Day 141 - 23 Jun 95 - Page 24

     
     1        there was something like 150 people there at the time at
     2        6 o'clock?
     3        A.  Yes.
     4
     5   Q.   That was four or five times the normal complement , so the
     6        normal complement would be then something like 30 or 40?
     7        A.  Yes.
     8
     9   Q.   Or 35 to 40?
    10        A.  I would say somewhere between 40 and 60 at that time
    11        probably, but -- boy -- I am stretching my ability right
    12        now on how you would schedule that store, because I have
    13        not operated a store with that many employees.
    14
    15   MS. STEEL:   Why do they have so many people on their books in
    16        Mexico?  Do they like paying out extra wages, why do they
    17        need so many ------
    18
    19   MR. JUSTICE BELL:  Do they pay extra wages unless they are
    20        working?
         A.  No, my Lord.
    22
    23   MS. STEEL:  So they just have them all on the books and they
    24        would do less hours than would be the case in America?
    25        A.  No, I have already indicated, it would be similar hours
    26        as in the United States.
    27
    28   Q.   Right.  So they must be paying more people to work those
    29        similar hours?
    30        A.  No.  I was talking that the average in general is what
    31        I would expect , average number of hours a crew person
    32        would work would be about the same in Mexico.
    33
    34   Q.   So are the labour costs a lot higher in Mexico?
    35
    36   MR. JUSTICE BELL:  I am sorry, could you start again ---
    37
    38   MS. STEEL:  Percentage-wise?
    39
    40   MR. JUSTICE BELL:  -- because I am not following how this is
         different to the United States?  Here we are in Mexico;
    42        Mr. Stein has admitted to some guesswork so I am not going
    43        to hold him to it precisely as he says to move the matter
    44        on, in other words, to try to help and keep the evidence
    45        moving along, he thinks that the complement for the store
    46        would be about 125 to 150.  He thinks that a normal working
    47        crew at any given time would be between 40 and 60.
    48
    49        You are assuming that is different to the US, it may be,
    50        but I do not know that, so you had better establish for my 
    51        benefit what would be the normal equivalent for this in a 
    52        United States store. 
    53
    54        (To the witness):  Do you know the stores in the States
    55        which have a complement of about 125 to 150 on their books
    56        working fairly regularly?
    57        A.  There would be a few stores like that, my Lord.
    58
    59   Q.   What would be a normal crew at any given time in such a
    60        store in the States?