Day 137 - 19 Jun 95 - Page 50
1 has to think about?
2 A. Absolutely.
3
4 Q. The cost of labour?
5 A. Sure.
6
7 Q. I take it you would agree, nobody in this court would
8 disagree, that if your labour costs are unduly high your
9 profitability may fall?
10 A. That is correct.
11
12 Q. First of all about this document, we or at least I in this
13 court had supposed this was a United States document for
14 the reason that it calls itself McCopCo, is it or not?
15 A. No. These crew labour percentages are lower than what
16 I would anticipate.
17
18 Q. Do you see the first line table the way the word "labour"
19 is spelt?
20 A. Yes.
21
22 MR. JUSTICE BELL: Can I make sure I have the right document?
23
24 MR. RAMPTON: It is called "Payroll per cent XLS" whatever that
25 might mean. It looks like that my Lord.
26
27 MR. JUSTICE BELL: That is 41A, is it?
28
29 MR. RAMPTON: Yes, my Lord. It should be 41A.
30
31 THE WITNESS: I have at the bottom 704A.
32
33 MR. JUSTICE BELL: That should come before 41B and C.
34
35 MR. RAMPTON: Do you think it likely that the Americans would
36 have as a courtesy to the British and their court
37 proceedings misspelt the word "labour"?
38 A. No. With all due to the regard to the respect we do
39 have, we would not do that. The spelling O-U-R is not used
40 in the US.
41
42 Q. Not I dare say for some years, though there might have been
43 a time. Mr. Stein, what do you think the US across the
44 country on average the labour costs are as a percentage of
45 sales?
46 A. It would be in the 17.5, 18 per cent range in the US.
47
48 Q. So it is significantly higher than it is in this country?
49 A. Yes, you need to ----
50
51 Q. What do you think the reason for that is?
52 A. It is clear to me why. This is a percentage of sales
53 and I believe that the stores in England have higher
54 volume, if you will. I do not know if the word
55 "volume" ----
56
57 Q. Yes.
58 A. --- is correct for you. But higher sales than the US
59 stores, so that has a direct bearing on what labour per
60 cent would be. Obviously, the higher the volume of the
