Day 079 - 27 Jan 95 - Page 43


     
     1        A.  Of course, McKey's take -- I have people who do that.
     2        I have got engineers.  You asked me a question, did I know;
     3        I do not know.
     4
     5   Q.   The photographs in this brochure, are they staged or are
     6        they actual working conditions?
     7        A.  They are working conditions.
     8
     9   Q.   What, all of them?
    10        A.  Yes.
    11
    12   Q.   So anything that you see there may be a typical scene?
    13        A.  Yes.
    14
    15   Q.   On the back page, not the map, but the one before the map,
    16        yes?
    17        A.  Yes.
    18
    19   Q.   There are five photographs.  The four at the top -- the two
    20        on the right are actually in McDonald's, are they?
    21        A.  The only one of those that is in McDonald's is the
    22        little girl.  If you want to say is that staged, I think,
    23        yes, that was staged because these photographs are actually
    24        stills taken from a film, a training film, of the factory.
    25
    26   Q.   So the other pictures are actually taken at McKey's?
    27        A.  Yes.
    28
    29   Q.   Would you like to comment on why the woman on the bottom
    30        left-hand of those four is not wearing any gloves while
    31        touching the patties?
    32        A.  Those patties are going out and that is a laboratory
    33        procedure.  I said yesterday the packing girls wear gloves.
    34
    35   Q.   Going out where?
    36        A.  They are going out from the loading dock.
    37
    38   Q.   These ones are going out to the loading dock?
    39        A.  Out from the loading dock.
    40
    41   Q.   To where?
    42        A.  To the distribution depot.
    43
    44   MR. JUSTICE BELL:  It is the woman who is -- have you the right
    45        picture -- to the left of the little girl?
    46        A.  Yes, sir.
    47
    48   MR. MORRIS:  That is the loading bay, is it?
    49        A.  Yes.
    50 
    51   Q.   Going to the distribution? 
    52        A.  Yes.  If you want me to explain to you what she is 
    53        doing, I will tell you.
    54
    55   Q.   Yes, go on then.
    56        A.  Before each pallet goes on out on the loading dock,
    57        you can see the pallets behind her are sealed and they are
    58        over-wrapped.  Every pallet, before it goes out, we open
    59        and that girl looks in to make the sure the patties are --
    60        can I use the term -- poker chips.  They are not frozen in

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