Day 010 - 11 Jul 94 - Page 52


     
     1   Q.   In fact, it has been put in reverse order, so the first
              part is the second page and the second part is the first
     2        page?
              A.  This is an internal memorandum that was leaked.
     3
         Q.   Sorry, has everyone got this page?
     4
         MR. JUSTICE BELL:  Yes.
     5        A.  It is an internal memorandum that was leaked which,
              whilst it does not refer specifically to the foam, the
     6        McToxics campaign, it does state in general in the first
              paragraph:  "The image of plastics among consumers is
     7        deteriorating at an alarmingly fast pace.  Opinion
              research experts tell us that it has plummeted so far and
     8        so fast, in fact, that we are approaching a 'point of no
              return'."
     9
              Then it goes on to say:  "We have an opportunity to
    10        correct this situation".  He calls for a meeting on
              January 15th 1990 at the Ritz-Carlton Hotel in Washington
    11        DC.
 
    12   Q.   A meeting for who?
              A.  It is a meeting for members of The Society of the
    13        Plastics Industry.
 
    14   Q.   So it is a very high level?  In fact, it is the highest
              level meeting for that industry?
    15        A.  Yes, the meeting would be hosted, directly above the
              words:  "January 15th 1990", it reads:  The meeting is to
    16        be hosted by SPI, that is The Society of the Plastics
              Industry, Polymeric Materials Producers Division".
    17
         Q.   What does it state underneath that paragraph?
    18
         MR. JUSTICE BELL:  Do we have a date on this -- the meeting is
    19        for 15th January 1990.
 
    20   MR. MORRIS:  I think the date has been removed so as to prevent
              identification of the person that leaked the information.
    21        A.  I could not attest to that.  I do not know why there
              is no date on it, but when we received this document it
    22        did not have a date other than the date of the meeting.
 
    23   Q.   Does it say underneath that:  "49 of 50 States have, or
              are considering, laws or regulations that ban, limit or
    24        restrict plastics and/or products made from plastics"?
              A.  That is what it says.  It adds a couple of other
    25        points, but what I call your attention to is the third
              paragraph from the last, from the end of the letter, where 
    26        it states:  "There is a growing consensus among plastics 
              executives that we must immediately undertake a major 
    27        programme of unprecedented proportions to reverse this
              fast-moving tidal wave of growing negative public
    28        perception."
 
    29        In the next paragraph in the centre it states:  "It is
              estimated that this effort will cost upwards of $50
    30        million a year for the next three years".
 

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