Day 071 - 11 Jan 95 - Page 04

     
     1        Street and somewhat further to the west, Radnor Walk?
     2        A.  Yes.
     3
     4   Q.   To the east, as you said, on the corner is Royal Avenue and
     5        then something, I think, called Walpole Street and then
     6        Cheltenham Terrace.  Do I have that right?
     7        A.  Yes.
     8
     9   Q.   Along the bottom of which runs St. Leonard's Terrace?
    10        A.  Yes.
    11
    12   Q.   Yes?
    13        A.  Yes.
    14
    15   Q.   Mr. Stump, you have been in charge of a McDonald's
    16        restaurant in a fashionable part of London for 18 months,
    17        roughly speaking, have you not?
    18        A.  Yes, I have.
    19
    20   Q.   How busy, compared, for example, with your experience in
         the West End of London, Leicester Square, a restaurant is
    22        the Kings Road restaurant?
    23        A.  In relation to the West End of London which contains
    24        about 30 restaurants, we are about middle of the ground,
    25        middle ground.
    26
    27   Q.   Middle ground.  Do you have any basis with which you could
    28        compare the "busyness" of Kings Road with, for example, a
    29        McDonald's somewhere in a city outside London in the
    30        British Isles?
    31        A.  Yes, the comparison could be by either sales or by the
    32        customers that come into the restaurant, the customer
    33        "transcan", we call it.
    34
    35   Q.   You, of course, understand that you are here to deal with
    36        the question of environment/index.html">litter ---
    37        A.  Yes.
    38
    39   Q.   -- allegedly generated by McDonald's in the Kings Road.
    40        Which is the relevant standard for judging what might be a
         environment/index.html">litter problem?  Is it the number of sales or the number of
    42        people?
    43        A.  Well, the company set a standard which all restaurants
    44        would use as a guideline.  They would all use the same
    45        standards for the trash walk.
    46
    47   Q.   What standard is that?
    48        A.  We are trained as managers and as employees to complete
    49        a trash walk.
    50 
    51   Q.   No, sorry, I did not put my question very well.  If one is 
    52        trying to estimate what sort of a environment/index.html">litter problem a 
    53        particular store might be creating, does one look at the
    54        number of people or at the number of transactions?
    55        A.  We do not look at it, but I would say that we would
    56        look at "transcan".
    57
    58   Q.   I am asking you for your opinion from your experience as a
    59        manager.
    60        A.  From my opinion, it would be based on the amount of