Day 084 - 07 Feb 95 - Page 11


     
     1        complaints in respect of food safety which are recorded in
     2        the incident reports form book in each restaurant.  He
     3        identified seven complaints in the three restaurants,
     4        I believe, in his chart.  There may have been more, I do
     5        not know -- no, the total number of complaints was nine in
     6        the three stores over different periods.
     7
     8        There were also memos from Head Office in relation to food
     9        safety; one of them particularly was a memo detailing the
    10        action to be taken by managers in relation to suspected
    11        cases of viral gastroenteritis dated 14.1.1993 and any
    12        other memos that were relevant to concerns by the company
    13        over health issues of the cooking process.  I will check
    14        that again tonight.
    15
    16        The other thing in Mr. Jackson's statement which I have not
    17        got on my list and I cannot find his statement, but he
    18        referred in his statement to his Sun Valley visit.  In one
    19        particular section of his statement he dealt with the
    20        number of birds rejected by the company or rejected as not
    21        fit for consumption either because they were dead or
    22        diseased.  I think it was something like 1.5 per cent.  If
    23        we could have the documents at the time of his visit or
    24        nearest available time as to that fact?
    25
    26        If I can leave packaging and employment to save time today,
    27        but there was just one other environmental matter which is
    28        soya, if I may go on to that?  It is just that in
    29        Mr. Cesca's affidavit -- it is his second affidavit, page
    30        8, I will just read out; it is only one sentence, it is his
    31        point 10 -- he says:  "Soya for cattle feed".  This was
    32        after our application based on our restored passages which
    33        obviously goes back 18 months, or something, originally,
    34        our application.  He says:  "I repeat what I said in
    35        paragraph 3 of my first affidavit".  I have not got his
    36        first affidavit with me, but it basically says it is being
    37        dealt with by Barlow Lyde and Gilbert.  He has no personal
    38        knowledge of the soya in Germany.  It was basically the
    39        sources of soya feed for McDonald's beef in Germany.  We
    40        had applied for in our application entitled "Discovery
    41        relating to restored passages", which is what Mr. Cesca
    42        replied to, correspondence with Franz Wirtz who is a
    43        witness of ours; correspondence between McDonald's Germany
    44        and L&O Fleisch Waren relating to feed for their beef;
    45        correspondence between McDonald's Germany and Raffeisenn
    46        Kraftfaterwerck regarding this issue and internal reports
    47        and memos regarding this issue.  Mr. Cesca says that is
    48        being dealt with by Barlow Lyde and Gilbert.  That is just
    49        because that was something I missed out yesterday.
    50 
    51        If I can move back to our list, while we are on the subject 
    52        of documents.  Again probably there is no time to go into 
    53        it now, but Mrs. Brinley-Codd has helpfully made up a list
    54        of documents served since 12.9.1994, served in court, but I
    55        do not know how this normally is dealt with.  We have
    56        contacted the Plaintiffs' solicitors and tried to work out
    57        a system but we have not been able to really develop one by
    58        agreement.  This is just something that I feel if we could
    59        just put down a marker that ----
    60

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