Day 061 - 05 Dec 94 - Page 60
1 this information came from, which document this came from?
2 Is it part of a document?
3
4 Q. I was hoping you would know. That is why I am asking.
5 A. I do not know. That is why I need to ask because it
6 looks like it is part of something.
7
8 Q. If it is for handing out if people ask, members of the
9 public ask, if it were for that and it appears you do not
10 know, but the point being made is, it is suggested, it is
11 not so much a statement of McDonald's position on animal
12 welfare and husbandry, but an attempt positively to promote
13 McDonald's as interested in animal welfare and
14 husbandry ----
15 A. I would agree that it ----
16
17 Q. --- to make a public relations point?
18 A. I honestly do not know that it has been used for public
19 relations purpose.
20
21 MR. RAMPTON: My Lord, I think I might be able to help. I am
22 not going to give evidence. I am going to make a
23 suggestion; your Lordship may or may not find it helpful.
24 If one looks at the wording of this typewritten document
25 and compares it with the wording in the Fact Book which is
26 for public consumption, that is to say, so far as page 1 of
27 the typewritten document is concerned pages 21 to 22 of the
28 Fact Book; so far as the succeeding pages are concerned
29 pages 24 onwards so far as McKey and Sun Valley are
30 concerned. It might be, and I do not know whether it is or
31 it is not, that this document is a draft for what is put
32 into public circulation in the Fact Book because the
33 wording is very similar, if not identical. I am sure we
34 can find out as a matter of fact whether that is right or
35 not. Certainly the document does not have the appearance
36 of something that is handed out to the public, whereas of
37 course the Fact Book does.
38
39 MR. JUSTICE BELL: If you go back, Ms. Steel, to 58 line 12, now
40 we have made some attempt to find where it comes from,
41 would you like to put the question again? I was trying to
42 help you by putting your question in another way. It
43 seemed to me, first of all, one should try to find out,
44 since one was looking at pages 1 and 2 and you were
45 particularly at the moment looking at page 2, what that
46 document was.
47
48 MS. STEEL: This document would be used as the basis for
49 answering enquiries that people might have about these
50 various issues, is that fair to say?
51 A. Yes, I think each of the individual items could be used
52 from time to time to answer an enquiry.
53
54 Q. I am not quite sure what you want me to do.
55
56 MR. JUSTICE BELL: I am not trying to take it out of your
57 hands. You may have a document which sets out a company or
58 an institution's attitude to things in order that all its
59 employees and people working within the company or
60 institution should know: "These are the standards we are
