnessed?
23 A. Yes.
24
25 Q. Then, in the next paragraph, the second line: "David has
26 finished cleaning out the fryer. He pushes it back into
27 place, a tight fit between the serving section and the
28 wall. He has to edge the frier into this tight fit.
29 Unlike Henry, has no protective clothing other than long
30 rubber gloves."
31
32 Was that something that you witnessed?
33 A. Yes.
34
35 Q. "The fat, which is still smoking hot, slops over the edges
36 of the vat. It would take only the smallest jerk for it to
37 slop over David. His groin is just about where the fat
38 would slop. The whole process of filtering and cleaning
39 the vat is unbelievably risky."
40
41 Is that all your observations?
42 A. Yes.
43
44 Q. Then, at the end of that paragraph, you say: "The floor is
45 treacherous. One slip could lead to hot oil spraying over
46 the whole work area."
47
48 Is that something you witnessed; yes?
49 A. Well, I witnessed that the floor was treacherous.
50 I never saw oil spraying over the whole work area.
51
52 Q. Fair enough. That was -- you mean there about the fat
53 filtering?
54 A. That was the process of changing the fat in the vats,
55 yes.
56
57 Q. Changing the fat in the vats, OK. I will move over the
58 page. In the second paragraph, you talk about:
59
60 "The two girls and Perez had finished their jobs on the
