Day 145 - 29 Jun 95 - Page 36

     
     1        foggiest.
     2
     3   Q.   No, in the USA.
     4        A.  In the US?
     5
     6   MR. JUSTICE BELL:  If you really do not know, please do not
     7        hesitate to say so.
     8        A.  I do not know, my Lord.
     9
    10   MS. STEEL:  OK.
    11
    12   MR. MORRIS:  I think it is not Mr. Stein's fault maybe because
    13        he has been portrayed as the person who can deal with all
    14        employment matters in the US from the time we started the
    15        case, so it is just .....
    16
    17   MR. JUSTICE BELL:  No, I am not criticising Ms. Steel for asking
    18        the question.  There is no shame in not knowing an answer.
    19        If you are to be criticised for not knowing an answer, then
    20        Ms. Steel or Mr. Morris will ask you a further question
         about it and suggest that you should know it.
    22
    23   MR. MORRIS (To the witness):  The figures given by, I think,
    24        Mr. Rampton regarding the age range of McDonald's
    25        employees; the London Greenpeace fact sheet says something
    26        like three quarters are under 21, something like that.
    27        I cannot remember the exact phrase -- it does not rally
    28        matter -- the important thing is that when you were asked
    29        you were asked to say what percentage were 19 or less.
    30        A.  That is correct.
    31
    32   Q.   You said 48 per cent?
    33        A.  That would be accurate.
    34
    35   Q.   Yes, the pertinent question is -- what percentage are 20 or
    36        less?
    37        A.  I would not know that.  The way we keep statistics in
    38        the US is I want to know how many teenagers we have and how
    39        many are beyond the teenage level.  That is the way we keep
    40        the statistics.
    41
    42   Q.   You said there are no records on people, how often they
    43        return to McDonald's after they have left or what
    44        percentage of staff return and when they return?
    45        A.  I think I indicated to you that there would be files in
    46        the stores ---
    47
    48   Q.   Yes.
    49        A.  -- that would show that but I would not have anything
    50        on a computer that would show that. 
    51 
    52   Q.   All right, so that information is not available to you --- 
    53        A.  No.
    54
    55   Q.   -- by snapping your finger?
    56        A.  Or by doing a lot of work it is not available to me,
    57        unless I go to stores.
    58
    59   Q.   You said in your examination-in-chief when you gave some
    60        evidence on that, I believe, that your opinion was based on