Day 163 - 25 Sep 95 - Page 24
1 that? McDonald's is not going to have any documentation
2 which shows it to be one of the four largest violators,
3 does it? It would have to have documentation which proved
4 the numbers of violations by all the fast-food firms, so
5 that from that you could say it was one of the top four,
6 quite apart from any answer Mr. Stein may have given.
7
8 MR. MORRIS: I think on this general point that there will be
9 documents associated with that hearing which Mr. Stein
10 attended, which will probably explain why those four were
11 invited to give evidence or to speak at that hearing,
12 probably identifying them as the four largest violators
13 nationwide of child labour laws which is what the hearing
14 was about.
15
16 Mr. Stein, from my memory, went on to say something about
17 that there had never been any child labour violations since
18 the Pennsylvania 466 McKale Management ones, I think.
19 I think he said that there was none since then and never
20 any of McDonald's directly controlled stores. So we then
21 move on from the general picture to the specifics in our
22 particulars in the pleadings which -- shall I move on to
23 No. 3?
24
25 MR. JUSTICE BELL: You have just dealt with (3).
26
27 MR. MORRIS: I just dealt with the introduction. That was not
28 the Illinois one. This was just the general position
29 justifying that introduction.
30
31 MR. JUSTICE BELL: Yes, I have put No. 3 against the 1990
32 Illinois Department of Labour.
33
34 MR. MORRIS: That is right, but what I was just referring to was
35 the one that has not got a number on it, the McDonald's
36 stores in the USA, which is a general introduction to the
37 following particulars. Just to justify that general
38 introduction, I referred to McDonald's being identified as
39 one of the four largest violators nationwide. Then I was
40 going to -----
41
42 MR. JUSTICE BELL: I thought you had justified that introductory
43 paragraph by the particulars which come thereafter.
44
45 MR. MORRIS: Yes.
46
47 MR. JUSTICE BELL: You have, for example -----
48
49 MR. MORRIS: Yes, these following ones are examples, but the
50 whole picture includes the fact they have been identified
51 by the House Subcommittees as one of the four largest
52 violators nationwide as well. Then I will come on to a
53 specific about Illinois.
54
55 If I can just go back to that last point, that the
56 committee or the government or the relevant department
57 obviously has compiled some kind of statistics or
58 monitoring system for violations of child labour laws. It
59 must be that if McDonald's were invited to attend the
60 committee hearing that such information would have been
