Day 246 - 09 May 96 - Page 25
1 is won?"
2
3 At that time, you were expecting to get damages if you won
4 the case?
5 A. We talked through this discharge issue quite
6 extensively yesterday. The entitlement to damages is
7 certainly there if we win. What they might be or whether
8 we choose to ----
9
10 MR. JUSTICE BELL: I do not want you to repeat what you said
11 yesterday, Mr. Preston, unless it is vital to your answer.
12
13 All you are being asked, having read the paragraph 1.1, is
14 ----
15
16 MS. STEEL: Basically you were still seeking damages at that
17 time?
18
19 MR. JUSTICE BELL: -- you were expecting to get your damages if
20 you won the case and were awarded damages?
21 A. Yes.
22
23 MS. STEEL: In No. 2 it talks about:
24
25 "Should be produced a briefing paper for the media that
26 could be faxed in response to inquiries or offered
27 pro-actively to a selected number of target journalists."
28
29 At that time who were -- I do not know mean who
30 individually -- were the would-be the targeted
31 journalists? Were they ones that had been sympathetic to
32 McDonald's previously?
33 A. I do not know who they would be talking about. "In
34 response to inquiries" could come from anybody.
35 "Pro-actively offered to selective", I do not know. They
36 may have been talking about the national media. They may
37 have been talking about local, I do not know.
38
39 Q. Then on page 10, which is the second page of this
40 particular document, under "Local Media Coverage":
41
42 "What impact will local coverage have on restaurants and
43 how will staff deal with customers questions? Should we
44 have a leaflet prepared for handing out in response to
45 questions, or even included in the leaflet dispensers?"
46
47 You are aware at that time that the Company was considering
48 putting them, or intending or thinking about putting them
49 out in the leaflet dispensers rather than just having them
50 behind the counter?
51 A. Yes.
52
53 Q. Why was it that Company decided, as you claim, not to have
54 them put in the leaflet dispensers?
55 A. They were prepared. They were to be used for response
56 to questions by customers. We feed something like a
57 million and a half people a day and if we gave them out to
58 every customer It would not last but a few hours in the
59 first day; 300,000 leaflets was intended to deal with
60 specific questions. It is a matter of logistics.
