Day 116 - 26 Apr 95 - Page 04


     
     1   MR. JUSTICE BELL:  Was that copy for Mrs. Brinley-Codd or for
     2        me?
     3
     4   MR. MORRIS:  That was for you.
     5
     6   MR. RAMPTON:  By all means, let your Lordship have it.  I am
     7        quite sure I have it; whether I have the enclosures is
     8        another question, but if I have not I will moan about it.
     9
    10   MR. MORRIS:  They were all served at the time and looked at in
    11        court; it is just that someone may have lost their copy or
    12        something.
    13
    14   MR. JUSTICE BELL:  I will file that away in due course.
    15
    16   MR. RAMPTON:  My Lord, all I would say about the employment
    17        witnesses is this:  In view of that response, it is a topic
    18        to which I should wish to return in due course, after
    19        Mr. Nicholson has given his evidence ---
    20
    21   MR. JUSTICE BELL:  Yes.
    22
    23   MR. RAMPTON:  -- for reasons which will be obvious to your
    24        Lordship.
    25
    26        The other things are these:  I have some documents to hand
    27        in.  The first is an update of the lavender diary.
    28        (Handed)  My Lord, what we have done -- also the
    29        Defendants have this -- is to copy the employment section
    30        of the Abstract which is tab 7, and number each of the
    31        passages.  I think it goes to 116.  It will make it a lot
    32        easier as we go through this part of case in the future.
    33
    34        My Lord, the next thing is we have prepared a hierarchy, a
    35        chart, showing the hierarchy at McDonald's so far as
    36        salaried and hourly paid staff are concerned.
    37        Mr. Nicholson will explain that in a moment.  Then there
    38        are some tables (and Mr. Nicholson will explain where they
    39        come from) showing the percentages of crew promoted to
    40        salaried management positions in 1988 and 1989.  The 1989
    41        document is a one page document; the 1988 document is a
    42        two-page document.
    43
    44        Then, my Lord, next a single sheet showing the percentage
    45        of labour costs for each category, crew and management,
    46        holiday and payroll taxes for, I think it is, a period in
    47        1993.  It may be for the whole of 1992.  Again, I will ask
    48        Mr. Nicholson to explain it.
    49
    50        Finally -- this does not relate to the evidence of 
    51        Mr. Nicholson but I have it now so I will, if I may, hand 
    52        it in -- the update on the Second Plaintiff's analysis or 
    53        monitoring of the ethnic origins of their workforce.  There
    54        is already in the file some earlier material.  This Lyn
    55        Mead will deal with.  This is an update for the second and
    56        fourth quarters of 1994.  Your Lordship does not need to
    57        worry about that at the moment.  That is for the future.
    58
    59        My Lord, can I ask your Lordship to keep what I call the
    60        Nicholson documents by for the moment, because their

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