Day 152 - 11 Jul 95 - Page 06


     
     1        A.  Right.  These are part-timers.  Three cleaners would
     2        generally come in 7.00 till about 10.00 maybe.
     3
     4   Q.   Are they not crew then?
     5        A.  In terms of payroll, they are on the payroll as
     6        part-time employees but in terms of people working crew
     7        stations, no, they would not be.
     8
     9   Q.   No, but you said three people came in in the mornings to
    10        open up and get ready for the -----
    11        A.  That is why, sorry, again yesterday I did make sure
    12        that you did mean people working crew stations.  I think
    13        I may have asked two or three times just to make sure I had
    14        it correct.
    15
    16   Q.   I am just checking.  Are you saying there were three crew
    17        working on the crew stations when the store was not open?
    18
    19   MR. JUSTICE BELL:  Can we do it more quickly than that?
    20
    21   MS. STEEL:  Plus three cleaners.
    22
    23   MR. JUSTICE BELL:  The people that Ms. Steel put on her schedule
    24        which was based, she said, on the evidence which you gave
    25        and which you varied to a small extent, if you look at
    26        that, were they all people on crew stations as opposed to
    27        cleaners and people of that kind?
    28        A.  Well, the restaurant would not be open as such but
    29        certainly in terms of preparing the restaurant for
    30        business, setting up the -- reassembling the kitchen.
    31
    32   Q.   Just look at the figures on Ms. Steel's schedule.  Assume
    33        for the moment that it reflects the evidence you gave?
    34        A.  Yes, sir.
    35
    36   Q.   Are they all on crew stations as opposed to being cleaners
    37        or security?
    38        A.  Yes, they are.  They are on crew stations, certainly.
    39
    40   Q.   So you have not, in those figures which Ms. Steel has
    41        reduced to a helpful schedule, included any cleaners or
    42        security or anything of that kind?
    43        A.  Oh, no.
    44
    45   MS. STEEL:  So there are those cleaners working from 7.00 to
    46        10.00 a.m.; is that every day of the week?
    47        A.  No, I think we probably have, again they would be
    48        available maybe a couple of mornings.
    49
    50   Q.   Two mornings a week? 
    51        A.  Perhaps. 
    52 
    53   Q.   Perhaps?  So they are not always ------
    54        A.  I am afraid my memory does not go back that far, but
    55        I can remember probably two morning cleaners.
    56
    57   Q.   And the security -- sorry, was it two security?
    58        A.  I can take you through it, if you wish?
    59
    60   Q.   Was it two security?

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