Day 152 - 11 Jul 95 - Page 17


     
     1        looking at the right number here, was take the column 730
     2        all the way down to the 1.00 till 2 o'clock in the
     3        morning.  So that is Monday to Thursday three till the
     4        number four.  If you add all those up and multiply by four
     5        for the four days, do the same thing for columns Friday,
     6        Saturday and Sunday.  You then add up my full-timers extra
     7        to these crew station requirements at 39; my part-timers,
     8        and I believe that I came out with a £2 average rate which,
     9        I believe, was in operation at the time, and my volume, a
    10        labour per cent of about just under 15 per cent, which
    11        would suggest that I am pretty much on target with the way
    12        I recollect these figures.  But those are my numbers.
    13
    14        That would certainly be the way I would check it initially
    15        with a Supervisor or with a Restaurant Manager.
    16
    17   Q.   Having made allowances for the 100 people, for the 13
    18        people on the payroll who were not just crew, that were
    19        cleaners, security, maintenance men, etc., I made
    20        allowances for those when I made these calculations?
    21        A.  Right.
    22
    23   Q.   There would be only 175 hours left for distributing between
    24        the part-time employees?
    25        A.  Assuming, sorry, 20 hours?
    26
    27   Q.   Assuming 39 hours for the full-timers?
    28        A.  But how many hours are you assuming for the part-timers
    29        then?
    30
    31   Q.   No, I am saying there is 175 hours left to be shared
    32        between the part-timers?
    33        A.  Yes, sorry.  But, as I mentioned earlier on, the
    34        vagaries of people's availability makes it impossible to
    35        carry out such basic calculations retrospectively.  In
    36        order for me to get an appreciation of whether or not the
    37        number a restaurant had on their payroll was accurate, this
    38        was the way that I would look at it and then, from my
    39        recollection, adding the hours and the average rate at the
    40        time of, again, two to two pounds ten (I think that was the
    41        basic rate, not the rate that may have been in operation at
    42        the restaurant at the time given pay reviews) I came at a
    43        figure of about 15 per cent, which would suggest to me that
    44        these figures were fairly accurate.  But I do not know if
    45        somebody was only available ten till 2 or was available
    46        from whatever periods of time to suggest that the 39 and
    47        then how many hours are left over is going to start to
    48        paint a distorted picture, if you forgive me for saying
    49        that.
    50 
    51   MR. JUSTICE BELL:  But is Ms. Steel not right that you start 
    52        from the premise that you have 26 people - forget Christmas 
    53        and any extra there.
    54        A.  Right.
    55
    56   Q.   Just suppose that for the whole of the year you are working
    57        these hours.  Ms. Steel says the hours add up altogether to
    58        1,170 hours.
    59
    60   MS. STEEL:  It is 89 for the 19 that he added this morning.

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