Day 140 - 22 Jun 95 - Page 28

     
     1        A.  Yes, because you have different starting rates based
     2        upon experience.
     3
     4   Q.   So do you know how many people started over that period?
     5        A.  I cannot -----
     6
     7   Q.   What percentage of the stores, of an individual store?
     8        A.  It would vary from store to store.  I cannot recall
     9        that specifically.
    10
    11   Q.   Why did you not ever publish this information, if you were
    12        so keen to persuade people that the PUP survey was
    13        completely incorrect?
    14        A.  We were not about to give out all of our payroll data,
    15        but we did provide the study that TPF & C and the professor
    16        worked on.
    17
    18   Q.   That was something that the Corporation asked them to do,
    19        is it?
    20        A.  That is correct, we did.
    21
    22   Q.   They prepared the report in May 1990, I think it was; is
    23        that right?
    24        A.  I do not recall the exact date that they did it.  It
    25        would have been several months after the matter began.
    26
    27   Q.   I believe it does say somewhere it was May 1990.
    28        A.  OK, that probably would be about right.
    29
    30   MR. JUSTICE BELL:  It appears that the survey instrument was
    31        mailed to participating restaurants in June 1990 and
    32        returned to Towers, etcetera, in July?
    33        A.  That could be, my Lord.  I cannot recall the exact
    34        month.
    35
    36   Q.   The point is, you say that whenever it was done, it was
    37        looking back at the same two months as the PUP report?
    38        A.  Exactly, my Lord.
    39
    40   MR. MORRIS:  Where does it say that?
    41
    42   MR. JUSTICE BELL:  I have got that from page 1473, which is the
    43        one I was looking at earlier for the separate samples.  It
    44        is the last point on the page.
    45
    46   MS. STEEL:  The page before it does actually say May.  It says,
    47        under the decision to conduct a survey:  "To determine
    48        whether PUP's claims are accurate, McDonald's commissioned
    49        an independent survey of starting wage rates at
    50        Philadelphia area in McDonald's restaurants in May." 
    51 
    52   MR. RAMPTON:  My Lord, that is not what it means.  That means 
    53        the commission came in and the surveys were sent out.
    54
    55   MR. JUSTICE BELL:  That is the way I have read it, whatever it
    56        is supposed to mean.  What I was most interested in what
    57        the material dates for the starting wages were.
    58
    59   MR. MORRIS:  I do not know how Mr. Rampton knows what it means.
    60