Day 140 - 22 Jun 95 - Page 58


     
     1        when it is coming under fire to try and deflect criticism
     2        by reeling off all these things where they supposedly have
     3        helped the community and done wonderful things for the
     4        community?
     5        A.  This is Mr. Brown's response.  It is not a tactic.
     6        That is how he responded to the letter.
     7
     8   Q.   But is that unusual for McDonald's?
     9        A.  It is neither unusual or usual.  I have seen it done
    10        sometimes, that people respond, and I have seen it not done
    11        other times.  It has nothing to do with the tactic.  These
    12        are all statements of fact.
    13
    14   Q.   I think they are repeated on your fact sheet about
    15        McDonald's and the community on page 1470?
    16
    17   MR. MORRIS:  We have a few more questions on that and then that
    18        is the end of this subject.  If we look in tab 154 of our
    19        documents, that is the Kingfisher blue 154, right in the
    20        middle of that large bundle.  I am sorry about this, but
    21        can you look in the middle where there are those
    22        documents.  There is a news item headed "Coalition boycotts
    23        city McDonald's".  It is the Philadelphia Enquirer.  We did
    24        not number the actual pages.  It is just after the other
    25        one we looked at?
    26
    27   MR. JUSTICE BELL:  What is the heading?
    28
    29   MR. MORRIS:  "Coalition boycotts city McDonald's" and there are
    30        no photographs on the page.  It is in the middle of that
    31        section.
    32        A.  Is this the February 14th article?
    33
    34   Q.   That is the one, thank you.  If you look at the middle
    35        column, the fourth paragraph down, it says: "Some of the
    36        operators" -- this is the McDonald's operators -- "hired a
    37        management consultant from Balasimot to negotiate with the
    38        coalition".  Do you know anything about who that was?
    39        A.  No, I do not.
    40
    41   Q.   Do you know whether some of the operations did hire a
    42        consultant to negotiate with the coalition?
    43        A.  I do not.  My personal knowledge is there was no
    44        consultant negotiating with anyone.
    45
    46   Q.   Did they have a consultant who met with the coalition?
    47        A.  You are going to have to ask them that; I have no
    48        idea.  I was not aware of any consultants being used for
    49        the purpose that is set forth here.
    50 
    51   MR. JUSTICE BELL:  He said that he does not know.  It says "some 
    52        of the operators".  It is not saying McDonald's actually 
    53        have done it and Mr. Stein says he does not know of any
    54        such consultant.
    55
    56   MR. MORRIS:  OK.  My last question is, it is in 156, I think.
    57
    58   MR. JUSTICE BELL:  Do you think you have just made a wrong note
    59        of 156 before?
    60

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