Day 153 - 12 Jul 95 - Page 24


     
     1   Q.   If, for example, the ketchups, the yield was too low on
     2        them and it was because of a blockage, it might be that by
     3        watering them down a bit they would flow out more smoothly
     4        and you would have less waste?
     5        A.  That certainly would not be a course of action that we
     6        ever would advocate.  It would not work, anyway, because if
     7        you added water to ketchup then the buns would be all
     8        soggy.
     9
    10   Q.   There is normally water within ketchup, is there not?
    11        A.  There is a certain amount, but the viscosity of the
    12        ketchup is predetermined at the factory.  If you start
    13        adding water actually in the restaurant, then, one, the
    14        water, I would imagine, you know, just squirt out
    15        everywhere and, secondly, your buns would be all soggy.
    16
    17   Q.   I believe water is one of the main ingredients in tomato
    18        ketchup, anyway.
    19        A.  Sure, but it is mixed at the factory.
    20
    21   Q.   Yes.  You are getting ketchup in bulk.  We are not talking
    22        about tiny little proportions where you would not be able
    23        to add any water without it being quite obviously
    24        different.  Where you are getting ketchup in bulk, it is
    25        quite possible for you to add water and to make very little
    26        difference or very little noticeable difference to the
    27        consumers or the product?
    28        A.  I would suggest that the product would be noticeably
    29        different if you added water to it.
    30
    31   Q.   You could improve or you could save costs on the amount of
    32        money that you were spending on cheese slices by cutting
    33        down on the amount that went into the cheeseburgers and the
    34        Filet-o-fish, but in such a way that customers would not
    35        necessarily notice, particularly not if it was the standard
    36        practice; there would not be anything unusual for them to
    37        notice?
    38        A.  I think the customers are far more discerning than you
    39        would give them credit for, and I think they would notice
    40        fairly quickly.
    41
    42   Q.   Not if they had only ever come to the Colchester store and
    43        this has always been going on since they have been going
    44        there?
    45        A.  The majority of people that come into McDonald's know
    46        what a McDonald's product looks like.
    47
    48   Q.   They might not know the exact size of a piece of cheese
    49        that was in the burger?
    50        A.  They might not know, but it would seem a totally 
    51        nonsensical way of trying to save money, to me. 
    52 
    53   Q.   You were given instructions to water down ketchup, mustard,
    54        cut the cheese slices, and use less lettuce by Mr. Stanton,
    55        were you not?
    56        A.  No, I was not.
    57
    58   Q.   And you did instruct floor managers and other managers to
    59        instruct crew to carry out those measures?
    60        A.  No, I did not.

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