Day 173 - 16 Oct 95 - Page 56


     
     1        that, something less maybe -- the reality is because of the
     2        large amount of full-timers that were clearly interested in
     3        union representation, the reality is it is something like a
     4        majority of full-timers in your Company at that time were
     5        interested in union representation.  Would you accept that?
     6
     7   MR. JUSTICE BELL:  Do you accept that?
     8        A.  I do not accept your comment that it is practically --
     9        I think you said practically all of the ----
    10
    11   MR. MORRIS:  No, the majority.
    12
    13   MR. JUSTICE BELL:  What Mr. Morris says, if you look at the
    14        full-time workers whom you might add are probably the
    15        people who are most concerned about what they get paid
    16        because that is probably, or could well be, their sole
    17        source of income.  What Mr. Morris is suggesting is that
    18        more than 50 per cent of those were interested in having
    19        the union represent them.  What I want to know is whether
    20        you accept that or not?
    21        A.  Well, I accept the fact that I think you counted two
    22        full-timers, which, based on Mr. Morris' calculation, is a
    23        fair proportion.
    24
    25   Q.   I have made this note:  I accept that about 18 of full-time
    26        crew were interested in union representation which, taking
    27        30 per cent of about 150, is a fair proportion?
    28        A.  Yes, my Lord.
    29
    30   Q.   That is what you meant to say?
    31        A.  Yes.
    32
    33   Q.   Mr. Morris can pick it up from there if he wants, but you
    34        accept that much?
    35        A.  Yes, my Lord.
    36
    37   MR. MORRIS:  Can I ask the status of the appendices that were
    38        attached to the statements?
    39
    40   MR. JUSTICE BELL:  Which particular ones are you interested in?
    41
    42   MR. MORRIS:  I am not sure yet.  I am asking for a legal -- this
    43        is a legal question really, I do not mind saying.
    44
    45   MR. JUSTICE BELL:  Sit down for a moment, please, Mr. Mehigan.
    46
    47   MR. MORRIS:  I do not think the appendices actually cover.  It
    48        is not ----
    49
    50   MR. JUSTICE BELL:  You must tell me --- 
    51 
    52   MR. MORRIS:  I was going to, yes. 
    53
    54   MR. JUSTICE BELL: -- which particular appendix you have in
    55        mind.
    56
    57   MR. MORRIS:  I think actually it is not something that was
    58        attached to his statement.  It was actually the letter
    59        allegedly written by the staff.  It is appendix 3.  So I
    60        have to deal with that.

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