Day 140 - 22 Jun 95 - Page 57


     
     1        differential between the city and suburbs in Philadelphia
     2        at this time, whether it was 11 cents, 22 cents, or 87
     3        cents, or $1.10c, would be based on availability of labour
     4        and market conditions?
     5        A.  It would be based on the survey data.
     6
     7   Q.   No, I mean the reason?
     8
     9   MR. JUSTICE BELL:  If there was a difference, would that arise,
    10        as Mr. Morris is suggesting, from availability of labour
    11        and market conditions or for some other reason?
    12        A.  It could be a variety of different reasons, my Lord.
    13
    14   MR. MORRIS:  If we look on 91, it is page 1464 in tab 91, this
    15        is a letter by Stephen Brown, System Vice President Labour
    16        Relations, who I believe is in the court at the moment, on
    17        July 3rd, 1991.  At the top of page 2 of that letter, which
    18        he wrote on behalf of Mr. Quinlan, or Mr. Quinlan asked him
    19        to respond, he says midway through that
    20        paragraph: "Contrary to PUP's claim the average wage paid
    21        to the surveyed restaurants differed by just 11 cents per
    22        hour based on availability of labour and market
    23        conditions".  Would you accept that is the Corporation's
    24        position?
    25        A.  That is Mr. Brown's point of view.  It could also be
    26        based upon such things as workers who go from the city to
    27        the suburbs, have to pay for car fare, if you will, train.
    28        There are a variety of different factors that come into
    29        play in an owner/operator determining what his or her pay
    30        should be.  You are asking me to read some conclusions and
    31        some very hypothetical situations.  Each owner/operator has
    32        to figure it out for himself or herself.
    33
    34   MS. STEEL:  Just to clarify, this is the letter that is the
    35        reply to the one I asked you about just a moment ago, and
    36        presumably you asked Mr. Brown to reply to this letter?
    37        A.  It looks like it may be. I ----
    38
    39
    40   Q.   In fact, the letter on the previous page has now got
    41        "Steve" written at the top?
    42        A.  Yes, but that is not my handwriting, so what often at
    43        times happens, if you will notice that my name is at the
    44        top right and then somebody else, my secretary or someone
    45        else, appears to have written "Steve" on it because that is
    46        not my handwriting.
    47
    48   MR. JUSTICE BELL:  It looks as if it could well be the response?
    49        A.  Yes.  I do not dispute that, my Lord.
    50 
    51   MS. STEEL:  Mr. Brown would have been under you at that time? 
    52        A.  Yes. 
    53
    54   Q.   Presumably you thought he was capable of doing his job?
    55        A.  I think he is a capable person, yes.
    56
    57   Q.   There is just one other thing I wanted to ask about this
    58        letter.  At the bottom of page 2 going over on to page 3
    59        there is a list of various what you might call charitable
    60        activities there.  Is that a frequent tactic of McDonald's

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