Day 193 - 28 Nov 95 - Page 06


     
     1
     2   Q.   They did not use it in the proceedings, did they?
     3        A.  I do not know.  I was not present at the proceedings.
     4
     5   Q.   I am now going to go through with you, if I may, some of
     6        the things which I would suggest you said to people when
     7        you recruited them, when you got them to sign cards; and
     8        I am going to give you the names and then I am going to
     9        suggest to you what form the conversation took; and where
    10        I can, I will give you a date.  Do you remember recruiting
    11        Lee Wilson?
    12        A.  I believe her name is Leah Wilson.
    13
    14   Q.   Sorry.  That is a girl, is it?
    15        A.  Yes.
    16
    17   Q.   Do you remember that it was about 8 o'clock in the evening
    18        in late August?
    19        A.  Yes.
    20
    21   Q.   Do you remember that you told her that she would have
    22        guaranteed job security and a wage increase every year?
    23        A.  No.  I guaranteed her job security and I told her that
    24        we would be able to negotiate wages at the store.
    25
    26   Q.   Do you remember saying to her that if she was a member of
    27        the union she would be able to tell off the managers when
    28        she wanted?
    29        A.  No, I did not say that.
    30
    31   Q.   Do you remember she said that she wanted to talk it over
    32        with her parents?
    33        A.  No, I do not remember, but she may have.
    34
    35   Q.   You do not, therefore, remember replying: "That is not
    36        necessary.  Go ahead" -----
    37        A.  No.  Whenever anyone asked me if -- because I told
    38        them, I said, whenever I signed someone up, that, you know,
    39        I wanted this a secret.  Some of them did ask me if they
    40        could speak to the parents.  "That is fine, speak to your
    41        parents, whatever, but what cannot happen is to have people
    42        talking about the union at work" -- because, obviously, we
    43        did not want management to find out right then and there.
    44
    45   Q.   Do you remember recruiting Sean Heggie?
    46
    47   MR. JUSTICE BELL:   Mr. Rampton, if a point is going to be taken
    48        on this under 18 argument, one way or the other, I think it
    49        would help me to know how old the various people mentioned
    50        are, because there might be a very considerable difference 
    51        in my mind between a 15-year-old and a 17-year-old, for 
    52        instance. 
    53
    54   MR. RAMPTON:  I quite agree.  But, my Lord, I cannot give you
    55        your Lordship -----
    56
    57   MR. JUSTICE BELL:  It may be that a witness will know.
    58        Otherwise, I just have to ask at the end, myself.
    59
    60   MR. RAMPTON:  My Lord, I will ask for each one, if the witness

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