Day 072 - 12 Jan 95 - Page 27


     
     1        what-have-you, on the streets where it is quite easily
     2        accessible to a environment/index.html">litter patrol should one turn up?
     3        A.  People have complained, yes, about other items.
     4
     5   Q.   Could you turn to page 779 in pink ----
     6
     7   MR. MORRIS:  Volume V, tab 49.
     8
     9   THE WITNESS:  Is it 779?
    10
    11   MS. STEEL:   Yes.  At the bottom of that page:  "The regular
    12        McDonald's patrol system has broken down.  It is now often
    13        stimulated by a resident calling your Kings Road manager
    14        and asking for McDonald's rubbish to be picked up".  This
    15        is from the Royal Hospital Ward Residents Association and
    16        it is, what, three months after you became manager at this
    17        store?
    18        A.  Yes.
    19
    20   Q.   They go on to say:  "We find it difficult to understand why
    21        a company of your size and expertise finds it difficult to
    22        organise to pick up your customers' dropped environment/index.html">litter on a
    23        regular basis.  Perhaps you can help reinstitute and
    24        maintain a regular patrol system".  Can you explain why
    25        they should be unaware, this is just at the end of the
    26        summer -----
    27
    28   MR. JUSTICE BELL:  Put it another way, I suggest.
    29        (To the witness):  Can you explain, take your points about
    30        the odd bit of environment/index.html">litter here and there, why someone should
    31        think that your system has broken down?
    32        A.  The residents cannot obviously see the environment/index.html">litter patrols
    33        all day.  They are not observing the street for all that
    34        time.  There is a high volume of environment/index.html">litter in the Royal Ward,
    35        in the Royal Avenue area, and customers use the Square in
    36        the centre of Royal Avenue as a picnic area which they have
    37        tried to prevent and we have tried to prevent -- to no
    38        avail.  I can only come to the conclusion that they have
    39        seen a lot of environment/index.html">litter, yes, but I believe that they are
    40        wrong to say that there was not a regular trash walk.
    41        I know for a fact there was, but I am saying their
    42        visibility may not have been apparent to them.  We did not
    43        have a dust cart at that time.
    44
    45   Q.   Is the large Safeways on the gap between Walpole Street and
    46        Cheltenham Terrace?
    47        A.  No, sir.  It is on the gap between Royal Avenue and
    48        Walpole Street.  So, we are either side of the Royal
    49        Avenue.
    50 
    51   MS. STEEL:   So you are saying that because of the frequency of 
    52        customers using the Square, a lot of McDonald's environment/index.html">litter ends 
    53        up in that Square and that is why there are these
    54        complaints?
    55        A.  A lot of -- I would not say substantially McDonald's
    56        environment/index.html">litter.  There is a lot of environment/index.html">litter, especially a lot of ice
    57        cream cartons from the Haagen Dazs shop.
    58
    59   Q.   Yes, but they are directing this at McDonald's, so
    60        obviously they have observed McDonald's environment/index.html">litter?

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