Day 153 - 12 Jul 95 - Page 36


     
     1
     2   Q.   You would have said, "which I presume no longer exists"?
     3        A.  Well .....
     4
     5   Q.   "I understand" implies that you asked somebody and somebody
     6        told you.
     7
     8   MR. JUSTICE BELL:  You have put your point to him and he has
     9        given his answer.  If you, in due course, want to argue
    10        that this is an indicator on credit, take it up with me
    11        later.
    12
    13   MS. STEEL:  Yes.  No, I want to repeat the question I asked
    14        before, which you said you want to look at your statement
    15        before you answered.  Were you told to put that in your
    16        statement or was it your own suggestion?
    17        A.  I believe it was my own suggestion, in that I would
    18        have been surprised if it was still available that long
    19        after.
    20
    21   MR. JUSTICE BELL:  Shall we break off there?  Two o'clock.
    22
    23                         (Luncheon Adjournment)
    24
    25   MR. MORRIS:   In paragraph 33 in your statement, you say it was
    26        never stated that a close was meant to finish at midnight,
    27        but that was the -- was midnight considered as a kind of
    28        official end of shift time, in terms of the calculation of
    29        breaks or food allowance, things like that?
    30        A.  I cannot remember.  I believe it was 1 o'clock.
    31
    32   Q.   So people were actually scheduled, if they were doing the
    33        last shift, they were scheduled to 1 o'clock?
    34        A.  No, they were scheduled till close.
    35
    36   Q.   Which was considered to be 1 o'clock?
    37        A.  No, which could be half past 12, it could be half
    38        past 1, it could be 1 o'clock, averaging out round about
    39        1 o'clock.
    40
    41   Q.   But if people worked as they did -- the last shift tended
    42        to be from 4 to 12, sorry, 4 till close; yes?
    43        A.  Yes.  Some people worked 6 till close.
    44
    45   Q.   But in terms of calculation of how much breaks that would
    46        entitle people to, and people knowing that in advance, it
    47        was assumed what, that that 4 till close meant what?
    48        A.  Well, the calculation of breaks and food allowances
    49        till what?
    50 
    51   Q.   I am just trying to say, was it assumed to be eight hours 
    52        plus whatever it took to close, or was it assumed to be an 
    53        eight hour, nine hour shift?
    54        A.  For the purpose of breaks and food allowance, it was
    55        assumed to be a nine hour shift, although we used to
    56        generally have a five to ten minutes break at 11 o'clock to
    57        give people the chance to have a cigarette and a drink, as
    58        well.
    59
    60   Q.   Further on in that section, you said that staff were

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