Day 169 - 04 Oct 95 - Page 16
1 crooked?
2 A. No, customers complained about the fact that their buns
3 were not toasted properly. The customer would not know
4 that the tray does not go in properly. All they would know
5 is that the bun they received, perhaps, would not be
6 toasted properly. They would come back and complain and we
7 would take action accordingly.
8
9 Q. So what percentage of complaints do you say were about
10 buns?
11 A. The vast majority of them.
12
13 Q. You are just saying that, are you not, Mr. Richards,
14 because you cannot find any incident report forms?
15 A. No, I am not. I am saying it because it is true. The
16 instances of people bringing back product which were
17 undercooked, for instance, a meat pattie or a chicken
18 pattie, are exceptionally rare. No-one has ever brought
19 one back to me, for instance.
20
21 Q. It is clear from Mr. Logan's statement and from your own
22 statement that what you are referring to about complaints
23 as being received approximately once a week is meat
24 products, is it not, and you are changing your story now?
25 A. No, it is not. If you read my statement, I do not
26 mention the word "meat" anywhere.
27
28 Q. No, but you do not say ------
29
30 MR. JUSTICE BELL: Let us look at the statement. If you are
31 going to cross-examine him on what the statement must mean,
32 then I think we should all look at it. Yellow X again.
33 Section F, 39C. The page?
34
35 MS. STEEL: Page 9, paragraph 19. (To the witness): You said:
36 "It is true that customers complain about uncooked
37 products. Logan is accurate in saying that such complaints
38 are received approximately once a week. However, it would
39 be extremely rare for a complaint of this nature to be
40 substantiated". Firstly, if a bun was not toasted properly
41 it would be quite obvious, would it not, therefore, it
42 would be substantiated?
43 A. Agreed.
44
45 Q. "However, it would be extremely rare for a complaint of
46 this nature to be substantiated and again I would dispute
47 Logan's claim that they are attributable to overcrowding of
48 meat on the grill". You are clearly talking about meat
49 products there, are you not?
50 A. No, we can argue about grammar, but what I am actually
51 saying is that we do receive complaints approximately once
52 a week about uncooked product, full stop. Some of those
53 complaints are about meat, OK, but I do say there:
54 "However, it is extremely rare for a complaint of this
55 nature to be substantiated". I then go on to say in
56 relation to the fact that he claims that we received
57 problems -- received complaints as a result of undercooking
58 meat because of overcrowding on the grill, "I would dispute
59 Logan's claim that they are attributable to the
60 overcrowding of meat on the grill".
