Day 025 - 16 Sep 94 - Page 61
1 reprehensible that I do not choose to suppose that
2 McDonald's engage in that -- if Mr. Rampton does, he may,
3 but I certainly could not.
4
5 MR. RAMPTON: Leaving aside your finer feelings in the
6 matter ---
7 A. Or coarser, Mr. Rampton.
8
9 Q. -- if I may, are you different, are you not to the
10 conclusion that, in fact, the nationwide operation must
11 have been virtually complete by 4th July, if they were
12 able to write to their own people in the terms they did on
13 3rd July 1986 at page 187? It must be so, must it not?
14 A. What operation, Mr. Rampton, the brochure?
15
16 Q. The nationwide distribution of brochures?
17 A. Were not to be to be ready until August 16th or
18 thereabouts.
19
20 Q. August 15th.
21 A. I stand corrected. That is about a 40 to 45-day lead
22 time which would certainly be enough time to cause the
23 brochures that were already in existence, the one we have
24 seen dated April 1987, to be printed in greater quantities
25 and shipped out. The decisions reflected in the July 3
26 letter do not require that greater length of time to make
27 nor to implement, given that the brochure was already in
28 existence.
29
30 Q. Have a look at page 194?
31 A. Yes, sir, I have it.
32
33 Q. By July 30th, which is 27 days after July 3rd, I think,
34 they tell you they have already instituted the programme
35 in New York, Connecticut, New Jersey and the District of
36 Columbia; that you already knew from their early letter of
37 21st July. By this time they have managed to add two
38 states, the states of Maryland and Virginia. Do you have
39 any idea of the planning, the cost and preparation time
40 required in producing a hundred brochures per restaurant
41 throughout the country?
42 A. Yes, sir. I am not saying it would be a piece of
43 cake, but I am saying for a company of the resources,
44 clout, finances and will of McDonald's, it could certainly
45 be done in that length of time.
46
47 Q. One final thing, Mr. Gardner: I think you told us
48 yesterday that there was -- you started by calling it
49 "agreement" or maybe they were the words of Mr. Morris or
50 Ms. Steel, but what it came to was this, that there was
51 some kind of informal understanding between you and
52 McDonald's and the other companies concerned that there
53 would be some kind of joint press release or announcement
54 of this nationwide campaign. Is that right? Have
55 I understood that correctly?
56 A. If you understand the qualifiers, that that is purely
57 working on memory you have, sir, that is my recollection.
58
59 Q. What I am asking you is this, I think: How informal was
60 this understanding to your recollection?
