Day 134 - 13 Jun 95 - Page 05


     
     1        Earnings Survey, particularly, but you may think that you
     2        would serve yourself just as well waiting until you have
     3        had time to digest anything in that New Earnings Survey or
     4        a later one, be it the 1989 or 1990 one, for instance, on
     5        the basis that you can be pretty confident that since
     6        McDonald's have put in figures from that, assuming that
     7        I am entitled to consider them, you can put in figures, any
     8        other figures, from there or figures from any later
     9        surveys, New Earnings Surveys, if you choose, without any
    10        comment from Mr. Rampton, including, if you chose, things
    11        like average manual earnings were across the board, not
    12        just restricted to catering, if you thought you could make
    13        some comment useful to your case based on that.
    14
    15        So I do suggest you restrict your cross-examination of
    16        Ms. Mead to things she can really speak to from her own
    17        experience, and I suggest that you can do that without
    18        losing anything in this case.
    19
    20             Cross-examined by the Defendants, continued.
    21
    22   MS. STEEL:   You have had responsibility for personnel areas for
    23        a considerable time now, have you not?
    24        A.  Yes.
    25
    26   Q.   What kind of records are kept on crew at the stores?
    27        A.  In what sort of areas, when you say "records"?
    28
    29   Q.   Is there like a file for each crew member?
    30        A.  Yes, there is for each current employee, yes, that is
    31        right.
    32
    33   Q.   What information would be kept within that file?
    34        A.  That would contain the application form, the letter of
    35        employment.  It would contain with regard to the training
    36        area certain ongoing pieces of information which would not
    37        necessarily be retained forever.  They would be things that
    38        were the up-to-date information about observation check
    39        lists and the tests and so on; a variety of those things,
    40        the performance reviews, any disciplinary warnings, any
    41        other perhaps relevant things like letters and so on that
    42        they might have written to the Manager or vice versa.
    43
    44   Q.   Right.
    45        A.  From recollection, that sort of covers it, I think.
    46
    47   Q.   When they leave do you add to that the reasons for their
    48        leaving?
    49        A.  There is a section inside the application form where
    50        the reasons for leaving is recorded and the date and so on. 
    51 
    52   Q.   When a person has left what happens to those records? 
    53        A.  What usually happens is that the principal information
    54        like the application form and the letter and, well, the
    55        disciplinary warnings would remain as well, and any other
    56        sort of things relating to the disciplinary action would be
    57        retained.  The rest of the information would then be
    58        discarded and the files would be retained somewhere.  Now,
    59        because we have differing sizes of restaurants and so on,
    60        where they are retained does differ.

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