Day 214 - 01 02 96 - Page 23

 
 

                                                                  DAY 214
 
                                                 DAVID ROBERTS, Examined:
 
 
 
     1   Q.   -- you would have to raise it after using ---
     2        A.  That is correct, yes.
     3
     4   Q.   -- it for sausage?
     5        A.  That is correct.
     6
     7   Q.   After breakfast, which -- when did breakfast stop?
     8        A.  11 a.m.
     9
    10   Q.   After 11 a.m. -- perhaps I ought to ask this question
    11        first:  could people order quarterpounders or regular
    12        hamburgers at breakfast time?
    13        A.  They could order hamburgers and Big Macs, which are all
    14        regular meat products.
    15
    16   Q.   But not quarterpounders?
    17        A.  Not quarterpounders.
    18
    19   Q.   So this grill would not be reset for use on the
    20        quarterpounders until breakfast had finished?
    21        A.  That is correct.
    22
    23   Q.   Presumably, quarterpounders then go on until the restaurant
    24        closes?
    25        A.  That is correct, yes.
    26
    27   Q.   When would the grill be reset to do sausage the next
    28        morning?
    29        A.  At night, it would be cleaned.  In the morning, the
    30        opening Manager would reset it, the breakfast Manager, a
    31        dedicated breakfast Manager.
    32
    33   Q.   So if a breakfast Manager overlooked one of his tasks --
    34        what time did breakfast begin?
    35        A.  It started at 6 a.m..
    36
    37   Q.   So if somebody came into the restaurant at, let us say,
    38        half past 10 in the morning and asked for sausage, he would
    39        either get properly cooked sausage or, if the grill had not
    40        been reset since the previous evening, everybody since --
    41        7.00, did you say, or 6.00?
    42        A.  Since 6.00.
    43
    44   Q.   -- between 6.00 and half past 10, would be having
    45        undercooked sausage?
    46        A.  Yes.  It would have been pink.
    47
    48   Q.   Pink.  Then, through the rest of the day, was that
    49        sausage/quarterpounder grill ever used for the regular
    50        hamburgers? 
    51        A.  No. 
    52 
    53   Q.   So whoever starts the quarterpounders after breakfast has
    54        finished has to raise it, make the setting higher?
    55        A.  It depends on the person.  They might not know how to
    56        do it themselves; it might be the Manager or a training
    57        squad who would do it for them.
    58
    59   Q.   But if -----
    60        A.  If they knew how to do it, they would do it themselves.
 
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