Day 134 - 13 Jun 95 - Page 17


     
     1   Q.   -- from your own knowledge and recollection?
     2
     3   MR. RAMPTON:  Yes, my Lord, I observe as the final link in that
     4        process that the annualised turnover for that quarter of
     5        1994 was 116 and a half, roughly speaking, as opposed to
     6        121.
     7
     8   MR. JUSTICE BELL:  Yes.  So, when the turnover was pretty well
     9        the same, the percentages were pretty well the same.
    10        I really think, Mr. Morris, it may be a matter of comment
    11        now if Ms. Mead cannot help.  What is suggested, if the
    12        turnover was significantly greater back in 1990, then the
    13        percentages of short serving people are likely to have been
    14        significantly greater as well.  That is the point which is
    15        being put to you.  Can you help us?
    16        A.  No, I do not believe I can.
    17
    18   MR. MORRIS:  OK, so if these figures are constant over a year,
    19        have been approximately constant over a year, broadly
    20        speaking, for the last year anyway -- in fact, for the last
    21        couple of years -- then it is a pretty reliable indicator
    22        of how long people are staying in the Company?
    23        A.  Yes.
    24
    25   Q.   Can we safely say that, for example, if 22 per cent stay
    26        between three and six months, just as a rough calculation,
    27        we can approximate that means 22 per cent stay
    28        approximately four and a half months, something like that?
    29        A.  Yes.
    30
    31   Q.   Somewhere in the middle.  Maybe the top figures might be a
    32        bit more difficult because between five and 10 years, 6 per
    33        cent, it may be nearer five years than 10 years?
    34        A.  It may be, but it may be nearer 10 than five.  I do not
    35        know.  Obviously, we do not know from these figures.
    36
    37   Q.   Can we just assume, anyway certainly for the lower figures,
    38        say, between 0 and one month a couple of weeks might be a
    39        good average to base that on, yes?
    40
    41   MR. JUSTICE BELL:  I really do not think you can ask.  Ms. Mead
    42        cannot say.  You can ask me to assume it later, if you
    43        want.
    44
    45   MR. MORRIS:  There is no reason ---
    46
    47   MR. JUSTICE BELL:  The whole case is decided on balance of
    48        probability.
    49
    50   MR. MORRIS:  -- to assume that, on balance of probabilities, 
    51        that people who stay between 0 and one month stay for a 
    52        couple of weeks -- I know it does not apply to every person 
    53        but ------
    54
    55   MR. JUSTICE BELL:  Can you help us on that?
    56        A.  I do not know.  I do not know why you need to make an
    57        assumption when there are figures that give a period -----
    58
    59   MR. MORRIS:  Because we are trying to make calculations based on
    60        figures.  We have to some kind of working method of doing

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