Day 125 - 12 May 95 - Page 46


     
     1   MR. MORRIS:  I have a couple of questions.
     2
     3   MS. STEEL:   Shall I leave the television until we have
     4        finished?
     5
     6   MR. JUSTICE BELL:  Yes.
     7
     8   MR. MORRIS:  There was a question I was going to ask you, before
     9        I forgot, you know when you had something around 175 patty
    10        suppliers, do you know how many abattoirs, on average,
    11        would supply each of those suppliers?
    12        A.  How many stores?
    13
    14   Q.   How many abattoirs ---
    15
    16   MR. JUSTICE BELL:  Slaughterhouses, you call them in the States.
    17
    18   MR. MORRIS: -- would supply each patty production?
    19        A.  No, I do not.
    20
    21   Q.   The Company would not know those figures.  At the time you
    22        would not be --
    23        A.  I would not be able to answer that.
    24
    25   Q.   For a typical supplier you might have had at that time,
    26        what would be a typical number of abattoirs that might
    27        supply that kind of supplier?  Would they take from
    28        hundreds of abattoirs from all over the States, or is that
    29        fairly normal?
    30        A.  I do not know.  At the time of my career at McDonald's
    31        I would not have had the need to know that, and later on
    32        those practices, the method of supply was dramatically
    33        different than -----
    34
    35   Q.   But in any case McDonald's would not have checked the
    36        abattoirs, would they?
    37        A.  Our purchasing people probably did from time to time.
    38        I am pretty sure they did.  How often I would not know, but
    39        I would think they would.
    40
    41   Q.   They might have the details of how many abattoirs supplied
    42        a particular -----
    43        A.  Would they have the details?  Would we have the
    44        details?
    45
    46   Q.   Yes?
    47        A.  I doubt it.  I mean, there would be no need to have
    48        copies of visits that go back 30-some years.
    49
    50   Q.   What were you doing in 1983/1984? 
    51        A.  I was zone manager for the mid-west. 
    52 
    53   Q.   As the zone manager in the mid-west, did you have
    54        responsibility for the whole mid-west ---
    55        A.  Basically.
    56
    57   Q.  -- for McDonald's?
    58        A.  With some exceptions, for the mid-west and I think part
    59        of the southeast as well.
    60

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