Day 122 - 05 May 95 - Page 62


     
     1        suggested by one of the Defendants -- I forget which,
     2        perhaps both -- that the Company tries to save money, in
     3        effect, by stifling promotion amongst certain lower ranked
     4        employees, yes?  Do you remember that suggestion?
     5        A.  Yes, I do.
     6
     7   Q.   That in order to save money, for example, it would
     8        habitually or systematically try to ensure that shifts were
     9        managed by some lowly, hourly paid worker as opposed to a
    10        manager or a first assistant, somebody like that; do you
    11        remember that suggestion?
    12        A.  I do.
    13
    14   Q.   Not needing to get out the document, you told us that the
    15        salaried positions begin with Junior Business Manager above
    16        Floor Manager who is the highest ranked of the hourly paid
    17        workers; is that right?
    18        A.  That is correct.
    19
    20   Q.   Below the Floor Manager there is a Lobby Host or Hostess,
    21        there is the Training Squad, the Night Closer and the
    22        Security Co-ordinator and below them the ordinary crew
    23        person?
    24        A.  That is correct.
    25
    26   Q.   Amongst those hourly paid workers which is permitted to
    27        manage a shift?
    28        A.  An accredited Floor Manager, that is one who has been
    29        through his Floor Manager's course, he is permitted to run
    30        a shift.
    31
    32   Q.   Above those, I think you told us, you first of all said
    33        Trainee Management then I think you corrected yourself?
    34        A.  Junior Business Managers now.
    35
    36   Q.   Would a Junior Business Manager be allowed to run a shift?
    37        A.  I do not know, perhaps after a certain time.  No,
    38        I think a Junior Business Manager would probably after he
    39        had passed his basic Operations course be allowed to run a
    40        shift, yes.
    41
    42   Q.   He is a salaried employee?
    43        A.  He is salaried employee.
    44
    45   Q.   You told us, I think, having first said that he might, you
    46        then said that you thought that was a mistake, that the
    47        Trainee Manager probably would not be allowed to run a
    48        shift?
    49        A.  That is what I believe.  I could be wrong on that, but
    50        I think it would be left to the judgment of the Restaurant 
    51        Manager as to whether a Trainee Manager was sufficiently 
    52        well trained to be able to run a shift, but it would be 
    53        unusual, I would have thought.
    54
    55   Q.   Above that the Second Assistant, First Assistant and then
    56        the Manager himself?
    57        A.  Yes.
    58
    59   Q.   They, I assume, all would be -----
    60        A.  They all run shifts.

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