Day 140 - 22 Jun 95 - Page 57
1 differential between the city and suburbs in Philadelphia
2 at this time, whether it was 11 cents, 22 cents, or 87
3 cents, or $1.10c, would be based on availability of labour
4 and market conditions?
5 A. It would be based on the survey data.
6
7 Q. No, I mean the reason?
8
9 MR. JUSTICE BELL: If there was a difference, would that arise,
10 as Mr. Morris is suggesting, from availability of labour
11 and market conditions or for some other reason?
12 A. It could be a variety of different reasons, my Lord.
13
14 MR. MORRIS: If we look on 91, it is page 1464 in tab 91, this
15 is a letter by Stephen Brown, System Vice President Labour
16 Relations, who I believe is in the court at the moment, on
17 July 3rd, 1991. At the top of page 2 of that letter, which
18 he wrote on behalf of Mr. Quinlan, or Mr. Quinlan asked him
19 to respond, he says midway through that
20 paragraph: "Contrary to PUP's claim the average wage paid
21 to the surveyed restaurants differed by just 11 cents per
22 hour based on availability of labour and market
23 conditions". Would you accept that is the Corporation's
24 position?
25 A. That is Mr. Brown's point of view. It could also be
26 based upon such things as workers who go from the city to
27 the suburbs, have to pay for car fare, if you will, train.
28 There are a variety of different factors that come into
29 play in an owner/operator determining what his or her pay
30 should be. You are asking me to read some conclusions and
31 some very hypothetical situations. Each owner/operator has
32 to figure it out for himself or herself.
33
34 MS. STEEL: Just to clarify, this is the letter that is the
35 reply to the one I asked you about just a moment ago, and
36 presumably you asked Mr. Brown to reply to this letter?
37 A. It looks like it may be. I ----
38
39
40 Q. In fact, the letter on the previous page has now got
41 "Steve" written at the top?
42 A. Yes, but that is not my handwriting, so what often at
43 times happens, if you will notice that my name is at the
44 top right and then somebody else, my secretary or someone
45 else, appears to have written "Steve" on it because that is
46 not my handwriting.
47
48 MR. JUSTICE BELL: It looks as if it could well be the response?
49 A. Yes. I do not dispute that, my Lord.
50
51 MS. STEEL: Mr. Brown would have been under you at that time?
52 A. Yes.
53
54 Q. Presumably you thought he was capable of doing his job?
55 A. I think he is a capable person, yes.
56
57 Q. There is just one other thing I wanted to ask about this
58 letter. At the bottom of page 2 going over on to page 3
59 there is a list of various what you might call charitable
60 activities there. Is that a frequent tactic of McDonald's
