Day 181 - 01 Nov 95 - Page 58


     
     1        included or only given one count instead of five or however
     2        many times they come back.
     3
     4   MR. MORRIS:  There was a clarification of a point that did come
     5        up, which is the reasons for leaving figures showing the --
     6        I do not know if it is a matter of legal point I should
     7        make direct -- I have said this before -- the reasons for
     8        leaving being 23 per cent for reasons for going back to
     9        school or college, these are reasons for each time an
    10        employee leaves.  Therefore, that indicates, if those are
    11        to be taken to be the ones that are actually students
    12        returning to college and school, 23 per cent, if they are
    13        returning, say, as McDonald's claim, three or four times in
    14        a year -----
    15
    16   MR. JUSTICE BELL:  That is a point of argument.  I have got the
    17        point you make.
    18
    19   MR. MORRIS:  The actual number of students is going to be -- the
    20        number of people would be a third or a quarter of that 23
    21        per cent and they would be figuring three or four times.
    22        So, it could be that there is only eight to 10 per cent of
    23        people in that category, but they are figuring three times
    24        in the figures.  OK.  I think we will leave that point.
    25
    26        You did say -- I was not quite clear about hustle -- that
    27        hustle was used -- when you saw your site visits how was
    28        hustle applied in the kitchen area?
    29        A.  Well, in my ------
    30
    31   MR. JUSTICE BELL:  How does this arise out of
    32        cross-examination?
    33
    34   MR. MORRIS:  Because Mr. Rampton was not clear whether skip
    35        running ------
    36
    37   MR. RAMPTON:  Oh, yes, I was because the witness told me that he
    38        preferred his first version, that skip running is in the
    39        front area alone.
    40
    41   MR. MORRIS:  Yes, and I am asking the witness to clarify -----
    42
    43   MR. RAMPTON:  So Mr. Morris is now trying to contradict his
    44        witness's answer.
    45
    46   MR. MORRIS:  No, I am not.  I am asking him, how was hustle
    47        applied in the kitchen area, to clarify what you were
    48        saying.
    49
    50   THE WITNESS:  Well, from my -- how was hustle applied in the 
    51        kitchen area?  I take it by "kitchen area", you mean back 
    52        of house, not front of house? 
    53
    54   Q.   Yes.
    55        A.  My evidence, my evidence, is primarily this, that you
    56        saw rapid work.  I am not claiming on those two site visits
    57        that I saw at the back of house in the few moments where I
    58        was allowed to stand with the Store Manager, with the
    59        Company's solicitor, I am not claiming that I saw in that
    60        quiet period in the back of house what I have described as

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