Day 214 - 01 02 96 - Page 32

 
 

                                                                  DAY 214
 
                                           DAVID ROBERTS, Cross-examined:
 
 
 
     1   Q.   So there would be 174?
     2        A.  I did not tell him it is around 160.  In his
     3        statement -- I was not there for his statement, so  .....
     4
     5   Q.   He said that that was where he got the figure from; that
     6        was something that you had told him.  Is that correct?
     7        A.  I never said to him I have around 160 crew.  I do not
     8        recall.
     9
    10   MR. JUSTICE BELL:  The figures are only two out, are they not?
    11        As I understand Mr. Roberts' evidence, there were 172
    12        hourly paid people, including Floor Managers.
    13
    14   MS. STEEL:  This is December 1994.  Where it says 170 in
    15        Mr. Roberts' statement is in August 1995, when he left.
    16
    17   MR. JUSTICE BELL:  Well -----
    18
    19   MS. STEEL:  That is what I am trying to clarify.
    20
    21   MR. JUSTICE BELL:  I understand now.  But if I did not, it may
    22        be that the witness did not, you see.
    23
    24   MS. STEEL:   OK.
    25
    26   MR. JUSTICE BELL:  (To the witness)  Do you understand
    27        Ms. Steel's point now?
    28        A.  Yes, I understand what she is saying, yes.
    29
    30   Q.   There are two more there, as it happens, than your ball
    31        park figure, but several months earlier.
    32        A.  Yes.
    33
    34   MS. STEEL:  So these would have been the correct figures for
    35        December 1994?
    36        A.  Yes.
    37
    38   Q.   And he would have got them from you?  Do you remember
    39        giving them to him?
    40        A.  He may have got them from various places.
    41
    42   Q.   If he said that he got them from you, which I believe he
    43        said yesterday, you would not argue with that?
    44        A.  He could have got them from me; he could have got them
    45        from the payroll department; he could have got them from
    46        Head Office -- anywhere.
    47
    48   Q.   Because at the beginning of December 1994 there were
    49        actually 139 hourly paid staff on the payroll, which is
    50        30 or so less than the figure that he has given? 
    51        A.  I cannot answer for his statement, I am sorry. 
    52 
    53   Q.   Is it quite likely that if we had the payroll for
    54        August 1995 it would be exactly the same?
    55        A.  I have not got the payroll here, so I cannot tell you.
    56
    57   Q.   We looked at Mr. Beech's forms this morning, when you were
    58        being asked about his holiday pay, the crew payroll
    59        summaries.  You saw Mr. Beech was still on there, I think
    60        Mr. Rampton said, six weeks after he had left.  I think
 
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