Day 195 - 04 Dec 95 - Page 68
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2 Q. So the problem was one of the system rather than
3 individual?
4
5 MR. JUSTICE BELL: Let the witness give the evidence.
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7 MR. MORRIS: OK. Finally -- Ms. Steel has some questions but
8 I will finish mine off first -- can you remember, you said
9 all night closes were sometimes as many as two in a month
10 or something?
11 A. Yes.
12
13 Q. Do you remember roughly how many you might have done in,
14 say you were there for two years, I am talking about all
15 night closes?
16 A. Yes.
17
18 Q. Just roughly some kind of figure, how many, say, in a year,
19 how many all night closes would you do?
20 A. I think all night closes I have to include an
21 explanation there, because the all night closes are usually
22 done by people who, first of all, have got some
23 experience. Secondly, they are recognised by the
24 management to have that experience and also they are, they
25 have got -- how can I put it -- the management regard them
26 as good material for doing all night closes, OK. So what
27 happens is that until I was actually in this position, in
28 the position to do all night closes, I was experienced,
29 I was not doing many, say, in the first year, right, or the
30 first nine months of my employment at McDonald's. But it
31 does not mean that all night closes did not happen. I was
32 not on every all night close. So what I am saying is that
33 there were all night closes that I did not take part in
34 for, you know, different reasons. You were not always, the
35 people who did all night closes were not always the same
36 group of people who did all night closes, but they happened
37 very regularly.
38
39 Q. Let us just take the last year. Just give us some kind of
40 figure. You are saying sometimes of the year you might
41 have done as many as three or four in a couple of months?
42 A. Yes.
43
44 Q. And at other times did none happen at all for three or four
45 months? Give us some general figure for the whole year.
46 Would you have done five, 10 or 15 or what? If you cannot
47 say just do not say.
48 A. No, I genuinely cannot remember. I mean, as far as
49 I can say, all I can say is that it seemed to me very many,
50 but I could not tell you what I meant by "very many".
51
52 Q. You did not do all the ones that were happening?
53 A. No. I did not, by no means I did. The case in point
54 is where Tracey Millain, for example, did a 16-hour shift,
55 I was not on that all night close; she did that all night
56 close and others. So I was not on every all night close,
57 no.
58
59 Q. In this period of time which we have got, just to clarify
60 the question of the accident that you had, you said that
