Day 142 - 26 Jun 95 - Page 27

     
     1        workers will be above the general crew rate?
     2        A.  But there are also crew people because of length that
     3        they have been there and the number of raises they
     4        get  -----
     5
     6   MR. JUSTICE BELL:  No, that is not Mr. Morris' point.  He is not
     7        at the moment arguing with the average among those.  What
     8        he is saying, when you look at figures for average hourly
     9        rate, that does not tell you what the ordinary crew
    10        person's average hourly rate is because up to 10 out of the
    11        60 or 70 are in slightly elevated positions while still
    12        remaining hourly paid?
    13        A.  That is correct, my Lord.
    14
    15   MR. MORRIS:  As you say, some people are returners who will
    16        start at a higher rate?
    17        A.  Yes.
    18
    19   Q.   Then there is also on top of the federal minimum of $4.25
    20         -- a number of states have state minimums ---
         A.  There are states -----
    22
    23   Q.   -- on top of that?
    24        A.  There are states that have state minimums, yes, that
    25        could be above.
    26
    27   Q.   So, having heard all that and thought about it -- we do not
    28        have to work out the exact figures -- we can safely say
    29        that the average starting rate for a newly employed crew
    30        person must be at or near to within, I would have thought,
    31        something like 50 cents at the most the federal minimum
    32        wage?
    33        A.  You are asking me to do a lot of calculations,
    34        I think.  You have gone through an analysis.
    35
    36   MR. JUSTICE BELL:  I do not think you are being asked to do the
    37        calculation; if a calculation has to be done for the
    38        purpose of cross-examining you, it is incumbent upon
    39        Mr. Morris to do it, in my view.  But what is being put to
    40        you is this:  From 91 to 93 the federal minimum wage was
         $4.25 an hour; in some states it may have been higher than
    42        that because the state legislature imposed a minimum which
    43        is higher than federal minimum.
    44        A.  Mmm.
    45
    46   Q.   The mean between the lowest average of $4.96 and highest
    47        5.14 is, in fact, 5.05 an hour?
    48        A.  OK.
    49
    50   Q.   $5.5 an hour or thereabouts which is 80 cents above the 
    51        federal minimum? 
    52        A.  Mmm. 
    53
    54   Q.   If you take into account the fact that something like 15
    55        per cent of the hourly paid workers, or 10 or 15 per cent,
    56        are higher level -- trainee trainers or swing managers ---
    57        A.  Right.
    58
    59   Q.   -- if you take into account that of the other crew a decent
    60        proportion will have received enhancements from their