Day 140 - 22 Jun 95 - Page 68
1 A. I also notice ----
2
3 Q. You know the Baltimore area, do you?
4 A. Yes, I do. Generally speaking, I know the Baltimore
5 area. Could you tell me when this was done?
6
7 Q. I do not know. I am going to check this out.
8 A. I do not know how I can start commenting on this thing
9 if I have no idea when it was done.
10
11 Q. If you look at the starting wage it is -- as a result of
12 the survey of many of the stores it is 4.25; so it
13 certainly indicates that it relates to after when the
14 minimum wage was increased?
15 A. I am not sure of that, sir. It could also be that they
16 plugged in some numbers and it could also be that the
17 minimum wage was a dollar less than that, and that is what
18 the stores were paying.
19
20 Q. Just by coincidence, all the stores happened to be
21 paying----
22 A. I look at that as somebody plugged in some numbers,
23 frankly. But if you will take a look at our data, we are
24 running at usually above the minimum wage. So I do not
25 know what we have in front of us. I also notice that this
26 document does not come from the group you mentioned. At
27 the top it says it comes from PUP which is in Philadelphia
28 which is 150/160 miles away from the area it purports to
29 cover.
30
31 Q. Yes. I got sent this about three days ago and I disclosed
32 it immediately.
33 A. I also ----
34
35 Q. If you note the conclusions of this -- you saw this
36 document, did you?
37 A. I have seen it prior to today, yes; only because you
38 handed it to the court. So I saw it yesterday, the day
39 before. I cannot recall when.
40
41 Q. But ----
42 A. Could I -- you drew my attention to a certain
43 paragraph and I do not know if that means you expect me to
44 adopt it or not. But I just want to make reference to the
45 same inadequacies of the PUP survey, and that is a claim
46 they spoke with the Manager. What manager is the Manager
47 who has salary data? If you recall correctly, we have
48 varying starting rates in the stores based upon
49 experience. It appears they are asking for one rate and
50 also appears that here, if the Manager did not give it to
51 him, they sent someone in. Was that someone with a lot of
52 experience or very little experience? How do I interpret
53 this thing?
54
55 Q. Yes. If you look at the conclusions -- this is the second
56 paragraph -- "Of the 32 restaurants contacted for this
57 survey" ----
58 A. Where are you reading from, please?
59
60 Q. The first page. "Of the 32 restaurants contacted for this
