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

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