Day 012 - 18 Jul 94 - Page 57


     
     1   Q.   You sent a copy to Mr. Rosberg at Dewey Ballantine?
              A.  That is correct.
     2
         Q.   The date here is the important thing, Mr. Horwitz:
     3        November 20th 1987:  "Dear Sandy, To keep you up to date
              enclosed is a copy of the one page "We Shop Where You
     4        Shop" advertisement which will be appearing in various
              national publications over the next few months.
     5        McDonald's has long been committed to providing its
              customers with nutrition and ingredient information on all
     6        McDonald's products.  We continue to believe that
              advertising the availability of such information is in the
     7        public interest.  As always, If you have any questions or
              comments with respect  to specific advertisements therein,
     8        we would be happy to discuss them with you."
 
     9        If you turn over the page, I hope you will find the We
              Shop Where You Shop advertisement that we looked at
    10        earlier.
              A.  Yes.
    11
         Q.   Though that was not one of the three specific
    12        advertisements which the Attorneys General of Texas
              California and New York had objected to, it was part of
    13        the overall campaign, was it not?
              A.  Yes, it was.
    14
         Q.   If you turn over the next page, you should find a rather
    15        unsatisfactory document in the sense that it is not my
              version complete.  It is dated 2nd December 1987?
    16        A.  Yes, Sir.
 
    17   Q.   The subject matter: The client is McDonald's.  Do you
              think this is a Leo Burnett document?
    18        A.  Yes, this is a Leo Burnett document.
 
    19   Q.   Signed by somebody called Joanna Hughes?
              A.  Yes, I do not recall the name.  I do recall the
    20        trademark Leo Burnett in the upper left-hand corner.  It
              is also stamped Leo Burnett.
    21
         Q.   It says: "This reports a conversation between Joanna
    22        Hughes, Thom Kettle and David Green on Tuesday December
              1st at McDonald's.  Re: First Quarter Nutrition Budget."
    23        Forgive me, Mr. Horwitz, but must be the first quarter of
              the next year, yes, 1988?
    24        A.  Where are you reading right now?
 
    25   Q.   "Re: First Quarter Nutrition Budget?
              A.  Yes, first quarter of 1988. 
    26 
         Q.   You see that in the next sentence? 
    27        A.  Yes.
 
    28   Q.   "This confirms the client's decision to cut back the
              Nutrition print budget for the for the first quarter 1988.
    29          Specifically, because we are already committed to 6th
              February insertions," was that true, were you?
    30        A.  Yes, as far as I can recall.
 

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