Day 144 - 28 Jun 95 - Page 53


     
     1   MR. MORRIS:  Actually, it was 22.91 per cent.  So your continual
     2        reference to people going back to school and college is
     3        just a smoke screen for the fact that the vast majority of
     4        employees in America are leaving because they are
     5        dissatisfied with the conditions?
     6        A.  Totally wrong.  You are using an English example to say
     7        what goes on in America.  I believe that I had heard some
     8        conversation that the American system, apparently, is a
     9        little bit different, and that is that in England
    10        apparently -- I am not an expert -- the government,
    11        apparently, pays for folks to go to university.  In the US
    12        it is funded personally by the individuals.  Therefore, the
    13        individuals in the US tend to need jobs more who are going
    14        to university.  So, this idea of a smoke screen is
    15        absolutely ridiculous.
    16
    17   Q.   I can read out a section -- I do not think the witness
    18        needs to see it but if he wants to he can, or if
    19        Mr. Rampton wants to, he can -- document 93, it is one of
    20        the Philadelphia documents, but you may just agree with it
    21        rather than get the document out.
    22        A.  I have already seen that you take bits and pieces out
    23        of documents so I would prefer to see the entire document.
    24
    25   Q.   It saves me getting you to read a five page document if I
    26        just refer you to the relevant section.
    27
    28   MR. JUSTICE BELL:  No, let us look at the document.  Give the
    29        reference; it is just safer.
    30
    31   MR. MORRIS:  Let me ask him if he agrees with it.  If he
    32        disagrees with it, then he will have to look at it.  Under
    33        "Employment Opportunities" ------
    34
    35   MR. JUSTICE BELL:  No, I want the witness to see the document.
    36
    37   MR. RAMPTON:  So do I .
    38
    39   MR. JUSTICE BELL:  It is safer for you and it is safer for the
    40        witness.  Can you give the reference?
    41
    42   MR. MORRIS:  It is bundle XIV, tab 93.
    43        A.  That is pink XIV?  I have the document.
    44
    45   Q.   In the second page of the document it says at the top of
    46        the page:  "Employees receive frequent raises based on
    47        performance.  Many new employees receive a raise as soon as
    48        three months after starting."  So, is that the general
    49        picture in the United States, that some time after three
    50        months after starting they would get a raise if they passed 
    51        a performance review? 
    52        A.  You are talking specifically here of Philadelphia? 
    53
    54   Q.   No, this is a general -----
    55        A.  This is Philadelphia.
    56
    57   MR. RAMPTON:  No, this is a Philadelphia document.
    58        A.  This is Philadelphia.  These are primarily and
    59        predominantly owner/operator stores.
    60

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