Day 195 - 04 Dec 95 - Page 68


     
     1
     2   Q.   So the problem was one of the system rather than
     3        individual?
     4
     5   MR. JUSTICE BELL:  Let the witness give the evidence.
     6
     7   MR. MORRIS:  OK.  Finally -- Ms. Steel has some questions but
     8        I will finish mine off first -- can you remember, you said
     9        all night closes were sometimes as many as two in a month
    10        or something?
    11        A.  Yes.
    12
    13   Q.   Do you remember roughly how many you might have done in,
    14        say you were there for two years, I am talking about all
    15        night closes?
    16        A.  Yes.
    17
    18   Q.   Just roughly some kind of figure, how many, say, in a year,
    19        how many all night closes would you do?
    20        A.  I think all night closes I have to include an
    21        explanation there, because the all night closes are usually
    22        done by people who, first of all, have got some
    23        experience.  Secondly, they are recognised by the
    24        management to have that experience and also they are, they
    25        have got -- how can I put it -- the management regard them
    26        as good material for doing all night closes, OK.  So what
    27        happens is that until I was actually in this position, in
    28        the position to do all night closes, I was experienced,
    29        I was not doing many, say, in the first year, right, or the
    30        first nine months of my employment at McDonald's.  But it
    31        does not mean that all night closes did not happen.  I was
    32        not on every all night close.  So what I am saying is that
    33        there were all night closes that I did not take part in
    34        for, you know, different reasons.  You were not always, the
    35        people who did all night closes were not always the same
    36        group of people who did all night closes, but they happened
    37        very regularly.
    38
    39   Q.   Let us just take the last year.  Just give us some kind of
    40        figure.  You are saying sometimes of the year you might
    41        have done as many as three or four in a couple of months?
    42        A.  Yes.
    43
    44   Q.   And at other times did none happen at all for three or four
    45        months?  Give us some general figure for the whole year.
    46        Would you have done five, 10 or 15 or what?  If you cannot
    47        say just do not say.
    48        A.  No, I genuinely cannot remember.  I mean, as far as
    49        I can say, all I can say is that it seemed to me very many,
    50        but I could not tell you what I meant by "very many". 
    51 
    52   Q.   You did not do all the ones that were happening? 
    53        A.  No.  I did not, by no means I did.  The case in point
    54        is where Tracey Millain, for example, did a 16-hour shift,
    55        I was not on that all night close; she did that all night
    56        close and others.  So I was not on every all night close,
    57        no.
    58
    59   Q.   In this period of time which we have got, just to clarify
    60        the question of the accident that you had, you said that

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