Day 166 - 28 Sep 95 - Page 62


     
     1        various things to help deliveries.  I increased the number
     2        of deliveries that restaurant had.  I increased the size of
     3        the freezer to receive smaller deliveries more often.
     4        Certain people might be good at doing deliveries so perhaps
     5        they would do them on a regular basis.
     6
     7   Q.   Was there a delivery team who generally did that kind of
     8        job?
     9        A.  That was -- I think the intention at one point that
    10        I had of trying to get one person that would be in early in
    11        the morning and help do that, I do not remember achieving
    12        that with any specific person.
    13
    14   Q.   Right.  So when Mr. Magill says he had to do stock
    15        rotation, for example, he would not have been doing that as
    16        part of a regular team throughout his period at
    17        McDonald's?  That is just something he did from time to
    18        time?
    19        A.  On one particular day or maybe on more than one day he
    20        might have done a delivery, yes.
    21
    22   Q.   It says that it will take up two hours to do that?
    23        A.  I would be very concerned at that.
    24
    25   Q.   Stock rotation though, specifically stock rotation?
    26        A.  No.
    27
    28   MR. JUSTICE BELL:  You would be very concerned at?
    29        A.  If it took two hours to do that.
    30
    31   Q.   On either a stock rotation or a delivery?
    32        A.  That is right.
    33
    34   MR. MORRIS:  Why would you be concerned?
    35        A.  Because that is a long period of time.
    36
    37   Q.   To spend in a walk in freezer?
    38        A.  To do a delivery or to do a specific task.
    39
    40   Q.   Would you be concerned about the Company losing money
    41        because it was taking so long, or would you be concerned
    42        about the employee being in a cold environment for two
    43        hours?
    44        A.  Everything.  I mean, it is just -- I mean, I have never
    45        had anyone in a freezer for two hours.  I do not think
    46        anyone could last in a freezer for two hours.
    47
    48   Q.   Can you recall how long Nicholas Magill himself spent in
    49        the freezer when he worked in the freezer?
    50        A.  No. 
    51 
    52   Q.   You cannot recall? 
    53        A.  No.
    54
    55   Q.   OK.  Thank you.
    56
    57   MR. JUSTICE BELL:  How long do you think it would take to do a
    58        stock rotation in the freezer in Marble Arch?
    59        A.  More than one person would do it.
    60

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