Day 133 - 12 Jun 95 - Page 50
1 Q. Do you know of any industry that has average earnings less
2 than catering or retail wage rates?
3 A. I do not know about other sectors, no, I do not have
4 any information on that.
5
6 MR. MORRIS: Can I just sit down?
7
8 MR. JUSTICE BELL: Yes. Quite frankly, if I were you, you have
9 some information here, Ms. Mead cannot speak to more than
10 is on the page, she cannot give any original. It is
11 entirely a matter for you, but I would leave your rates of
12 pay there. Do a bit of looking to see whether the New
13 Earnings Survey helps you. It has, for instance, average
14 manual wages which includes absolutely everything, manual
15 male, manual female, non-manual male, non-manual female.
16 It is a mine of information. Since it has been introduced,
17 see what, if anything, you can get out of it, but if you
18 can get a back copy which is the relevant -- they are
19 relevant years -- which is the particular year when you can
20 say someone reading this leaflet which is written in the
21 present tense, so far as this is concerned, this section of
22 the case is concerned, would be looking at what the wages
23 were in the year up to April 1990 and then work on that
24 basis.
25
26 MR. RAMPTON: My Lord, while Mr. Morris gathers himself, I would
27 like to take up a completely false point which Ms. Steel
28 made which, in answering, I would like to do it now in
29 fairness to the witness. She seemed to assert that there
30 had been, as she often does, some deliberate concealment of
31 documents.
32
33 Your Lordship will remember that in Ms. Mead's statement
34 she gave figures for turnover in 1989 and for the present
35 time, which is in 1993, when she made her statement. That
36 was paragraph 17 of the statement. The request for
37 discovery to which Ms. Steel just now referred was this
38 under paragraph 17: "Of the 191 per cent turnover rate in
39 1989, any documents relating to the percentage of leavers
40 re-employed within a year". When Mrs. Brinley-Codd swore
41 her affidavit she said in answer to that request: "There
42 are no documents."
43
44 MS. STEEL: Can I just point out, I am getting the blame for
45 that, I did not even mention it but ......
46
47 MR. RAMPTON: An apology both to Ms. Mead and to
48 Mrs. Brinley-Codd might be appropriate.
49
50 MR. JUSTICE BELL: What are you saying that Ms. Steel said?
51
52 MR. RAMPTON: She appeared to suggest that a request for general
53 discovery of turnover figures had been made in relation to
54 that paragraph of Ms. Mead's statement. It is not so.
55 What was asked for -----
56
57 MR. JUSTICE BELL: Paragraph 17?
58
59 MR. RAMPTON: Yes.
60
