Day 140 - 22 Jun 95 - Page 32

     
     1        A.  As I said, personally, I would have tossed it all, but
     2        it was kept in the office, some parts of it; some parts of
     3        this information were kept in the office.  When I conclude
     4        a matter, I do not need to keep things around, unless there
     5        is some specific reason for it.
     6
     7   Q.   Just while we have this page open of this letter -- sorry,
     8        do you know when that report was destroyed?
     9        A.  No, I do not.
    10
    11   Q.   You have no idea?
    12        A.  No, I do not.
    13
    14   Q.   How long afterwards was it?
    15        A.  I really do not have any idea.  I usually do not keep
    16        things that long.  I get a stack of mail virtually every
    17        day that would be several inches thick, so I try to dispose
    18        of things; otherwise, I would need cabinets that would
    19        occupy the entire building that I am in.
    20
    Q.   Your report included the wage rates at McDonald's in other
    22        states, did it not?
    23        A.  Other states?
    24
    25   Q.   Yes, not just in Pennsylvania?
    26        A.  Oh, are you referring to the fact that some of the
    27        stores that are considered suburban Philadelphia would be
    28        in, I think, Delaware or -- I am not sure exactly where
    29        they were, but there were some peripheral -- New Jersey,
    30        Delaware and Philadelphia are right together.
    31
    32   Q.   I am referring to the fact that when you decided to draw
    33        24 mile radius around Philadelphia, it included two other
    34        states.
    35        A.  I think it did, yes.
    36
    37   Q.   Two other states that may not have had minimum wage rates
    38        as high as those in Pennsylvania?
    39        A.  We chose the geographical area that PUP chose, and we
    40        did that on the first run, on 33.  The second round went
         out 24 miles.  But the first survey, if you will, was a
    42        mirror image of the geographical area that PUP had chosen.
    43        The wider survey, the 24 mile one, would have gone further,
    44        as you are suggesting.
    45
    46   Q.   Page 1461, again.
    47        A.  Yes.
    48
    49   Q.   Paragraph 4: "Regarding your information at the inquiry
    50        report that Glen Berkins disclaimed to you figures used in 
    51        his April 30th 1990 article, I contacted Mr. Berkins the 
    52        day after our meeting." 
    53
    54        Did you say that Mr. Berkins had disclaimed the figures
    55        used in his article?
    56        A.  One of our -- yes, I did.  At our meeting, one of our
    57        executives had spoken with Mr. Berkins to find out what
    58        methodology he had used, and I was informed that he had
    59        backed off on the accuracy of what he had done.
    60