Day 164 - 26 Sep 95 - Page 28


     
     1        be a composite document or not.  All they have now and have
     2        had for the purposes of this case is the executive
     3        summary.
     4
     5        I took with me when I went to Chicago Mr. Marcheid's
     6        statement and the executive summary.  I asked whether
     7        Towers and Perrin still had the original study and final
     8        report, call it what you like.  The answer was that they
     9        did not and that they had destroyed it for the reasons
    10        which I have given as soon as they delivered the final
    11        report and study to McDonald's.  As for the idea that every
    12        research organisation retains all that it has ever done,
    13        one only has to contemplate what one does with one's old
    14        opinions to realise -----
    15
    16   MR. JUSTICE BELL:  Let me make sure I understand it, because my
    17        reading of Mr. Marcheid's letter is that the report which
    18        was produced for McDonald's by this firm included an
    19        executive summary.  The executive summary is not a separate
    20        report.  It is some pages of the report.  McDonald's have
    21        that part of the report, copies of which are in our
    22        bundles, but they do not have the rest of the full report.
    23        Towers and Perrin, it has been said in open court, do not
    24        have anything.
    25
    26   MR. RAMPTON:  They do not have anything.
    27
    28   MR. JUSTICE BELL:  You see, if you pursued this to its logical
    29        and legal conclusion, the only issue would be whether
    30        I ordered that an affidavit be sworn by someone who would
    31        set out the source of their information and belief, because
    32        it would, presumably, be a solicitor in this country who
    33        would say whom they had spoken to.  The reality is it would
    34        only duplicate what leading counsel has said in open court,
    35        so it amounts to the same thing and you can base any
    36        comment which you wish to make in due course on that.
    37        Yes?
    38
    39   MR. MORRIS:  I wanted to leave the Bath documents until after
    40        lunch because I have not got the statements with me, not
    41        the Sean Richard statement anyway.
    42
    43        In the statement of Chantal Villeneuve-Gallez, our witness
    44        from France, from the Lyons area, who people recall is a
    45        union rep or a union organiser in the McDonald's store in
    46        Lyons -- one of them.  She refers to -- I have not got it
    47        here, it is on the last page of her statement; I am doing
    48        it from memory -- 50 employees made witness statements to
    49        the police as part of the judicial investigation of
    50        McDonald's and claims about sabotaging of union elections. 
    51        We believe those statements ----- 
    52 
    53   MR. RAMPTON:  My Lord, once again, I fear I do have to
    54        interrupt.  It is not Chantal Villeneuve-Gallez; it is
    55        Hassen Lamti.
    56
    57   MR. MORRIS:  I am sorry about that.
    58
    59   MR. RAMPTON:  What Mr. Morris has said about is it not
    60        accurate.  It is best your Lordship looks at it.  It is

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