Day 208 - 24 Jan 96 - Page 44
1 I have done it four or five times today already -- so that
2 Mr. Morris does not let the matter go unheeded. Do not let
3 us argue about it now. Move on to another matter of
4 cross-examination with Mr. Cox, if you have it.
5
6 MR. MORRIS: Yes, it is just the last question on this subject.
7 You did say: "At the time the attitude of a lot of Floor
8 Managers when I was a crew person was to get the breaks out
9 of the way", I think it says, "as soon as possible and, if
10 possible, talk the individual into taking less of a
11 break". Do you think that is a responsible attitude? Did
12 that upset you at the time, that that was the attitude of a
13 lot of Floor Managers when you were a crew person?
14 A. It did not upset me. I did not consider it to be a
15 responsible attitude, though, and I do not think that you
16 would find many of the salaried Managers take it to be a
17 responsible attitude either.
18
19 Q. Why is it important that the store is adequately staffed?
20 A. It is important for a number of reasons, first and
21 foremost, health and safety.
22
23 Q. Of what? Of employees?
24 A. Of the employees ---
25
26 Q. And the customer?
27 A. -- and the customers and, secondly, to ensure a good
28 service so far as possible.
29
30 Q. OK. You have said in your statement paragraph 10: "I
31 would estimate that at least 90 per cent of the time the
32 restaurant is adequately staffed". So, would you say about
33 10 per cent of the time the restaurant is not adequately
34 staffed?
35 A. Sorry?
36
37 MR. JUSTICE BELL: Refer him to the part.
38
39 MR. MORRIS: In paragraph 10. You said in paragraph 10, towards
40 the bottom, you are contrasting the next sentence which
41 is: "I completely disagree with Mike's comment that one in
42 three shifts are inadequately staffed". Would you say nine
43 out of 10 adequately staffed would be a more realistic
44 view?
45 A. I would say it would be more realistic as in the
46 statement "because of the reasons above". It is not down
47 to the schedule in almost every single case.
48
49 Q. Right. So about one in 10 are inadequately staffed and
50 that would be because there are low shows or lateness or
51 sickness or something like that?
52 A. Yes, or it could possibly be a turnover point with the
53 students.
54
55 Q. OK.
56
57 MS. STEEL: Sorry, so if it is a turnover point with the
58 students, that is something that would go on over a number
59 of days after the students have left?
60 A. Any times where you get a students' turnover period, it
