Day 149 - 06 Jul 95 - Page 27


     
     1        important a question, is:  what useful basis would that
     2        provide your Lordship with for drawing any general
     3        conclusions about the length of time that people in the
     4        United States work for McDonald's, so that your Lordship
     5        might be able to arrive at a similar sort of factual
     6        conclusion as is shown by the documents which are available
     7        in this country for the whole country, and which Mrs. Mead
     8        brought to court with her?
     9
    10        My Lord, I would heavily resist being asked to do it, if it
    11        was any sort of trouble, because, as I say, I do not
    12        believe that the eventual result would be worth the
    13        effort.  I do question what value it would have, even if it
    14        were easy to do and it were confined to the group of
    15        Company stores in, let us say, Chicago.
    16
    17   MR. JUSTICE BELL:  Can I add to that, that if I saw some appeal
    18        in your argument, one is then left with one sheet of paper
    19        with several columns for years.  If I recall correctly, it
    20        has months down the left-hand column, it has the years
    21        along the top, and it has percentages in between, and it is
    22        one sheet of paper.  Heaven knows whether anyone can rely
    23        on that in any way at all, one way or the other.
    24
    25   MR. RAMPTON:  I quite agree.  That might be one of the section 5
    26        documents at the end of the case, which is very likely the
    27        product of a combination of people acting under a duty and
    28        a computer.  I can probably prove those figures without
    29        having to resort to any underlining material at all.
    30
    31        My Lord, I was not on turnover figures; I was on
    32        Mr. Morris' different request.  Remember, Mrs. Mead
    33        produced a computer printout showing, by periods of time,
    34        what numbers and percentages of people had worked for those
    35        periods of time.  There were some that had worked 0 months
    36        (which seemed odd) and then there were others who worked
    37        one to three, and three to six, and so on and so forth.
    38
    39   MR. JUSTICE BELL:  Yes.  I am sorry.  The point was also
    40        taken  -----
    41
    42   MR. RAMPTON:  Yes, my Lord, I was coming to that.
    43
    44   MR. JUSTICE BELL:  But that is separate point.
    45
    46   MR. RAMPTON:  It is a separate point.  I have taken them in
    47        strict chronological order.
    48
    49   MR. JUSTICE BELL:  No.  You are quite right.  That is the next
    50        point but one. 
    51 
    52   MR. RAMPTON:  What Mr. Morris is wanting to know is how does the 
    53        breakdown of length of service work for a group of Chicago
    54        stores.  Even assuming that information were readily
    55        available (which one may doubt), I do ask what conceivable
    56        value or real value it would have for the purposes of this
    57        case.  Suppose you found a certain happening in Chicago, it
    58        would be impossible, we would submit, to infer that that
    59        happening was reproducible for the United States as a
    60        whole.

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