Day 169 - 04 Oct 95 - Page 41


     
     1   Q.   So you did something like 20 to 30 full field audits?
     2        A.  No, if I had eight stores -- well, yes, yes.
     3
     4   MR. JUSTICE BELL:  16 to 28 if you stuck strictly to it?
     5
     6   MR. MORRIS:  Plus any extra ones for stores that were having a
     7        problem?
     8        A.  Yes.
     9
    10   Q.   You have not got copies of any of the documents from that
    11        time, have you, or you did not check any of the documents
    12        from that time before you wrote?
    13        A.  I have not got any copies of the documents from that
    14        time.
    15
    16   Q.   Relating to that store?  Can you remember the names of
    17        anybody that worked at that store, crew members, between
    18        June 1984 and July 1985?
    19        A.  I probably cannot remember any of their surnames.  I
    20        would probably remember some of their Christian names, but
    21        not necessarily their surnames.  I remember a girl called
    22        Sophie.  I think, at that point in time she was actually
    23        the Floor Manager.  She had just been promoted.  There was
    24        an Admin Assistant called Mark Pearson.  I cannot remember
    25        any other specific names at this point in time.
    26
    27   Q.   Are you sure though that they worked there between June
    28        1984 and July 1985, are you?
    29        A.  Yes.
    30
    31   Q.   But you cannot remember any crew?
    32        A.  Well, like I said, I can remember maybe some of their
    33        first names, but I would not be able to remember their
    34        surnames anyway.
    35
    36   MR. JUSTICE BELL:  Can you remember the name of the Store
    37        Manager during that year which was Mr. Cranna's year?
    38        A.  Robert O'Malley, as far as I recall, was Store Manager
    39        at that point in time.  James Graham may have been there
    40        slightly before that.
    41
    42   MR. MORRIS:  James Graham?
    43        A.  Yes.
    44
    45   MR. JUSTICE BELL:  Do you want -- I hesitate to interrupt early
    46        in your cross-examination -- to pursue what has happened,
    47        for instance, to O'Malley or whether he stayed in
    48        McDonald's and went on up or whether he left, that sort of
    49        thing, if indeed the witness knows?
    50 
    51   MR. MORRIS:  Not really. 
    52 
    53   MR. JUSTICE BELL:  The only reason I say it -- there is no harm
    54        in saying it in Mrs. French's presence -- is if at the end
    55        of the day I accept the evidence of some of your witnesses
    56        with regard to particular stores, not saying that I will
    57        but if I do, at the end of the day, if I prefer their
    58        evidence to any contrary evidence, the next question may be
    59        whether they were just things which happened to happen in
    60        that store or whether I can treat them as some kind of

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