Day 213 - 31 01 96 - Page 42

 
 

                                                                  DAY 213
 
                                            SEMIR KHAZNA, Cross-examined:
 
 
 
     1   Q.   It did not?
     2        A.  No, because the labour percentage -- because they were
     3        on the Heathrow payroll at the time, the labour percentage
     4        of Heathrow actually went up.
     5
     6   Q.   Leaving aside totally the Feltham workers, can you tell me
     7        at what level you would consider -- what number of hourly
     8        paid employees on the payroll you would consider to be
     9        grossly understaffed?
    10        A.  At the Heathrow branch?
    11
    12   Q.   Yes.
    13        A.  On my evaluation of the store, anything below 120, 130,
    14        would have been understaffed for that restaurant.  But, as
    15        I said in my statement, we needed approximately 160 people
    16        for that restaurant.
    17
    18   Q.   Anything under 120 to 130 hourly paid employees you would
    19        consider grossly understaffed?
    20
    21   MR. JUSTICE BELL:  No.  I particularly noted it.  You certainly
    22        asked that question, but he answered it in different
    23        terms.  He did not put "grossly" in his answer.  If you
    24        want to pursue it, then do.
    25
    26        If I might say so, if one uses a word like "grossly" -- and
    27        I am not criticising you for it, but people have different
    28        views of what it means.  If you asked, having got the
    29        figure which you have just got, that anything between 120
    30        and 130 would have been understaffed, and if you want to
    31        ask a question in ordinary lay language such as: "At what
    32        level would you be in real trouble running the restaurant",
    33        find what that is, and you have your bracket.
    34
    35   MS. STEEL:  (To the witness)  Can I just clarify?  When you
    36        answered my question, although you did not use the word
    37        "grossly", would you consider 120 to 130 hourly paid staff
    38        on the payroll to be either grossly or very understaffed?
    39        A.  Not very.  I would say it is sufficient, but in my
    40        evaluation ---
    41
    42   Q.   It is understaffed?
    43        A.  I would -- no, not understaffed.
    44
    45   Q.   You did say "understaffed".  At what level would you say
    46        that the store was grossly or very understaffed?
    47        A.  Anything below the levels I have said, which is, if it
    48        started going any below the 130, 120 mark, it was
    49        understaffed.
    50 
    51   MR. JUSTICE BELL:  I am sorry.  I think we really have reach a 
    52        stalemate.  Since I am the person who ultimately needs to 
    53        know, let me ask you questions in my own terms, and then
    54        Ms. Steel will come back to it.  You are understaffed if
    55        you are anything below 120 or 130?
    56        A.  That is correct.
    57
    58   Q.   If you were the Store Manager, at what level of crew
    59        numbers would you think you would have real trouble running
    60        the store?
 
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