Day 140 - 22 Jun 95 - Page 25

     
     1
     2   Q.   The first couple of pages are city, what they have labelled
     3        "city", and the second couple of pages are suburbs; from
     4        page 1433 is suburbs.
     5        A.  Yes.  I am trying to -- I know some street addresses,
     6        so I am trying to help by looking at street addresses.
     7
     8   Q.   To be of assistance, page 1433 and 1435 are the same.
     9        A.  Thank you.
    10
    11   MR. JUSTICE BELL:  Just so that I can be clear in my own mind
    12        where we are going, if you look at tab 94 on page
    13        1473 -----
    14        A.  Tab 1473?
    15
    16   Q.   Yes.
    17        A.  OK.
    18
    19   Q.   What that document says, for better or worse, is that the
    20        survey -- the McDonald's Survey, it is called, but I assume
         that means the survey commissioned by McDonald's from
    22        Towers Crosby?
    23        A.  Yes, my Lord.
    24
    25   Q.   -- included hourly wage rate data from separate samples,
    26        the first being McDonald's restaurants found in the PUP
    27        survey?
    28        A.  Yes, my Lord.
    29
    30   Q.   There are 33, presumably?
    31        A.  Yes, there are.
    32
    33   Q.   And a broader sample of all McDonald's restaurants within a
    34        24 mile radius from the centre of Philadelphia.  The 24
    35        mile radius was selected at an appropriate distance,
    36        because it includes the furthest out line or restaurant in
    37        the centre of Philadelphia.  You say that that area would
    38        contain 118 McDonald's restaurants?
    39        A.  Yes, my Lord.
    40
    MR. JUSTICE BELL:   Just so that I understand what you are
    42        saying.
    43
    44   MS. STEEL:  Before you started rubbishing this report to -----
    45        A.  Are you stating a fact or something I did?
    46
    47   MR. JUSTICE BELL:  Can I say what I said once before, because --
    48        I forget the adjective which you used on a previous
    49        occasion.  It is generally much more helpful and productive
    50        if you always use fairly neutral language, because if you 
    51        put in a word like "rubbish" or a pejorative adjective, the 
    52        first thing which the witness does is complain about that; 
    53        and we then about three or four more questions before we
    54        get the answer to what you are really asking.  So I suggest
    55        you just ask what you want to ask, without using words
    56        which immediately call some comment into the question.
    57
    58   MS. STEEL:  (To the witness)  Are you saying you did not rubbish
    59        this report?
    60        A.  I think I pointed out that it is not adequate, it is