Day 293 - 04 Nov 96 - Page 20
1 argue anyway it is not substantially post-consumer, it is
2 not recycled, in any event.
3
4 MR. JUSTICE BELL: Very well.
5
6 MR. MORRIS: Obviously, we have got much more detailed
7 information about the European situation and the figures
8 seem to be more reliable on the European situation.
9
10 And just to say that if you look at page 14 there is
11 another chart, handwritten 14, behind the other one, there
12 is another chart that ----
13
14 MR. JUSTICE BELL: That is 350 of the bundle?
15
16 MR. MORRIS: Yes, where it compares the recycled versus virgin
17 paper content. That accords with the first chart in terms
18 of equivalence. So it does seem a bit kind of confusing
19 one way or the other as far as America is concerned.
20
21 Can I also say, if you look at page 347, bundle 347, this
22 is a document which has been produced for public or some
23 kind of, you know, formal public use, or whatever it is,
24 presentation, not for this case, by Persico including David
25 Kouchoucos. If you look at the bottom of that page 347, in
26 the middle of that last full paragraph: In 1989 McDonald's
27 paper packaging contained 7 percent recycled content.
28
29 So I don't consider that the view of that first chart is
30 some kind of clerical error or something and it is
31 something they have on record about in court and publicly.
32
33 I think that is all I have to say on that. While we have
34 got that tab open, if we can just note that the DJK5, which
35 is pages 338 in that tab onwards, is a list of supply mills
36 which I think we have put anyway to one or other of the
37 witnesses as regards where the mills are sited and the use
38 of chlorine bleaching and other matters.
39
40 You may still need to have that file out, I think, because
41 I was going to look at what I have got as DJK4. I don't
42 know if it is part of his first statement or his second
43 statement, but it is bundle page numbers 50 to 57.
44
45 MR. JUSTICE BELL: Yes.
46
47 MR. MORRIS: If you are making any calculations yourself,
48 I think this is an important set of documents. This again
49 is not the complete story, because, as far as I can see, it
50 does not include all the packaging. For example, the
51 transport packaging for food items is not included. On
52 page 2 it has got: Corrugated containers from all of the
53 above items. Again, it is not clear if it is all of the
54 above items on the first two pages or just that one page.
55 That is all transport and packaging for the packaging items
56 rather than for the food items, and, as we know, that is
57 far greater in weight.
58
59 MR. JUSTICE BELL: Which is your page 2? What has that got at
60 the bottom?
