Day 214 - 01 02 96 - Page 30

 
 

                                                                  DAY 214
 
                                           DAVID ROBERTS, Cross-examined:
 
 
 
     1        store, if you do not need them in your own store?
     2        A.  We did need them.  We could use them.
     3
     4   Q.   So they were a necessary part of the team, you considered?
     5        A.  Yes, they were, but they could have been replaced.
     6
     7   Q.   Well, in theory, anybody can be replaced?
     8        A.  Yes, but they would have been trained up, so when the
     9        new restaurants opened up they would have experienced
    10        people rather than new people; and I would already have
    11        experienced people; therefore, it would not be so hard for
    12        me to take on new people.
    13
    14   Q.   Did that mean that you were cutting back on the hours that
    15        other crew were working?
    16        A.  No.
    17
    18   Q.   You were not?  So, basically, you were taking these people
    19        on because they were needed?
    20        A.  Yes.
    21
    22   Q.   So you felt you needed 170 on the payroll?
    23        A.  Yes, that is right.
    24
    25   Q.   Did that include Floor Managers, or is that separate?
    26        A.  It is everybody together.  It is hourly paid employees.
    27
    28   Q.   Sorry, actually, it does say "approximately 170 crew
    29        members on the payroll".
    30        A.  Hourly paid.  The 170 is not an accurate figure that is
    31        worked out according to a set formula.  It is a hunch
    32        figure.
    33
    34   Q.   A hunch figure?
    35        A.  Yes.
    36
    37   Q.   Was it a hunch figure that you gave Mr. Khazna when he used
    38        to ring you up and say: "How many have you got on your
    39        payroll"?
    40        A.  He did not have to phone me up to ask me how many
    41        people I had on the payroll.  I would tell him how many
    42        people I had working, or he would come into the restaurant
    43        and count the people on the schedule.
    44
    45   Q.   He said yesterday -- and you must have heard him, because
    46        you were here -- that he used to phone you up and ask you
    47        how many people there were on the payroll?
    48        A.  If he needed to.
    49
    50   Q.   So, was that just a hunch figure that you gave him when he 
    51        phoned you up? 
    52        A.  Like I said, he did not have to phone me up to ask me 
    53        how many -----
    54
    55   MR. JUSTICE BELL:  Better find out what his evidence is as to
    56        whether Mr. Khazna did phone up and, if so, how often.  We
    57        know what Mr. Khazna said.
    58
    59   MS. STEEL:  OK.  (To the witness)  Did Mr. Khazna phone you up
    60        and ask you that question or not?
 
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