Day 124 - 10 May 95 - Page 46
1 Q. Do you know if it is 10 per cent, 20 per cent?
2 A. I doubt it would be that high, no. No, it would be
3 smaller than that. My guesstimate would be that it would
4 be less than 10 per cent, a smaller per cent.
5
6 Q. Somewhere between 5 and 10 per cent?
7 A. It could even be less than that. It is not
8 significant, but there is a percentage of business that
9 does go out the door.
10
11 MR. JUSTICE BELL: While Mr. Morris is thinking, is it unusual
12 then in the States, or not very typical, for someone to
13 come in, buy at the counter, and walk out of the restaurant
14 but not into a car, just wander off into the street with
15 their ---
16 A. That does -----
17
18 Q. -- package food?
19 A. Yes. My Lord, it depends upon the location of
20 restaurant. Some of our restaurants are located on the
21 periphery of residential areas where there are apartment
22 buildings, condominiums, directly behind or adjacent to our
23 facility.
24
25 Q. Or there is a park?
26 A. A park. You would have more walk-away trade.
27
28 Q. It depends where you are?
29 A. Exactly.
30
31 MS. STEEL: I do not know whether you have a copy of your
32 statement to hand, I think it is in yellow bundle 1. It
33 should be tab 2, I think, or it might be tab 3. I am not
34 sure what tab it is.
35
36 MR. JUSTICE BELL: They are at tabs 1, 2 and 3, but 3 is a very
37 short statement of one page. The main statement is tab 2.
38 Tab 3 is the short statement saying: "Shortly why
39 McDonald's brought the suit", and secondly Ray Kroc and
40 environment/index.html">litter.
41
42 MS. STEEL: It is the first statement that I wanted to ask
43 about. In paragraph 6 you said "As" -- it is about
44 halfway through the paragraph, in fact possibly two-thirds
45 of the way through --
46
47 "As an area supervisor I had direct responsibility for
48 seven company restaurants and my job to ensure these
49 restaurants met their sales and profit goals, were properly
50 staffed, efficiently run, and that the crew members and
51 management team were being trained properly and were
52 content". Can you just explain how you did that, how you
53 carried all that out?
54 A. As a supervisor, basically I worked with the store
55 management in making sure that the restaurants were staffed
56 appropriately for the anticipated volume of business, and,
57 on numerous occasions, I would spend time in the restaurant
58 with members of management, observe the training of crew
59 people, sometimes participate in that training, on occasion
60 I would sit in on crew meetings, or participate in crew
