Day 133 - 12 Jun 95 - Page 50


     
     1   Q.   Do you know of any industry that has average earnings less
     2        than catering or retail wage rates?
     3        A.  I do not know about other sectors, no, I do not have
     4        any information on that.
     5
     6   MR. MORRIS:  Can I just sit down?
     7
     8   MR. JUSTICE BELL:  Yes.  Quite frankly, if I were you, you have
     9        some information here, Ms. Mead cannot speak to more than
    10        is on the page, she cannot give any original.  It is
    11        entirely a matter for you, but I would leave your rates of
    12        pay there.  Do a bit of looking to see whether the New
    13        Earnings Survey helps you.  It has, for instance, average
    14        manual wages which includes absolutely everything, manual
    15        male, manual female, non-manual male, non-manual female.
    16        It is a mine of information.  Since it has been introduced,
    17        see what, if anything, you can get out of it, but if you
    18        can get a back copy which is the relevant -- they are
    19        relevant years -- which is the particular year when you can
    20        say someone reading this leaflet which is written in the
    21        present tense, so far as this is concerned, this section of
    22        the case is concerned, would be looking at what the wages
    23        were in the year up to April 1990 and then work on that
    24        basis.
    25
    26   MR. RAMPTON:  My Lord, while Mr. Morris gathers himself, I would
    27        like to take up a completely false point which Ms. Steel
    28        made which, in answering, I would like to do it now in
    29        fairness to the witness.  She seemed to assert that there
    30        had been, as she often does, some deliberate concealment of
    31        documents.
    32
    33        Your Lordship will remember that in Ms. Mead's statement
    34        she gave figures for turnover in 1989 and for the present
    35        time, which is in 1993, when she made her statement.  That
    36        was paragraph 17 of the statement.  The request for
    37        discovery to which Ms. Steel just now referred was this
    38        under paragraph 17:  "Of the 191 per cent turnover rate in
    39        1989, any documents relating to the percentage of leavers
    40        re-employed within a year".  When Mrs. Brinley-Codd swore
    41        her affidavit she said in answer to that request:  "There
    42        are no documents."
    43
    44   MS. STEEL:  Can I just point out, I am getting the blame for
    45        that, I did not even mention it but ......
    46
    47   MR. RAMPTON:  An apology both to Ms. Mead and to
    48        Mrs. Brinley-Codd might be appropriate.
    49
    50   MR. JUSTICE BELL:  What are you saying that Ms. Steel said? 
    51 
    52   MR. RAMPTON:  She appeared to suggest that a request for general 
    53        discovery of turnover figures had been made in relation to
    54        that paragraph of Ms. Mead's statement.  It is not so.
    55        What was asked for -----
    56
    57   MR. JUSTICE BELL:  Paragraph 17?
    58
    59   MR. RAMPTON:  Yes.
    60

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