Day 012 - 18 Jul 94 - Page 81


     
     1        it.  It has been canvassed in open court now.  If it is
              available, it should be forthcoming.
     2
         MS. STEEL:  The correspondence with the New York Attorney
     3        General on this issue would be relevant as well, and I do
              not think any of that has been disclosed, so that might be
     4        helpful.
 
     5   MR. JUSTICE BELL:  I do not know whether there is any in
              existence.  All I can say is I would expect it to be
     6        discovered if it is available.
 
     7   MR. MORRIS:  So just to quickly move on to finish with this
              page:  The point in No. 1 is that there was nutritional
     8        information available on request from company
              headquarters.  You said something about collect call;
     9        people could say McDonald's can pay for the call.  Was
              that ever advertised?
    10        A.  It was not.
 
    11   Q.   No.
 
    12   MR. JUSTICE BELL:  It was a matter of practice, was it, really
              if anyone made a collect call to the headquarters it was
    13        taken?
              A.  Yes, without exception.
    14
         MR. MORRIS:  But how many customers do you serve a day?
    15        A.  I think 23 million worldwide.
 
    16   Q.   Right.  Let us say in America 19 million, I think it is?
              A.  12, 14 million, I cannot remember.
    17
         Q.   If they wanted systematic information, even if one per
    18        cent of them wanted systematic information, about
              brochures, a number without a collect call information
    19        would not have been a very satisfactory way, would it, of
              reaching your entire consumers?  If they wanted
    20        nutritional information, if one per cent of those wanted
              accurate information, you would be getting -----
    21        A.  It would have been a mad house.
 
    22   Q.   It would have been 500,000 calls or something?
              A.  That is right, whatever the number is.
    23
         Q.   I just want to ask you about point 3.  This agreement with
    24        the New York Attorney General that you mentioned, that was
              very much to see how it went, yes, was it?  The first
    25        sentence:   "... announced a voluntary agreement with the
              New York Attorney General".  Was that one of your testing 
    26        the water to see how it went type of programmes? 
              A.  In terms of whether the brochure was accepted by the 
    27        public?
 
    28   Q.   Yes.
              A.  Yes.
    29
         Q.   The next sentence says:  "The company announced it would
    30        that it would put complete ingredients and nutrition
              information in every one of its restaurants in New York

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