Day 024 - 15 Sep 94 - Page 31
1 work went into the decision to distribute the July 3rd
2 memorandum.
3
4 I conclude that they were intentionally deceiving the
5 States of California and Texas when they told us they
6 needed additional time so that they could then
7 intentionally deceive the people of our country when they
8 told them that this was something they had, in essence,
9 come up with on their own when they put out their press
10 release on July 7th 1986. (Pause).
11
12 MR. MORRIS: Could we ask for some guidance?
13
14 MR. JUSTICE BELL: Yes.
15
16 MR. MORRIS: There are a couple of letters that follow this,
17 but to save time -- we do not really want to read them --
18 could we note on the record they are in the documents?
19
20 MR. JUSTICE BELL: Yes, I am aware they are there. I have read
21 them before. I read them again yesterday. You choose
22 what you want to ask about, then Mr. Rampton will decide
23 what he wants to ask about. You will have an opportunity,
24 if you wish, to re-examine.
25
26 MR. MORRIS: Just for the record, the letters of July 23rd,
27 Exhibit 4, from the Attorney General of Texas to
28 Mr. Horwitz; July 30th 1986, Exhibit 5, from Gerald
29 Rosberg to yourself and Mr. Sheldon, and the letter of
30 July 21st 1986 from the Attorney General's office in
31 California to Mr. Rosberg. That is also on your behalf,
32 that letter. Just for the record, are they true
33 documents?
34 A. Yes. Although, if I heard you right, you referred to
35 what is the August 5 letter as a July 21 letter. But
36 Exhibit 6 is the August 1986 letter that was sent on the
37 letterhead of the California Attorney General, but on
38 behalf of both the State of Texas and the State the
39 California. So that is a letter not signed by me but sent
40 by me.
41
42 Q. So far as you are concerned, it accurately represents your
43 views, as does the July 23rd letter?
44 A. Absolutely. And the Exhibit 6, August 5, is the one
45 I have referred to earlier, saying it was the one that was
46 responsive to Mr. Rosberg's July 21 letter that we have
47 been discussing. The July 23 letter, Exhibit 4 to my
48 statement to Mr. Horwitz from me and the California
49 Attorney General's office and the July 30 letter from
50 Mr. Rosberg on behalf of McDonald's to myself and
51 Mr. Sheldon also are of a pair; they relate to each
52 other. The July 21 and August 5 letters relate to each
53 other. These copies are all true and correct copies and
54 do reflect what we had taken positions on at that time.
55
56 Q. Is there anything important from those letters or, indeed,
57 about this whole issue that you would like to say to the
58 court that you have not said?
59
60 MR. JUSTICE BELL: This is the 1986 matters, because Ms. Steel
