Day 152 - 11 Jul 95 - Page 13


     
     1        A.  Yes, sir, it was.
     2
     3   MR. MORRIS:  I am not going to pursue that line of question any
     4        more.
     5
     6   MS. STEEL:  I wanted to say something.  When I was putting it to
     7        the witness earlier, I actually said it would leave around
     8        210 working hours which, shared out between part-time
     9        employees, they would be lucky if they got eight hours each
    10        week.  I have two sets of figures on my page.  I read from
    11        the wrong set.  It would be -----
    12
    13   MR. JUSTICE BELL:  You have had some further information about
    14        part-timers anyway.  So if you want to start afresh on it
    15        and make your point, do so.
    16
    17   MS. STEEL:  I was just going to say, I should have said three
    18        hours each per week on the last occasion.  If we take off
    19        five full-time employees from the 100 and eight part-time,
    20        that would cover the people that you listed - one full-time
    21        Admin and four full-time Floor Managers and then the other
    22        eight were part-time, the cleaners, the security, the
    23        maintenance man ---
    24        A.  Yes. OK.
    25
    26   Q.   -- floor managers, which leaves 23 full-time crew per week?
    27        A.  No.  In terms of going back to this, the 14 and the 12
    28        is 28.  There would be a minimum.  Again, going back on
    29        this, if I needed 14 for the Friday lunch-time, 12 to 2.00,
    30        and 12 for the night shift -- and I am assuming obviously
    31        that the two days off are going to be Saturday, Sunday --
    32        I would need 28 people.
    33
    34   Q.   26?
    35        A.  Sorry, 26, 26 people to staff that.  So I would be
    36        looking for a minimum of 26 full-time crew.  If I was
    37        sitting down the first time with a Manager -----
    38
    39   MR. JUSTICE BELL:  It may be obvious but why full-time crew?
    40        A.  Because in terms of people's individual availabilities
    41        obviously can be varied, but in terms of sitting down with
    42        a Manager and planning our staffing requirements ---
    43
    44   Q.   Yes.
    45        A.  -- first of all, to get it fairly straightforward so
    46        that the Manager can understand.  One of the things I will
    47        assume is say Monday to Friday; let us just assume Monday
    48        to Friday we only have full-timers.  I know we are going to
    49        have part-timers who can work evenings and some full-timers
    50        who can work weekends.  That tends to get complicated. 
    51 
    52        But, to start off with, to give them a basic idea of what 
    53        they should be looking at, let us say Monday to Friday,
    54        those five days a week, 14 at lunch, 12 in the evening; so
    55        that would be 26 people on a full-time basis.  Then I would
    56        do the same thing with the weekend, and in this case 25, 12
    57        and 15 was my sort of 52.  So, if we were looking at these
    58        staffing levels, 26 and 52 would be our starting point.
    59
    60        Obviously, then, I would sit down with the Manager and see

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