Day 209 - 25 Jan 96 - Page 56
1 the employee record, I suggest you steer clear of Gore and
2 Stokes because, quite apart from the PRs, rightly or
3 wrongly, someone has written in some pretty critical things
4 about them on their disciplinary records.
5
6 So, pick one or two who have not got those critical things
7 written in about them, and do a bit of working out as to
8 how much they got increased over a period of time. Then if
9 you think it helps your argument, serve it up to me at the
10 end of the day. I probably will not ask you about it again
11 because it is up to you whether you think it is productive
12 from your point of view, but that is the kind of assistance
13 which might help.
14
15 MR. MORRIS: Yes, I will try to, if I remember.
16
17 MR. JUSTICE BELL: I mean, if you do not serve it up to me, I am
18 not going to draw any conclusion; it may be that you have
19 not had time to do it, it may be just that you have
20 forgotten, but that is the sort of thing you have to look
21 at.
22
23 THE WITNESS: Could I mention something?
24
25 Q. If you wish.
26 A. We do have, when we used to fill in the cash sheets at
27 night, we have what is called an "average rate". That
28 shows the average for all the crew members in the store at
29 that time.
30
31 Q. There you are.
32 A. And that is on every cash sheet for every year, and
33 those cash sheets have to be kept. So you could get the
34 average rate for the last few years for every day.
35
36 Q. Do you know how long they are kept?
37 A. I do not know how long cash sheets are kept for, but
38 I assume it is several years. It is a book that -- it is
39 all the entries that you, you know, have for all the cash
40 you took, so I would imagine it is at least two or three
41 years -- probably more. Every day -----
42
43 MR. MORRIS: That is crew?
44 A. Every day you had to write the average crew rate, the
45 average rate for crew.
46
47 Q. Did that include people from your grade as well?
48 A. Yes.
49
50 Q. Anyone who is hourly paid?
51 A. Yes.
52
53 Q. It would be averaged out?
54 A. Yes.
55
56 Q. What type of average was it, do you know? Was it add them
57 all up and divide by the number of people or what?
58 A. It used to work out at about £3.40 when I was there and
59 that was -- it was all the crew members, all the hourly
60 paid staff, divided by the number of hourly paid staff,
