Day 008 - 07 Jul 94 - Page 53


     
     1        the summary to indicate what the source of the information
              is?
     2        A.  Sure.
 
     3   Q.   So far as it does not mean hiring a transatlantic
              container ship, send the source documents to
     4        Mrs. Brinley-Codd in England?
              A.  We will do that.
     5
         Q.   Thank you.  Can we go back then, please, to page 142 of
     6        the pink bundle IV, Roman 4.
 
     7   MR. JUSTICE BELL:  Do we need the others out still?
 
     8   MR. RAMPTON:  I will need, not yellow III, but I will need pink
              V in a moment.  In this document -- I am very shortly
     9        going to be finished with it, Mr. Langert -- on page 142,
              I was asking you about recycled paper.  I broke the flow
    10        and investigated the question of these percentages.  The
              bit I was reading is the first complete paragraph on page
    11        142:
 
    12        "Building on this experience McDonald's has directed its
              nearly 600 suppliers to use corrugated boxes that contain
    13        at least 35 per cent recycled materials, a target
              considerably higher than the industry average."  Two
    14        questions because there are two statements.  Did
              McDonald's direct its suppliers to do that?
    15        A.  Yes.
 
    16   Q.   Did they comply?
              A.  Yes.
    17
         Q.   I am asking you far more than two questions.  Was it a
    18        target considerably higher than the industry average?
              A.  Yes.
    19
         Q.   Has it increased since then?
    20        A.  Yes, our standard has increased since then.
 
    21   Q.   What does it stand at now?
              A.  40 per cent.
    22
         Q.   "McDonald's has directed its suppliers to maximise the
    23        percentage of recycled post-consumer materials".  Then
              they are described.  What happened about that?  I think
    24        you told us briefly a moment ago.
              A.  What happened to?
    25
         Q.   Did they do that?  Have they maximised the percentage of 
    26        recycled paper? 
              A.  We have made continual advancement. 
    27
         MISS STEEL:  I hesitate to interrupt, but to save the court
    28        time, I am not clear that any of this is relevant to any
              of the pleaded issues.  It is all post dating the time of
    29        the alleged libel and of the time of the pleading.
 
    30   MR. RAMPTON:  I am sorry to disappoint Miss Steel.  What the
              pamphlet accuse McDonald's of, amongst other things, is

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