Day 209 - 25 Jan 96 - Page 57


     
     1        really, the amount they earned divided by how many hours,
     2        whatever.  I am trying to think now how we used do it.  It
     3        is a very simple calculation, but the actual -- that amount
     4        is on every single cash sheet.  It is written on every
     5        single cash sheet because it is a track of how much people
     6        are earning.
     7
     8   Q.   Right.
     9        A.  The average rate in our store, I remember, for the last
    10        year I was there, on the closes I did, which was probably
    11        one or two a week, it did not -- I do not remember it going
    12        up.  It was always a relatively constant thing, but that
    13        information is very easily obtained, I think, just from
    14        looking at the cash sheets.
    15
    16   Q.   I was not aware that document existed.  Maybe that could be
    17        a formal application that would save -----
    18
    19   MR. JUSTICE BELL:  What I suggest you do -- do not make an
    20        informal formal application now -- is you go home and think
    21        about it.  Think about some specimen times and restaurants
    22        and then you can raise the matter.  I can see what, if
    23        anything, Mr. Rampton has to say about it and what, if any,
    24        further discovery of documentation, if available, are
    25        there.  But what we cannot have that is quite apparent is
    26        discovery of, if they are available, all the cash sheets of
    27        all the restaurants since 1985 or something.  So, I want
    28        you to go away, like you did, do you remember, when we were
    29        considering Bath documents anyway ---
    30
    31   MR. MORRIS:  Yes.
    32
    33   MR. JUSTICE BELL:  -- and suggest what a reasonable approach to
    34        that would be.  Make a note of it.
    35
    36   MR. MORRIS:  Yes.  (To the witness):  Just brief questions about
    37        the audit.  We have actually been through them; we do not
    38        need to go through them again.  How seriously were audits
    39        taken or have you any comments about store audits -- we
    40        have a number of documents here which you have looked at --
    41        in general?
    42        A.  I would say that the ones done from Head Office were a
    43        fairly serious thing, but I do believe you had notification
    44        of when they were going to happen, or you certainly had
    45        some indication, or the Store Manager was giving a sly
    46        phone call, because we seemed to -- suddenly everything
    47        seemed to get moving and then we would have a store audit.
    48        But in-store audits were, I do not know, they were, you
    49        know, they were -- I would not say not taken seriously, but
    50        they were not as serious as out of store audits, the ones 
    51        done by Head Office.  You have got a -- where is it, the 
    52        first audit in here on page 159 --- 
    53
    54   Q.   This is in tab 9?
    55        A.  -- tab 9, was done by Rianna Easton.  She was a -- she
    56        is a Floor Manager so .....
    57
    58   MR. JUSTICE BELL:  Which page is that?
    59        A.  159, tab 9.
    60

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