Day 134 - 13 Jun 95 - Page 19


     
     1        three percentages, 16 per cent -- because of the weighting
     2        of those percentages I have averaged that out about one
     3        month,  about 16 per cent stay one month -----
     4
     5   MR. JUSTICE BELL:  I do not see how you get that, quite frankly.
     6
     7   MR. RAMPTON:  I do believe this is a completely valueless
     8        exercise.
     9
    10   MR. MORRIS:  It is not at all.
    11
    12   MR. RAMPTON:  If Mr. Morris wants to make a speech about this at
    13        the end of the case or sometime at the end of this year or
    14        the beginning of next, let him do so.  This is a witness
    15        who has a job to do.  She is a busy person.  She should not
    16        be stood there while Mr. Morris makes wild assumptions
    17        about what these figures mean.
    18
    19   MR. MORRIS:  I am not making any wild assumptions.
    20
    21   MR. JUSTICE BELL:  Just listen to me.  I do not want you to say
    22        what this means to you now.  You can say what it means to
    23        you when you are commenting at the end of the case and
    24        I will either accept it or reject or accept it in part and
    25        reject it in part -- just listen -- Ms. Mead is in the
    26        witness box.  You are to ask her questions.  If she says:
    27        "I cannot help you", in effect, as she has said about
    28        this, "from my own experience", you must move on to
    29        something else.
    30
    31   MR. MORRIS:  All right.  From my calculations on that first
    32        column, it represents a turnover of 272 per cent a year.
    33        The second column represents a turnover of 440 per cent.
    34        That is the previous quarter to that one.  I did not work
    35        out the previous one.  I will be submitting -- I just
    36        thought I would give you the opportunity -- that the
    37        turnover rate is in fact even higher -----
    38
    39   MR. JUSTICE BELL:  Stop.  Put it as a question.
    40
    41   MR. MORRIS (To the witness):  That these figures which are a
    42        reliable indicator, as you have said, on adducing turnover
    43        and length of stay of staff represents a turnover rate of
    44        the first quarter of 272 per cent, or thereabouts, and 440
    45        per cent for the previous quarter.  Have you made that
    46        calculation?  Have you tried to make that calculation to
    47        understand these figures?
    48        A.  No, certainly not.  I have no idea what you are
    49        referring to.
    50 
    51   Q.   You can calculate, I mean, anyone can do that -- I am sure 
    52        everyone will. 
    53
    54   MR. JUSTICE BELL:  Then calculate it in due course.
    55        A.  I do not think you can calculate it from what you are
    56        saying.
    57
    58   MR. JUSTICE BELL:  I do not follow at the moment how you come to
    59        that.
    60

Prev Next Index