Day 193 - 28 Nov 95 - Page 14


     
     1   Q.   What is the basis for that allegation?
     2        A.  The basis is that before management knew anything about
     3        the union, no one intimidated.  When management found out
     4        about the union, people all of a sudden, apparently, from
     5        those letters, did not want any part of it any more.
     6
     7   Q.   Who do you mean by "management"?
     8        A.  The entire management staff.
     9
    10   Q.   Sorry?
    11        A.  All the management at the store.
    12
    13   Q.   When do you say all the management at the store knew about
    14        the unionisation?
    15        A.  I am not saying at that particular stage, but
    16        management, as in Rob Pinkney, Cam Ballantyne.  I am sure
    17        Patty Galbraith knew about it at that point.  I knew Travis
    18        had known about the union, because I told him.  Swing
    19        management knew, as well.
    20
    21   Q.   Let me be quite clear about this.  Are you asserting that
    22        Cam Ballantyne knew about the organisation attempt before
    23        the weekend of 2nd/3rd October, 1993?
    24        A.  Before the weekend?
    25
    26   Q.   Yes.  That is when the petition was got up.  It was handed
    27        in to the Board on -----
    28        A.  I do not know the exact date that he found out about
    29        it, but I imagine that he found out about it around that
    30        time.
    31
    32   Q.   You have no evidence at all, do you, for what you have
    33        written in this paragraph?  It is sheer speculation, is it
    34        not?
    35        A.  (Pause)  No.  Well, I do not know what -- I do not know
    36        these legal terms.
    37
    38   Q.   You are guessing?
    39        A.  No, I am not guessing.
    40
    41   Q.   You would like to think it was true, but you have no proof?
    42        A.  I know it is true, because people have told me that
    43        this is what they were telephoned and told.
    44
    45   Q.   Who told you that?
    46        A.  Day staff told me about it.
    47
    48   Q.   What do you mean by day staff?
    49        A.  The employees that worked during the day.
    50 
    51   Q.   Any crew member who works during the day is day staff, is 
    52        it? 
    53        A.  That is what we referred to them, yes.
    54
    55   Q.   And the day staff told you they knew about this, did they?
    56        A.  Yes.
    57
    58   Q.   Would you like to give me some names?
    59        A.  Actually, I would not, because some of them are still
    60        working there, and if they are known as pro-union they feel

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