Day 148 - 05 Jul 95 - Page 20

     
     1        of what form it could be retrieved in.  Obviously, if they
     2        only have it on a local store level, the Plaintiffs might
     3        find it a little bit time consuming, considering all the
     4        other work they have to do as a multinational corporation
     5        to check all their stores, but they could do a selected
     6        section of stores.
     7
     8        Of course, we would be concerned that the selection would
     9        be favourable to them; therefore, some kind of arbitrary
    10        group of stores or a particular town could be chosen, such
    11        as stores in Inner Philadelphia, Inner City Philadelphia,
    12        which has arisen in the case already in some detail,
    13        although they may be franchise stores, in which case maybe
    14        the Company owned stores in Chicago might be most
    15        appropriate.
    16
    17   MR. JUSTICE BELL:  I remember Mr. Stein's evidence, but do you
    18        have the reference, the precise reference to it?
    19
    20   MR. RAMPTON:  My Lord, one reference is page 64, lines 37 to 58,
         on 28th June which was day 144 -- that is only one
    22        reference; there may be others -- Mr. Morris recited to
    23        Mr. Stein what Mr. Beavers had said and Mr. Stein, in
    24        effect, said that Mr. Beavers had got it wrong because it
    25        is not his.
    26
    27   MR. JUSTICE BELL:  Yes, I remember that very well.  The part
    28        I do not remember as well is Mr. Morris suggests that it
    29        would be available in local stores and if he said anything
    30        about what form it would take, because ---
    31
    32   MR. RAMPTON:  I have not got that.
    33
    34   MR. JUSTICE BELL:  -- there is probably all the world of
    35        difference between being able to look in the file of a crew
    36        member in the store and see when he started and when he
    37        ended, and a document in the store which was the store
    38        equivalent of the UK printout.
    39
    40   MR. RAMPTON:  I will not say anything until I have found the
         reference, but I rather suspect it is the former.
    42
    43   MR. MORRIS:  What day was Mr. Rampton referring to then?
    44
    45   MR. RAMPTON:  144, page 64, lines 37 to 58.
    46
    47   MR. MORRIS:  I do not believe Mr. Beavers being so confident
    48        about the information being available if it was only
    49        available in an individual file.  You asked Mr. Beavers --
    50        I just read it out before -- "Might they show what 
    51        proportion, if any, of the people employed by McDonald's 
    52        leave in the first week, in the first month, in the first 
    53        three months, in the first six months?"  He said:  "Yes, we
    54        could have information like that, yes", implying that it
    55        was not just a question of leafing through individual
    56        files, it was something which could be available.
    57
    58        I cannot find the reference to Mr. Stein on that subject.
    59        But even if he said something different from Mr. Beavers,
    60        there is no reason to think that Mr. Beavers cannot have an