Day 140 - 22 Jun 95 - Page 43
1 on Towers Perrin Foster & Crosby, but an attack on behalf
2 of what McDonald's produced as a summary from the Towers
3 report. But there we are. You put it fair and square, and
4 you have Mr. Stein's answer to it.
5
6 MR. MORRIS: Mr. Stein, McDonald's extracted summary which was
7 allegedly based on the unavailable survey, in your third
8 paragraph in your summary, page 1472 ---
9 A. Third paragraph, yes.
10
11 Q. Yes -- "TPF & C's research indicated" -- it did not say
12 "found" -- "indicated that the average differential
13 between city" -----
14
15 MR. JUSTICE BELL: Are you suggesting there is -----
16
17 MR. MORRIS: There is a slight difference.
18
19 MR. JUSTICE BELL: Where?
20
21 MR. MORRIS: Indication can be what the person reading it has
22 concluded, rather than the person who actually did the
23 actual study.
24
25 MR. JUSTICE BELL: I interpreted it as meaning "showed".
26
27 MR. MORRIS: "....indicated that the average differential between
28 city and suburban starting wage rates for McDonald's
29 restaurants included in the PUP survey is actually 11
30 cents." That does not say "was", does it?
31 A. You have to go back to the time period that they were
32 using. They were trying to mirror what they thought the
33 time period was that PUP had used, and they are trying to
34 emphatically say there that when matching up apples to
35 apples, this is what it is.
36
37 Q. There is nothing anywhere, is there -- can you find
38 anything in your executive, whatever you call it, in your
39 statement here, this document, that says that period
40 surveyed was, in fact, something that was
41 pre-November 1989?
42 A. The document speaks for itself.
43
44 Q. You cannot find anything in there, then?
45 A. You want me to start reading the entire thing and
46 wasting even more time than we have wasted since we have
47 come back from lunch?
48
49 MR. JUSTICE BELL: I am sorry, Mr. Stein, but I have to say
50 I find it unattractive when you make comments like that.
51 You may be subject to all sorts of frustrations, but you
52 just have to grin and bear it. For better or worse, the
53 Corporation of which you are an executive started this
54 litigation. If it wants to see it through, it must do so
55 with forbearance.
56 A. Yes, my Lord.
57
58 MR. MORRIS: As Ms. Steel pointed out, the second to last
59 paragraph: "Commissioned an independent survey of starting
60 wage rates at Philadelphia McDonald's restaurants in May."
