Day 074 - 16 Jan 95 - Page 08

     
     1        sidewalks" by which they mean pavements, "landscaping, and
     2        street gutters for a distance of", and then we go into
     3        heavy italics "at least one block in every direction of the
     4        store", do you see that?
     5        A.  Yes, sir, I do.
     6
     7   Q.   So far as you are concerned in your time as manager twice
     8        and licensee, have you carried out that direction or not?
     9        A.  Yes, sir, every day.
    10
    11   Q.   Are there circumstances in which for one reason or another
    12        the trash walk may not take place every 30 minutes exactly?
    13        A.  Yes, if it is raining heavily or if it is snowing or
    14        the weather is bad or if it is extremely busy, sometimes it
    15        does happen that a group of either tourists or students,
    16        they come in.  So, although the intention has always been
    17        there, but sometimes there have been occasion where there
    18        was instead of half an hour it has taken slightly longer.
    19
    20   Q.   I am going to ask you to look at a map in a moment.  Can I
         just ask you this, during all your time as a manager and a
    22        licensee, have you felt any pressure to preserve or improve
    23        your profitability or your turnover by cutting down on
    24        trash walks?
    25        A.  No, sir, never because profitability is not based on a
    26        trash walk; it is to build sales through high quality,
    27        service and cleanliness, customer care and intensive
    28        community relationship.
    29
    30   Q.   So, are the trash walks a feature, an element, in your
    31        profitability?
    32        A.  No, it is not.  But a trash walk we perform not only to
    33        clean the environment but to have a very good relationship
    34        with the community we live in.
    35
    36   Q.   We notice if we look at the observation check list -- it is
    37        in the other file, I am sorry, at tab 7 -- that No. 14, the
    38        trash walk, gets a possible score of four points; do you
    39        see that?
    40        A.  Sorry?
    41
    42   Q.   The observation check, the OCL, behind Mr. Stump's
    43        statement?
    44        A.  Yes.
    45
    46   MR. JUSTICE BELL:  The one you were looking at a moment ago.
    47
    48   MR. RAMPTON:  It should be in that yellow file at tab 7.
    49        A.  Yes.
    50 
    51   Q.   Item 14 is the trash walk.  We see it gets a score of four 
    52        points? 
    53        A.  Yes, sir.
    54
    55   Q.   Which is the next highest after, for example, keeping the
    56        fire exits free of obstruction; do you see that?
    57        A.  Yes.
    58
    59   Q.   In your view as a manager, former manager, and a licensee,
    60        does the trash walk merit in terms of importance a score as