Day 247 - 10 May 96 - Page 29
1 put to me when you come to make your submissions and I will
2 make of it what I will. I really do not think asking Mr.
3 Preston about it advances the matter at all.
4
5 MR. MORRIS: Well, if you remember, we had a lot of documents
6 served after Jill Barnes left the witness box and they
7 included -- and I do not have them in front of me
8 although ----
9
10 MR. JUSTICE BELL: I really do not think Mr. Preston can help in
11 the face of experts in this particular field we have had
12 and people who are working in the field.
13
14 MR. MORRIS: Right. You did say that we could invite you to
15 draw conclusions from the documents themselves.
16
17 MR. JUSTICE BELL: You are going to refer me, or you may do,
18 either in shorthand by saying, "Remember the comments, the
19 matters we put in cross-examination of the Plaintiffs'
20 witnesses on the HSE Report", or you may point to specific
21 parts of it and then you say, "That shows they were not
22 taking health and safety seriously". Then when we get on
23 to Mr. Rampton, he will put another point of view perhaps,
24 and I will have to decide about it.
25
26 MR. MORRIS: It is just that the documents that we got since Miss
27 Barnes left the witness box we were going to recall her for
28 questioning her, and you said that that may not be
29 necessary and we were entitled to point you to various
30 parts of the those documents.
31
32 MR. JUSTICE BELL: Yes, but you need not do it through the
33 formula of Mr. Preston.
34
35 MR. MORRIS: OK, let us leave that then. You can leave that
36 document then, Mr. Preston.
37
38 MR. JUSTICE BELL: What I will do is I will hand those back, not
39 because I am not interested in them ultimately, but by the
40 time you come to make any comment on it, no doubt the place
41 in the bundle will be identified and I do not want too much
42 loose paper around.
43
44 MR. MORRIS: It should be there somewhere.
45
46 We have had a great deal of evidence, I am sure we do not
47 want to go into again, about the turnover of staff at
48 McDonald's stores which was running like something 195 per
49 cent in December, I think it was December 1989 according to
50 your figures, your Company figures, in the UK stores and
51 has been progressively brought down since then.
52
53 Was there any monitoring -- do you know, if you do not
54 know, you do not know -- of the turnover rates before 1989?
55 A. There may have been. If you want a number I could not
56 tell you what the number was.
57
58 Q. I want to know if there was any monitoring of turnover
59 rate?
60 A. In the British company?
