Day 007 - 06 Jul 94 - Page 36


     
     1        square mileage) to see if you can help us to give an
              estimate for the total area of timberland used for
     2        McDonald's purposes throughout the world.
              A.  Okay.
     3
         Q.   Do you accept, or not, that as a very rough guide to the
     4        amount of packaging you need the number of restaurants per
              country may assist?
     5        A.  Yes.
 
     6   Q.   Obviously, we leave out of account, if we use that figure,
              the variation in the average number of customers that
     7        visit those restaurants in those different countries?
              A.  We would.
     8
         Q.   But, as a very rough guide, if there are, or were in 1993,
     9        9,283 restaurants and those restaurants used a total of
              9.4 square miles in that year, can we calculate that each
    10        restaurant was responsible for using 0.0010126 square
              miles?
    11        A.  You can.
 
    12   Q.   We know that Europe (which includes Africa and the Middle
              East which is perhaps a strange concept, but it does for
    13        these purposes) has 1,823 restaurants?
              A.  Okay.
    14
         Q.   If we add the number of European restaurants to the number
    15        of United States restaurants, that means that in 1993 the
              rest of the world had 2,887 restaurants, 2887?
    16        A.  I follow.
 
    17   Q.   Would it be fair, when looking at those restaurants, for
              the rest of the world to use what one might call the
    18        American standard of number of square miles per restaurant
              I have just suggested?
    19        A.  It would be fair.
 
    20   Q.   The European one actually works out rather lower?
              A.  It was a rough estimate.
    21
         Q.   But let us use the higher figure, may we?
    22        A.  It is more conservative, yes.
 
    23   Q.   Then for those remaining restaurants in the world of 2887,
              at a figure of point 0.0010126 square miles per
    24        restaurant, one arrives, does one not, at a total area of
              timberland used by those restaurants in the rest of the
    25        world of 2.9 square miles total per annum?
              A.  Yes. 
    26 
         Q.   In a sense, I am putting words into your mouth but have 
    27        you yourself done these calculations?
              A.  I have verified those calculations.
    28
         MR. JUSTICE BELL:   If, in fact, we took the figures from the
    29        tables and the premises you have accepted, we could sit
              down and do it ourselves.
    30
         MR. RAMPTON:  We could.

Prev Next Index