Day 206 - 22 Jan 96 - Page 54
1
2 MR. JUSTICE BELL: Mr. Morris is asking you recently; obviously
3 at the time I assume you saw the documents?
4 A. Yes.
5
6 Q. But in the last few weeks, have you been looking at
7 documents going back to 1993, apart from the August 93
8 ones?
9 A. No, only these documents.
10
11 MR. JUSTICE BELL: Do you know what the complaint is,
12 Mr. Morris, about many shifts. I mean ---
13
14 MR. MORRIS: This is Paul Scott Shepherd, is it?
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16 MR. JUSTICE BELL: Yes -- I mean, have you got a case to put
17 that he was working 12, 13, 14, 15 days in a row, or
18 something like that?
19
20 MR. MORRIS: It just says in the statement "very many shifts in
21 a row 1993-ish.
22
23 MR. JUSTICE BELL: I am only asking you whether you have a
24 positive number to put.
25
26 MR. MORRIS: The problem is that I have not analysed all the
27 documents that we have been disclosed.
28
29 MR. JUSTICE BELL: Very well. I was only asking you; I am not
30 criticising you for not putting it. If you had a positive
31 figure, then it would be right to put it, you see.
32
33 MR. MORRIS: Yes.
34
35 MR. JUSTICE BELL: If what you are doing is trying to gain some
36 confirmation from the witness that there were a number, and
37 then pressing him as to how many at most, then I understand
38 that. You have been over that ground.
39
40 MR. MORRIS: Right. (To the witness): So you remember that
41 "many shifts in a row" is from your memory?
42 A. Yes.
43
44 Q. Not from the documents?
45 A. It is, yes, from my memory and as I would have seen the
46 schedule as he worked it.
47
48 Q. As he worked it, right. Because in 1993 the only month we
49 have got, he worked 92 hours in that month which is not
50 many hours. But it may have been different in the summer
51 period when you had an increase in the amount of staff?
52 A. Increase in the sales volume, you mean?
53
54 Q. Pardon?
55 A. Increase in the sales volume, not an increase in the
56 amount of staff? Am I correct in what you are saying?
57
58 Q. Probably, I do not know. Anyway, let us move on.
59
60 MR. JUSTICE BELL: Yes.
