Day 144 - 28 Jun 95 - Page 41


     
     1
     2   MR. MORRIS:  Let us quickly go through this before the lunch
     3        break.  I put the same question to you that I put to Jill
     4        Barnes.
     5        A.  To who?
     6
     7   Q.   To a previous witness.
     8        A.  OK.
     9
    10   Q.   Which is why did you not put in there:  "Pay:  I do not get
    11        enough" or "I do get enough"?
    12        A.  Listen, this thing is done by people who have far more
    13        understanding of it, far more knowledge, than we do.  These
    14        are the questions that they think will elicit the kinds of
    15        responses to help steer us on what we should be doing from
    16        a Human Resource standpoint.  Do not ask me to start
    17        substituting my judgment for people who I think know far
    18        better than I do.
    19
    20   MS. STEEL:  Mr. Stein, if you consider that everybody wants more
    21        pay, why is there this useless question in there which is
    22        not going to provide you with any information?
    23        A.  Because you want to get a relative idea of the
    24        question.
    25
    26   Q.   So you do think it is a useful question?
    27        A.  It would not be in here if it was not useful, but what
    28        it does is it highlights certain things or it draws your
    29        attention to certain things, and you compare it to other
    30        things and you try to make sense of it.  You hold -- after
    31        you do this, you hold some rap sessions, you hold some crew
    32        meetings, you have other communication processes with your
    33        people.  You have lots of discussions to try to really get
    34        at what is most important to them that they would like to
    35        see different.
    36
    37   Q.   But you do not put the pay up?
    38        A.  I have already testified concerning pay and how we
    39        proceed with pay.  I have done that I think at least on two
    40        occasions, maybe three occasions.  That is just a question
    41        that is so ---
    42
    43   Q.   You could just answer "no"?
    44        A.  -- ubiquitous.  Excuse me?
    45
    46   Q.   You could just answer "no" or "yes" if you really believe
    47        that you do put the pay up after you get a response like
    48        that?
    49        A.  I am saying to you ------
    50 
    51   MR. JUSTICE BELL:  I did not understand that that is what you 
    52        were getting at, so maybe Mr. Stein did not anyway.  What 
    53        you are being asked is would not a skilled survey revealing
    54        that the norm throughout McDonald's was that two out of
    55        five people thought that their pay increases were about
    56        what they expected, the inference I have drawn being that
    57        the balance of the remainder either did not know one way or
    58        the other or thought that it was less than they expected,
    59        as opposed to more than they expected, is that, in your
    60        view, a reason for putting pay up generally?

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