Day 140 - 22 Jun 95 - Page 22
1 managers"?
2 A. And I am telling you that is not my information.
3
4 Q. But your information is just what -----
5 A. My information is based, they spoke to different
6 people: crew people in one store, a manager, maybe, in
7 another store, and a crew person in another store; that it
8 was not all managers, and they just randomly spoke to
9 people. They may have, in fact, been customers.
10
11 Q. You also criticise the survey, saying that they skipped
12 certain stores?
13 A. Yes, they did.
14
15 Q. Right.
16 A. Certain stores where the representatives had gone they
17 skipped, and others.
18
19 Q. You said that, in the greater Philadelphia area of
20 McDonald's stores, there would be around 200 stores?
21 A. What I said was, I was asked the question of how many
22 stores in the Philadelphia region.
23
24 Q. Actually, you were asked: "How many stores were there in
25 Philadelphia at that time, do you remember", and you
26 said: "There would probably, in the greater Philadelphia
27 area, McDonald's stores, there would be around 200."
28 A. OK. My reference at that point was to the region.
29
30 Q. Right. There are not 200 stores in Philadelphia?
31 A. In the Philadelphia region there are 200 stores.
32
33 Q. At that time, there were 43 stores in Philadelphia ---;?
34 A. No.
35
36 Q. -- were there not?
37 A. No.
38
39 Q. No?
40 A. The Philadelphia region contains a large geographical
41 area beyond the city of Philadelphia.
42
43 Q. There were 43 stores in Philadelphia itself?
44 A. In the city.
45
46 MR. JUSTICE BELL: Can I find out, what did the PUP Report
47 cover?
48
49 MS. STEEL: 33.
50
51 THE WITNESS: 33 stores, my Lord.
52
53 MS. STEEL: In the city and suburbs; it is not the Philadelphia
54 region.
55
56 MR. JUSTICE BELL: But what do the suburbs cover?
57 A. They covered a 24 mile radius surrounding Philadelphia.
58
59 Q. If someone said "Philadelphia and suburbs" to you, what
60 would that mean?
