Day 209 - 25 Jan 96 - Page 56


     
     1        the employee record, I suggest you steer clear of Gore and
     2        Stokes because, quite apart from the PRs, rightly or
     3        wrongly, someone has written in some pretty critical things
     4        about them on their disciplinary records.
     5
     6        So, pick one or two who have not got those critical things
     7        written in about them, and do a bit of working out as to
     8        how much they got increased over a period of time.  Then if
     9        you think it helps your argument, serve it up to me at the
    10        end of the day.  I probably will not ask you about it again
    11        because it is up to you whether you think it is productive
    12        from your point of view, but that is the kind of assistance
    13        which might help.
    14
    15   MR. MORRIS:  Yes, I will try to, if I remember.
    16
    17   MR. JUSTICE BELL:  I mean, if you do not serve it up to me, I am
    18        not going to draw any conclusion; it may be that you have
    19        not had time to do it, it may be just that you have
    20        forgotten, but that is the sort of thing you have to look
    21        at.
    22
    23   THE WITNESS:  Could I mention something?
    24
    25   Q.   If you wish.
    26        A.  We do have, when we used to fill in the cash sheets at
    27        night, we have what is called an "average rate".  That
    28        shows the average for all the crew members in the store at
    29        that time.
    30
    31   Q.   There you are.
    32        A.  And that is on every cash sheet for every year, and
    33        those cash sheets have to be kept.  So you could get the
    34        average rate for the last few years for every day.
    35
    36   Q.   Do you know how long they are kept?
    37        A.  I do not know how long cash sheets are kept for, but
    38        I assume it is several years.  It is a book that -- it is
    39        all the entries that you, you know, have for all the cash
    40        you took, so I would imagine it is at least two or three
    41        years -- probably more.  Every day -----
    42
    43   MR. MORRIS:  That is crew?
    44        A.  Every day you had to write the average crew rate, the
    45        average rate for crew.
    46
    47   Q.   Did that include people from your grade as well?
    48        A.  Yes.
    49
    50   Q.   Anyone who is hourly paid? 
    51        A.  Yes. 
    52 
    53   Q.   It would be averaged out?
    54        A.  Yes.
    55
    56   Q.   What type of average was it, do you know?  Was it add them
    57        all up and divide by the number of people or what?
    58        A.  It used to work out at about £3.40 when I was there and
    59        that was -- it was all the crew members, all the hourly
    60        paid staff, divided by the number of hourly paid staff,

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