Day 116 - 26 Apr 95 - Page 04
1 MR. JUSTICE BELL: Was that copy for Mrs. Brinley-Codd or for
2 me?
3
4 MR. MORRIS: That was for you.
5
6 MR. RAMPTON: By all means, let your Lordship have it. I am
7 quite sure I have it; whether I have the enclosures is
8 another question, but if I have not I will moan about it.
9
10 MR. MORRIS: They were all served at the time and looked at in
11 court; it is just that someone may have lost their copy or
12 something.
13
14 MR. JUSTICE BELL: I will file that away in due course.
15
16 MR. RAMPTON: My Lord, all I would say about the employment
17 witnesses is this: In view of that response, it is a topic
18 to which I should wish to return in due course, after
19 Mr. Nicholson has given his evidence ---
20
21 MR. JUSTICE BELL: Yes.
22
23 MR. RAMPTON: -- for reasons which will be obvious to your
24 Lordship.
25
26 The other things are these: I have some documents to hand
27 in. The first is an update of the lavender diary.
28 (Handed) My Lord, what we have done -- also the
29 Defendants have this -- is to copy the employment section
30 of the Abstract which is tab 7, and number each of the
31 passages. I think it goes to 116. It will make it a lot
32 easier as we go through this part of case in the future.
33
34 My Lord, the next thing is we have prepared a hierarchy, a
35 chart, showing the hierarchy at McDonald's so far as
36 salaried and hourly paid staff are concerned.
37 Mr. Nicholson will explain that in a moment. Then there
38 are some tables (and Mr. Nicholson will explain where they
39 come from) showing the percentages of crew promoted to
40 salaried management positions in 1988 and 1989. The 1989
41 document is a one page document; the 1988 document is a
42 two-page document.
43
44 Then, my Lord, next a single sheet showing the percentage
45 of labour costs for each category, crew and management,
46 holiday and payroll taxes for, I think it is, a period in
47 1993. It may be for the whole of 1992. Again, I will ask
48 Mr. Nicholson to explain it.
49
50 Finally -- this does not relate to the evidence of
51 Mr. Nicholson but I have it now so I will, if I may, hand
52 it in -- the update on the Second Plaintiff's analysis or
53 monitoring of the ethnic origins of their workforce. There
54 is already in the file some earlier material. This Lyn
55 Mead will deal with. This is an update for the second and
56 fourth quarters of 1994. Your Lordship does not need to
57 worry about that at the moment. That is for the future.
58
59 My Lord, can I ask your Lordship to keep what I call the
60 Nicholson documents by for the moment, because their
