Day 140 - 22 Jun 95 - Page 26

     
     1        totally incorrect.
     2
     3   Q.   Did you check all the figures that are given there for
     4        starting rates for McDonald's stores?
     5        A.  What figures?
     6
     7   Q.   The figures that are given on pages 1431 to 1434?
     8        A.  McDonald's people first check them, and then TPF & C
     9        and the professor check them independently.
    10
    11   Q.   When you check them, or when somebody checked them -- did
    12        you ask somebody to check them?
    13        A.  Yes.
    14
    15   Q.   You did?  Did they give you a final report on what they
    16        found?
    17        A.  Yes, they gave me an oral report on what they found.
    18
    19   Q.   An oral report?
    20        A.  Yes.
    21
    22   Q.   So they were carrying around the figures for all these
    23        stores in their heads, were they?
    24        A.  They were referring to wage data PIRO records from the
    25        stores.
    26
    27   Q.   So no formal report was ever compiled by McDonald's about
    28        the starting wage rates?
    29        A.  The formal report was done by Towers Perrin and
    30        Professor Perrin.
    31
    32   Q.   No formal report was done by McDonald's; is that correct?
    33        A.  We did not do a written report.
    34
    35   Q.   What exactly were the payroll records that you looked at?
    36        A.  From the stores in question.
    37
    38   Q.   So what information is on the payroll records that you saw?
    39        I do not know whether they are the same as the ones we have
    40        seen in the UK?
         A.  It has individuals' names, it has their hours worked,
    42        it has their pay rate -- those things.
    43
    44   Q.   Did you do it solely on what the lowest rates were in the
    45        stores, or what?
    46        A.  No.  It is the average starting rate.
    47
    48   Q.   For crew, was it?
    49        A.  That is correct -- solely for crew.
    50 
    51   Q.   So does the payroll record indicate how long people have 
    52        been working for the Company? 
    53        A.  It would have a hire date on it, yes.
    54
    55   Q.   When did you ask for this information?
    56        A.  I think that the issues arose in the latter part
    57        of '89, in that time period, right after the issue arose.
    58
    59   MR. JUSTICE BELL:  I am sorry, I have not understood.  When you
    60        look at the payrolls to check, that does not give you the