Day 145 - 29 Jun 95 - Page 37


     
     1        anecdotal evidence on the number of people that come back,
     2        do you remember that?
     3        A.  Yes, it would be on my being in stores reviewing
     4        files.  I do not know if I got into all of that detail.
     5
     6   Q.   Then when I asked you -- I have forgotten when it was now;
     7        I think it was this morning -- some matter that was related
     8        to anecdotal recollection -- I cannot remember what it was;
     9        it might have been reasons for leaving or whatever -- you
    10        said that your experience was each store is different, each
    11        region is different, each person's individual experience is
    12        different, therefore, you could not possibly give -----
    13        A.  It is really hard -- you are asking me to give you a
    14        conclusion and I cannot often times because there is a
    15        great deal of variation.  There are 10,000 restaurants
    16        throughout the United States.
    17
    18   Q.   OK.  We will leave that then.  We are just checking.  There
    19        was one thing I wanted to clarify, Mr. Stein:  You talked
    20        about 12 years ago you said courts began to oppose the
    21        rights of employers to end people's employment unless the
    22        contract of employment was an at will contract.
    23
    24   MR. JUSTICE BELL:  From what I understand of it, there was a
    25        ruling I assume, of some superior court, or a series of
    26        rulings, which left the law in a state where an employee's
    27        employment could not be terminated without it amounting to
    28        a breach of contract unless the contract had some provision
    29        providing termination?
    30        A.  That is correct, my Lord.
    31
    32   MR. MORRIS:  Yes, but, of course, employees could have their
    33        employment ended if, presumably, for any number of reasons
    34        that were acceptable to the court, for example, continued
    35        lateness or -----
    36        A.  Generally, the standard that you are pushed to in the
    37        US is showing just cause.
    38
    39   Q.   You would have to show just cause?
    40        A.  That is correct.  Generally, that is the standard
    41        because they will allege, the employees will allege, things
    42        that are protected under the law, and you need to show just
    43        cause, otherwise it will be presumed it was for something
    44        that is prohibited by law.
    45
    46   Q.   So if employers want to terminate people's employment
    47        unjustly, they can do so as long as they have an at will
    48        part of their contract?
    49        A.  Non sequitur -- absolutely not.  You cannot do that.
    50 
    51   Q.   Employees could leave before this at will contract? 
    52        Employees were able to leave, were they not, if they gave 
    53        notice or whatever?
    54        A.  They can leave -----
    55
    56   Q.   They were not slave bound to their employment for the rest
    57        of their lives, were they?
    58        A.  Before or after this employment at will, they can leave
    59        at any time they want to for whatever reason they want to,
    60        unless there is an express contract in writing saying, no,

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