Day 138 - 20 Jun 95 - Page 22


     
     1        There is a good deal of detail, including some figures.  On
     2        the whole, Mr. Stein, unless his Lordship prefers
     3        otherwise, I would rather you did not have ---
     4        A.  That is fine.
     5
     6   Q.   -- any writing in front of you ---
     7        A.  Perfectly fine.
     8
     9   Q.   -- except as necessary.  I will, however, read you out the
    10        various allegations that are made by the Defendants so that
    11        you can deal with them.
    12
    13   MR. JUSTICE BELL:  When Mr. Rampton reads it out, he is not
    14        asking you just for a general comment.  He will ask you
    15        specific questions once he has read it to you.
    16        A.  Yes, my Lord.
    17
    18   MR. RAMPTON:  I will just read it out so you know what it is we
    19        are dealing with, Mr. Stein, then I will ask questions
    20        about it, if I may.
    21        A.  The first allegation, if we may call it that,
    22        Mr. Stein, is this, that in the United States in 1989 the
    23        official minimum wage in Philadelphia was $3.70 per hour.
    24        McDonald's pay $3.70 to $4.  The first question, do you
    25        recall what the Philadelphia minimum wage was in 1989?
    26        A.  My recollection would be that 3.70 would be correct.
    27
    28   Q.   As a slight digression from that -- there is no need to
    29        look at it -- the chart which you have supplied to us
    30        giving the national minimums shows us, if it be right, that
    31        the national or federal minimum at that time, 1989, was
    32        3.35?
    33        A.  I believe that is correct.
    34
    35   Q.   So the Philadelphia minimum was above the federal minimum?
    36        A.  Yes, it was.
    37
    38   Q.   So that had been done by the city or by the state?
    39        A.  I believe that was the state of Pennsylvania.
    40
    41   Q.   My question is what, in fact, was the average starting
    42        rate, if you can remember, paid by McDonald's in
    43        Philadelphia at that time?
    44        A.  It would be in the 3.90 area, I think, 92, 93,
    45        something like that, up to 4.13, I believe.
    46
    47   Q.   Would that have been the average starting rate?
    48        A.  That is correct, sir.
    49
    50   Q.   So the average rate for the crew as a whole in Philadelphia 
    51        would have been the same, more or less? 
    52        A.  It would be the same; it would be within that rate. 
    53
    54   Q.   That is for the starting rate; what about the average rate
    55        for all workforce?
    56        A.  The average rate, oh, that would be higher.
    57
    58   Q.   A bit more substantial:  Again in Philadelphia in
    59        1989 -- my Lord, this is on page 8, it is (ii), it is 99 of
    60        the Abstract -- this reads, Mr. Stein, as follows:  "In or

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