Day 173 - 16 Oct 95 - Page 14

     
     1        is pink XIII B; it is one of the pink bundles.
     2
     3   MR. JUSTICE BELL:  On the top right shelf.  Thank you.
     4
     5   MR. MORRIS:  If you go to tab 59 -- I hope it will be the one
     6        I am looking for -- on page 990.  If you look at the bottom
     7        right-hand corner you have the page numbers.
     8        A.  Yes.
     9
    10   Q.   This is an affidavit.  If you look at the back on page 997,
    11        it is an affidavit you wrote on 3rd April, 1979, and you
    12        have signed it.  Yes?  It is 997.
    13        A.  Yes.  It is witnessed by a Commissioner for Oaths.
    14
    15   Q.   If you go back to page 990, paragraph 4, you say in that
    16        paragraph:  "I say and truly believe that the Plaintiff
    17        Company occupies and carries on business from two premises,
    18        the first of these being at 62 Upper O'Connell Street in
    19        the City of Dublin and the second at 9/10 Grafton Street in
    20        the City of Dublin, and the total employment of the
         Plaintiff Company is in excess of 150 persons."
    22
    23        You agree with all that, do you?
    24        A.  Yes, I would.
    25
    26   Q.   So the total employment of the Plaintiff Company -- when
    27        you say "in excess", what, do you mean something between
    28        150 and 160, but it fluctuates; is that what you mean?
    29        A.  Possibly, but I cannot -----
    30
    31   Q.   Something like that?
    32        A.  I cannot recollect.  This was a long time ago.
    33
    34   Q.   Right.  The total employment of the Plaintiff Company would
    35        have included, obviously, management.  Did that include --
    36        would that have included your business partner?
    37        A.  No, because he was not actively in the business.  He
    38        was a business partner, but he did not work in the
    39        business.
    40
    Q.   So it would have been anybody under you, effectively?
    42        A.  Yes -- working in the restaurants, I presume.
    43
    44   Q.   It says "total employment of the Plaintiff Company"; so
    45        that would have included any administrative staff you had
    46        at the time?
    47        A.  Possibly.  I am sure it did, but the administrative
    48        staff was very little at that particular point.
    49
    50   Q.   What was it, one or two people? 
    51        A.  Probably two or three. 
    52 
    53   Q.   Two or three.  Do you remember if you employed, for
    54        example, separate cleaners apart from crew at that time?
    55        A.  No, I do not recollect employing separate cleaners.
    56
    57   Q.   That is because you did not do it, or because you just do
    58        not remember?
    59        A.  I cannot recall exactly whether I did or I did not.
    60