Day 153 - 12 Jul 95 - Page 14


     
     1   MR. RAMPTON:  My Lord -----
     2
     3   MR. MORRIS:  --- on that occasion, into the store -- I cannot
     4        find the reference now -- it came out into the back room.
     5        Is that correct?
     6        A.  Initially, yes.
     7
     8   Q.   The back room is a food preparation area, is it not?
     9        A.  No.  It is a cleaning area.
    10
    11   Q.   There was some food preparation going on there, was there
    12        not; salad was sliced in there?
    13        A.  Salad was sliced?  I do not believe we sliced any
    14        salad.
    15
    16   Q.   Tomatoes?
    17        A.  Tomatoes?  I do not remember tomatoes being, or that
    18        were used at that time.
    19
    20   Q.   For the McBLT, for example?
    21        A.  We would have used tomatoes for that, yes.  That was a
    22        test; that was only done as a test and was only in the
    23        restaurant for two or three months.  Generally, tomatoes
    24        would not have been sliced in the back room; they would
    25        have been sliced in the kitchen area.
    26
    27   Q.   What about the chips being basketed in that area?
    28        A.  That was away from that area.  It was not specifically
    29        where the water was coming up.
    30
    31   Q.   They were in the back room, but in a different part of the
    32        back room; is that what you are saying?
    33        A.  That is right.
    34
    35   Q.   So the back room was, to some extent, a food preparation
    36        area?
    37        A.  The fries were wrapped in one corner of the back room.
    38        The area where the water came up was not a food prep area.
    39
    40   Q.   Moving on through your statement -- just one second,
    41        sorry -- in your point 13, it says:  "All crew members were
    42        occasionally asked to work extra hours."  Then you give an
    43        example.
    44        A.  Yes.
    45
    46   Q.   Do you agree with that, yes?
    47        A.  Yes -- occasionally.
    48
    49   Q.   Halfway down that paragraph, you say about people being
    50        asked to work all night in order to clean the store on rare 
    51        occasions.  Then you say:  "However, none of these 
    52        situations was particularly common, and nobody, to my 
    53        knowledge, was forced to come in when they were not
    54        scheduled or forced to work extra hours."  Do you agree
    55        with that?
    56        A.  Yes.
    57
    58   Q.   You were not in the restaurant night and day, were you?
    59        A.  No.
    60

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