Day 060 - 02 Dec 94 - Page 52


     
     1        A.  Yes.
     2
     3   Q.   -- in 1991, but that change over only took place in May
     4        1991  ---
     5        A.  Yes.
     6
     7   Q.   -- that if carry-out bags were changed to 100 per cent
     8        before May 1991, you would have put that in this document?
     9        A.  If they had been.  I am not certain of the date of this
    10        document.
    11
    12   MR. JUSTICE BELL:  Do you know what date it is or what the
    13        materials are?
    14
    15   MS. STEEL:  This is giving a picture of the year in total, is
    16        it?
    17
    18   MR. JUSTICE BELL:  I mean, one sees there are some -- if one
    19        looks at 38, for instance, assuming this is all the same
    20        document ---
    21
    22   MR. MORRIS:  It is the same document.
    23
    24   MR. JUSTICE BELL:  -- it talks about 1992 in the past tense in
    25        the marginal note.
    26
    27   MS. STEEL:  I think this document was produced in 1993, would
    28        that be right?
    29        A.  I would think so, yes.  That was certainly about the
    30        time we first produced this document.
    31
    32   Q.   In fact, right at the beginning, the introduction page
    33        says:  "By the end of 1992 the company had opened 472
    34        restaurants"?
    35        A.  OK, yes.
    36
    37   Q.   Which does indicate that it is likely to be 1993.  So,
    38        would you agree that this appears to reflect what the
    39        situation was at the end of 1991, if anything, the chart?
    40        A.  It is not specific in terms of when in 1991 they are
    41        talking about.
    42
    43   MR. JUSTICE BELL:  No, I think the point which may be made (and
    44        is being made against you) is this, that obviously
    45        McDonald's is anxious to say that materials it uses are
    46        made from a high percentage of recycled material, if that
    47        is so.  If this document was produced in early 1993, and at
    48        any time in 1991 the carry-out bags were 100 per cent
    49        recycled material, one might expect McDonald's to put that
    50        100 per cent figure in on a chart for "Recycled Material 
    51        Used in 1991" because at some stage in 1991 the carry-out 
    52        bags have become 100 per cent; that is the effect of what 
    53        is being put to you.
    54        A.  I think that would be misleading, my Lord.
    55
    56   Q.   Right.  Why do you say that?
    57        A.  Because at the end column it says "Total UK saving in
    58        kilos".  If we claimed a saving relating to 100 per cent
    59        recycled carry-out bag, that would have been wrong because
    60        it was not 100 per cent for the whole of 1991.

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