Day 283 - 21 Oct 96 - Page 41
1 directors, they were all people who one could easily
2 identify as being currently compromised by their loyalty to
3 McDonald's and what it stands for. I think some have left
4 the company, but I can't remember now. But that can be
5 dealt with when we go into the detail. Secondly, some of
6 the higher ranking, or all of the higher ranking,
7 representatives of McDonald's who gave evidence can be said
8 to have relied greatly on hearsay. I do not think any of
9 them were experts and therefore entitled to opinion on
10 expert matters, and they greatly relied on hearsay about
11 what happened in McDonald's and how things are enforced or
12 not enforced, or whatever.
13
14 But, of course, hearsay, we submit, is allowable when it is
15 an admission against interest. And another thing to be
16 borne in mind when the evidence is analysed is that a great
17 many of the McDonald's witnesses were trained
18 propagandists, public representatives of McDonald's who
19 have been travelling the length and breadth of their own
20 country, or indeed the world, promoting McDonald's. So
21 this is one reason that we felt it took some time on many
22 occasions to get at what we felt the truth was behind the
23 kind of official position that was being put in the witness
24 box.
25
26 Another point was that the hearsay that most of McDonald's
27 representatives, not so much the people that worked in the
28 stores because they could speak from their own experience
29 in many ways, although a lot of what they were talking
30 about they would not have seen with their own eyes, whereas
31 with our witnesses they were talking about what they saw
32 with their own eyes, much of the matters, say, coming from
33 Mr. Preston or Mr. Stein, or whatever, about what he had
34 been told by other people in the McDonald's chain. So it
35 is hearsay about what other people in similar positions may
36 be passing on to them, who also, of course, have an
37 interest in promoting McDonald's corporation to each other,
38 but they are reliant in many of the issues in the case on
39 their suppliers for information about what really happens
40 in the packaging, by the packaging manufacturers, beef
41 suppliers, or whatever, and I think there is a particularly
42 helpful and revealing comment by Dr. Gonzales.
43
44 I am just going to find it, Day 69, page 38 and 29. It is
45 really part of the cross-examination about the fact that
46 the sales director of Co-op Montecillos had stated that
47 they were sending beef for McDonald's use in the USA. If
48 you look at, especially, lines 30 to 33, it says here, "Can
49 you clearly see during the film that there is some mention
50 directed to the fast food restaurants because any
51 salesperson will tell you, if I am interested in buying
52 this piece of cloth will tell you that he has that
53 particular piece of cloth, suit or whatever". And then he
54 goes on saying, the next paragraph, bottom paragraph, about
55 not knowing what he is talking about or lying about what he
56 is talking about.
57
58 Now, it is very hard to understand Dr. Gonzales's evidence
59 because it may be partly language and partly because, we
60 will submit, he kept changing his line and was very
