Day 140 - 22 Jun 95 - Page 27
1 starting rates, does it?
2 A. It does, because you can look down it, my Lord, and see
3 when somebody started.
4
5 Q. I see. What, you find when a particular person started
6 when you look at what their rate was?
7 A. -- starting rate was, my Lord, exactly.
8
9 MS. STEEL: So what period did you check back over?
10 A. It would be for those crew that were on the payroll as
11 of November/December, some time period there, and we would
12 go back and see what their average starting rate was.
13
14 Q. Would there always be on every payroll new people starting?
15 A. Yes.
16
17 MR. JUSTICE BELL: So one person's starting wage might be, let
18 us say, a date in 1982; another person's starting wage
19 might be a date in the middle of 1989?
20 A. It could be.
21
22 Q. But you get them all together and you take the average?
23 A. Right; and the way I believe -----
24
25 Q. Even though the person who started in '82, their starting
26 wage would have been much higher if they started in '87,
27 whether it was in the same restaurant or another
28 restaurant, same franchisee ---
29 A. That is the way I did it, my Lord.
30
31 MR. JUSTICE BELL: -- and vice versa.
32
33 MR. MORRIS: So if someone started 20 years previously, you
34 would have said that their starting rate was 50 cents an
35 hour, something like that?
36 A. No, no. I think I understand the confusion. No. The
37 starting rates -- I am sorry, my Lord. The starting rates
38 were those people who were hired during that
39 November/December period, and we would look back at the
40 payroll period when they started; so it would be within
41 that November/December time period, not someone back -----
42
43 MR. JUSTICE BELL: You only took people who had actually started
44 within that time period?
45 A. That is correct, my Lord.
46
47 Q. You looked back and took out the crew who it turned out,
48 when you looked back, had started within that time period?
49 A. Yes. What you do, when you take the November/December
50 -- and I think it was November/December, it may have been
51 January, my Lord, I cannot specifically recall.
52
53 Q. And that is what PUP worked on, was it?
54 A. They worked on that time period.
55
56 MS. STEEL: Some people might start at a higher rate if they had
57 more experience?
58 A. That is correct.
59
60 Q. So they would have been included in the average?
