Day 207 - 23 Jan 96 - Page 37


     
     1
     2   THE WITNESS:   Section 5.
     3
     4   MS. STEEL:   OK.  "...for August 1993, May 1994 and August
     5        1994.  Without knowing the precise volume of business in
     6        the restaurant for each of the hours shown on the sheets
     7        I cannot say for certain that the staffing levels were
     8        always exactly what was needed to provide the required
     9        standards of service."
    10
    11        So, is that a recognition there that sometimes the stores
    12        were understaffed?
    13        A.  From looking at the crew in store each hour, that would
    14        give you a report of the number of hourly paid staff
    15        working up to that hour, provided they did not -- say in
    16        the period of 4/8/93, up till nine o'clock, it says nine
    17        people; if someone took a break before that period, it is a
    18        minimum staffing level.  Basically, if they took a break
    19        before one minute to nine, they would not be included in
    20        that.  From that, you can take a look through and arrive at
    21        an opinion from -- well, it shows you the staffing levels.
    22        As you go through the printouts which show hour by hour the
    23        number of staff working, in my opinion, it was not --
    24        during this period it was not understaffed.
    25
    26   Q.   Are you saying it was never understaffed?
    27        A.  I am saying in this period -- there are occasions when,
    28        perhaps due to illness or something, then you could run
    29        short of staff and have to call staff in, et cetera.  But
    30        during this period it was not deliberately understaffed.
    31
    32   Q.   You are aware, presumably, of complaints in the rap
    33        sessions about understaffing from time to time?
    34        A.  Within the rap session, it does say -- I believe there
    35        are comments about understaffing.
    36
    37   Q.   Was any notice taken of those complaints?
    38        A.  In doing the schedule, you are always trying to
    39        schedule the correct amount of staff that the store needs;
    40        so you would take notice of those comments.  But you would
    41        not wait for a rap session if you felt there was a need for
    42        staff.
    43
    44   Q.   If a complaint was made by a crew at a rap session about
    45        short staffing -- well, complaints were made.  As a result
    46        of any of those complaints, were the numbers of people
    47        working on given shifts increased?
    48        A.  As I said, in my opinion, the restaurant was not
    49        understaffed; and I would not use the rap session as a
    50        guide to the number of -- a rap session report as a guide 
    51        to what I felt the restaurant needed.  I would update it 
    52        more frequently than that.  So, if I felt that there were 
    53        more staff needed or the staff was adequate, I would say
    54        the numbers that I felt could run the restaurant properly.
    55
    56   Q.   Sorry, did you say you would or you would not use the rap
    57        session as a guide?
    58        A.  Would not.
    59
    60   MR. JUSTICE BELL:  He said that he would not; he would update

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