Day 064 - 08 Dec 94 - Page 67


     
     1
     2   Q.   So he is one the four Heads of Department underneath
     3        yourself?
     4        A.  Right.
     5
     6   Q.   You know the leaflet that was issued by McDonald's
     7        criticising the Defendants?  I believe 300,000 were issued
     8        by McDonald's?
     9        A.  Yes.
    10
    11   Q.   You know that leaflet?
    12        A.  Yes, I do.
    13
    14   Q.   You saw it at the time, did you?
    15        A.  I did.
    16
    17   Q.   Did you approve it?
    18        A.  Did I approve it?  It went out -- yes, I did.
    19
    20   Q.   You did.  Did you check the facts in it?
    21        A.  Yes, I am aware of what is in it.
    22
    23   Q.   No, but did you check the facts in it?
    24        A.  What are you referring to?
    25
    26   Q.   Did you check before you issued a national leaflet to
    27        300,000 customers, did you check the facts that were in
    28        it?
    29
    30   MR. JUSTICE BELL:  Which facts?
    31
    32   MR. MORRIS:  The statements.
    33
    34   THE WITNESS:  Which one?
    35
    36   MR. MORRIS:  You know the leaflet, do you not?  When you
    37        approved it, did you say:  "Yes, that is fine; get on with
    38        it" or did you say:  "We had better check this out",
    39        whatever it was, "the facts are correct"?
    40        A.  No.  What went out I thought was OK, yes.
    41
    42   Q.   You thought was OK.  I will give you an example, for
    43        example -----
    44
    45   MR. RAMPTON:  My Lord, again, no, I am sorry, this is a
    46        McDonald's document.  The Defendants are going to ask
    47        detailed questions about statements made in a document
    48        which is the subject of the counterclaim for which this
    49        witness is to be held responsible.  He must be allowed to
    50        see a copy of the document.  Apart from anything else, as 
    51        your Lordship knows, I am highly suspicious of selective 
    52        reading. 
    53
    54   MR. JUSTICE BELL:  I appreciate you are trying to save time.
    55
    56   MR. MORRIS:  It is the last point we are making.  How can we get
    57        a copy of this leaflet to the witness?  I do not know
    58        whether the counterclaim file is -----
    59
    60   MR. JUSTICE BELL:  I have to say my counterclaim files are at

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