Day 145 - 29 Jun 95 - Page 16
1 MR. JUSTICE BELL: I think Mr. Rampton's point is it is too
2 obvious to ask, but just give an answer to it, Mr. Stein.
3
4 MS. STEEL: I would like him to answer it.
5
6 MR. JUSTICE BELL: I cannot see what the difficulty in answering
7 it, really, for the very reason that Mr. Rampton has given.
8
9 THE WITNESS: My Lord, I am not trying to be difficult. The
10 answer I am giving is if, in fact, a marketplace were to
11 reflect -----
12
13 MR. JUSTICE BELL: But do you know of anywhere, have you heard
14 of anywhere, where someone would start as a crew member at
15 $10 an hour. I mean, maybe they do, maybe they do not, but
16 do you know whether they do anywhere?
17 A. I am aware in some operator stores of $8 and $9 an
18 hour.
19
20 Q. Is that starting or what?
21 A. That would be starting, my Lord.
22
23 MS. STEEL: In 1989/90 the average hourly rate that you were
24 paying was $4.64 for 89 and $4.88 for 1990. At that time
25 would you have been interested in taking crew on at $8 or
26 $9 an hour starting rate?
27 A. The market -- I am not trying to be difficult -- the
28 marketplace, you are asking me for -- you are asking a
29 general question.
30
31 Q. At double the rate that you were paying on average?
32 A. You are asking me a general question and you are
33 looking for a general response. We have over 200 million
34 people in the United States, we have over 50 states, we
35 have nearly 10,000 McDonald's restaurants. You are asking
36 me very general questions about -- areas in the country
37 differs considerably from one area to another. So I am
38 having difficulty answering general questions.
39
40 Q. Do they vary that much?
41 A. They will vary to some degree, yes.
42
43 Q. To virtually double the rate?
44 A. No, I do not think they usually would be double, but
45 they will vary, and you are trying to ask me to answer
46 general questions, and I have tried to be more precise in
47 my answers, perhaps because of my training, but I do not
48 like to answer general questions where I know there are
49 exceptions and there are differences; it is just not very
50 fair.
51
52 Q. Mr. Stein, if you had two workers, one prepared to work for
53 one dollar less than the other and they both had the same
54 experience and references, you would employ the cheaper
55 one, would you not?
56 A. Absolutely not. We would employ what the surveys
57 show. We are not going to take advantage of people. That
58 would be silly. That would take advantage of people. That
59 would cause problems within the restaurant. That is not
60 how a responsible business conducts itself.
