Day 043 - 01 Nov 94 - Page 70


     
     1   Q.   That means the waste paper basket, does it?
     2        A.  Yes.
     3
     4   Q.   The bin?
     5
     6   MR. JUSTICE BELL:  What does it mean, Mr. Green?
     7        A.  Most of the memos that are sent to me, I get a stack of
     8        memos maybe this high over a period of time.  If they are
     9        not relevant to something that either I or my secretary
    10        feel that is relevant, they are thrown away.
    11
    12   MR. RAMPTON:  I think you said a circular filing cabinet?
    13        A.  Yes, that is a euphemism for the waste basket.
    14
    15   MR. JUSTICE BELL:  I was not familiar with it, that is all.
    16        A.  I am sorry.
    17
    18   MR. RAMPTON:  Can you think of any reason why in relation to
    19        this complaint way back in the spring of 1987 you should
    20        have kept any of your documents?
    21        A.  Any documents that were kept would be the ones that
    22        would normally be kept at that time.
    23
    24   Q.   But how long would you keep documents of this kind in the
    25        normal way?
    26        A.  A few weeks, maybe a few months.  Most of the time,
    27        since I am carboned on many documents, I personally do not
    28        keep many documents at all, knowing that other people may
    29        keep them within the company.
    30
    31   Q.   There is no dispute about this:  There were no legal
    32        proceedings arising out of this incident, were there?
    33        A.  None that I know of.
    34
    35   MR. MORRIS:  Sorry, what incident?
    36
    37   MR. RAMPTON:  This complaint by the Attorneys General never
    38        crystallized into legal proceedings?
    39        A.  No, the facts, as I understand it, that never happened.
    40
    41   MR. JUSTICE BELL:  That is common ground.
    42
    43   MR. RAMPTON:  That is common ground.  Perhaps we can pass now to
    44        the last document I ask you to look at which is in tab 2 --
    45        I hope it is anyway.  Perhaps you can help me, Mr. Green.
    46        Is there in that file behind or in front of
    47        Mr. John Horwitz's statement a document -- again I suspect
    48        it would be a Leo Burnett document -- signed by Joanna
    49        Hughes and dated 2nd December 1987?
    50 
    51   MR. JUSTICE BELL:  It is behind tab 2, at the end of tab 2, and 
    52        if yours has been put in the same form as Mrs. Brinley-Codd 
    53        handed to me, it is the third sheet; the second is:  "We
    54        shop where you shop".  Then the third sheet.
    55        A.  Yes, it says "certified mail" on the top?
    56
    57   MR. RAMPTON:  No.
    58        A.  It is dated December 2nd 1987?
    59
    60   Q.   That is the one.  It is December 2nd 1987.  Is Joanna

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