Day 122 - 05 May 95 - Page 54
1 given the full-time and part-time figures, that is not a
2 record of which crew members are employed as full-time
3 workers and which are employed as part-time workers?
4 A. No.
5
6 Q. Is it?
7 A. No, it is the ones that are indicated to me in that
8 return as working part-time and full-time.
9
10 Q. It is just the ones that are indicated as working over, is
11 it, 39 hours?
12 A. 39 hours.
13
14 Q. Over 39 hours a week or under 39 hours a week?
15 A. No, at 39 hours.
16
17 Q. At 39?
18 A. Yes. There is nowhere else I could get that
19 information.
20
21 Q. The distinction may become important later. I mean, a lot
22 of companies actually specifically state: "We are
23 employing you as full-time, we are employing you as
24 part-time and, therefore, you have different rights",
25 whatever, but you do not do that; you just base it on how
26 many hours people are working?
27 A. We base it on what they request to work.
28
29 Q. Yes, but your statistics are based upon how many hours
30 people work?
31 A. Because it is the only place I can go to find out that
32 information.
33
34 Q. That is all I am trying to confirm.
35 A. Yes.
36
37 Q. So you do not have any separate records on who is actually
38 employed as a full-timer and who is actually employed as a
39 part-timer?
40 A. I cannot say "no" to that because it may be obtainable
41 from payroll computer records. I have never looked for
42 that kind of information. I based my figures, as I said,
43 on those returns.
44
45 MR. JUSTICE BELL: While we are on that page, you said the 600th
46 restaurant was opened a few days ago?
47 A. Last -- a week last ----
48
49 Q. The Monday before this one?
50 A. Yes, that is right.
51
52 Q. Did you say whether that included the franchised
53 restaurants or not; I cannot remember?
54 A. No, that included the franchised restaurants.
55
56 Q. Does the 380 there in 1989 include the franchised
57 restaurants?
58 A. Yes, that would include franchised restaurants. So,
59 the franchised -- the franchised crews would not be
60 included in that number. In 1989 we would have
