Day 069 - 19 Dec 94 - Page 12


     
     1        produce tonnes of product per week.  If you had a problem,
     2        you would see it more often than just one.
     3
     4   Q.   You mean if the machinery process was not functioning
     5        efficiently, you would get a rash of these incidents?
     6        A.  That is correct.  If it does not function for one
     7        minute, you will get a lot of complaints.
     8
     9   Q.   I was going to ask you -- I do not know if you know the
    10        answer to this, but you have been with McDonald's now for
    11        three years; is that right?
    12        A.  Three and a half.
    13
    14   Q.   Three and a half years.  If there were numerous complaints,
    15        genuine complaints, about matters of this kind, would it
    16        come to your attention?
    17        A.  Absolutely.
    18
    19   Q.   Over those last three and a half years, how many, roughly
    20        speaking, genuine incidents, genuine complaints,
    21        substantiated complaints, of this kind do you think you
    22        have come across?
    23        A.  None.
    24
    25   Q.   None?
    26        A.  That is correct.
    27
    28   Q.   Please turn over to page 7.  We now move away from
    29        McDonald's, although we notice that the product was called
    30        "chicken parts/drumsticks".  That does not look like a
    31        trade name; that is probably an anatomical description,
    32        would you not think?
    33        A.  Yes.
    34
    35   MR. MORRIS:  Are we going to look at page 6?  Is that a
    36        mistake?
    37
    38   MR. RAMPTON:  That is a mistake by me, sorry.  Page 6, which is
    39        the fourth of these complaints.  This concerns chicken
    40        fritters -- not a McDonald's product?
    41        A.  That is correct.
    42
    43   Q.   Coming from somebody called Simex.  Do you know them?  What
    44        are they:  food processors or distributors?
    45        A.  They are packers.  They put the labels on the products
    46        that are produced at the Tyson facility and then they sell
    47        it.
    48
    49   Q.   This lady bought the thing at a shop in Buffalo -- Mn,  is
    50        that Minnesota? 
    51        A.  That is correct. 
    52 
    53   Q.   But these fritters came from Tysons Foods at Nashville,
    54        Arkansas?
    55        A.  That is correct.
    56
    57   Q.   So it is said.  Do you know anything about that product,
    58        chicken fritters?
    59        A.  Yes, I do.
    60

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