Day 188 - 15 Nov 95 - Page 34


     
     1        A.  Yes.
     2
     3   Q.   Do you stand by it?
     4        A.  Yes.
     5
     6   Q.   There were just a few points in the notes that I was going
     7        to refer to, ask you about.  If you can go to page 10,
     8        please, of the notes, in the first paragraph on that page,
     9        it is talking about buns, at two in the morning, being left
    10        in the lobby throughout the night until the cleaning is
    11        almost finished.  Is that something you witnessed?
    12        A.  Yes.
    13
    14   Q.   Further on down that page, in the fourth paragraph, the
    15        third line, you say: "The kitchen is indescribable chaos.
    16        The floor is sopping wet with fat and water, a lethal
    17        mixture if crew members stepped into it, to be about.
    18        There are vague attempts to mop the floor from time to
    19        time, but it is wasted energy and not taken seriously,
    20        because the floor would swiftly become a mess again."
    21
    22        Is that something you witnessed?
    23        A.  Yes.
    24
    25   Q.   Then, in the next paragraph, the second line:  "David has
    26        finished cleaning out the fryer.  He pushes it back into
    27        place, a tight fit between the serving section and the
    28        wall.  He has to edge the frier into this tight fit.
    29        Unlike Henry, has no protective clothing other than long
    30        rubber gloves."
    31
    32        Was that something that you witnessed?
    33        A.  Yes.
    34
    35   Q.  "The fat, which is still smoking hot, slops over the edges
    36        of the vat.  It would take only the smallest jerk for it to
    37        slop over David.  His groin is just about where the fat
    38        would slop.  The whole process of filtering and cleaning
    39        the vat is unbelievably risky."
    40
    41        Is that all your observations?
    42        A.  Yes.
    43
    44   Q.   Then, at the end of that paragraph, you say: "The floor is
    45        treacherous.  One slip could lead to hot oil spraying over
    46        the whole work area."
    47
    48        Is that something you witnessed; yes?
    49        A.  Well, I witnessed that the floor was treacherous.
    50        I never saw oil spraying over the whole work area. 
    51 
    52   Q.   Fair enough.  That was -- you mean there about the fat 
    53        filtering?
    54        A.  That was the process of changing the fat in the vats,
    55        yes.
    56
    57   Q.   Changing the fat in the vats, OK.  I will move over the
    58        page.  In the second paragraph, you talk about:
    59
    60        "The two girls and Perez had finished their jobs on the

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