Day 148 - 05 Jul 95 - Page 22
1 that information by going to individual stores and I do and
2 taking a look at it."
3 Those are termination reasons. So it does not strike -----
4
5 MR. MORRIS: That would reinforce my view.
6
7 MR. RAMPTON: No, my Lord, may I finish? It does not ring any
8 bells that he ever said anything which would suggest that
9 they keep individual records for length of stay, save in a
10 personnel file, which they might well do.
11
12 MR. JUSTICE BELL: Thank you for the reference. If anyone finds
13 any other references, I would be grateful if they would
14 give them to me and I will look them up.
15
16 MR. MORRIS: It does seem to me that reference certainly
17 indicates that each store has some record of reasons for
18 leaving, not in individual personnel files but as a store.
19 Whether that indicates the length of time as well, we know
20 that the Company in its Operations Manual evaluates the
21 reasons for leaving given by employees.
22
23 So, it implies there is some kind of store monitoring of
24 reasons for leaving, and we believe Mr. Beavers can only be
25 referring to that kind of information on a store level. He
26 was implying it was Company level, but certainly store
27 level for length of stay as well.
28
29 So I think that, in the light of that, maybe the easiest
30 thing would be to say if that could be done for, say,
31 Company owned stores in the Chicago area. I do not know if
32 Chicago is a highly franchised area or a highly McOpco
33 area, but I personally do not think it makes any difference
34 but, just to save argument on that, McOpco stores in the
35 Chicago area.
36
37 Of course, if that exercise was done, then McDonald's would
38 themselves benefit from it if they had not got that
39 information in any other easily available form.
40
41 MR. JUSTICE BELL: Unless you have more to add in relation to
42 that, your other item of discovery on 4 is pesticide and
43 hormone residue documents referred to by Dr. Gomez Gonzales
44 ---
45
46 MR. MORRIS: Yes.
47
48 MR. JUSTICE BELL: -- which, I assume, tell me if I am wrong,
49 depends upon you getting leave to amend in relation to
50 pesticide and hormones, which is a matter which you want to
51 leave over for the moment.
52
53 MR. MORRIS: I do not see why the disclosure should be reliant
54 on a specific pleading because evidence has already been
55 given by McDonald's own witness, and it is obviously a
56 matter that is relevant. It is a direct reference in the
57 London Greenpeace fact sheet to pesticides and hormones,
58 and Dr. Gomez Gonzales was asked, well, he gave evidence on
59 day 92.
60
