Day 169 - 04 Oct 95 - Page 19


     
     1        undercooking were about the buns".  Even in your evidence
     2        that still leaves a minority.  You have not seen any
     3        incident report forms for those undercooked meat products
     4        that were complained about?
     5        A.  There are other instances of undercooking.  For
     6        instance, you could get a fillet portion which was
     7        undercooked.  You could get fries that are undercooked.
     8        Just because I say buns, it does not mean -- I mean, people
     9        get fries that are undercooked.
    10
    11   Q.   So you have never had any complaints about undercooked meat
    12        products; is that what you are saying?
    13        A.  No, I have never received any complaints about
    14        undercooked meats product.
    15
    16   Q.   Or anybody in the store that you are aware of?
    17        A.  No, I cannot speak for anybody else, can I?
    18
    19   Q.   That you are aware of?
    20        A.  As far as I am aware, we have not received any
    21        complaints of undercooked meat products.
    22
    23   Q.   The cooking of 12 patties on the clam shell grill occurred
    24        at a time when you were aware that you were not supposed to
    25        cook more than nine pieces of meat on a grill, did it not?
    26        A.  No, it did not.
    27
    28   Q.   The change over to 40 to 44 seconds for the regular
    29        hamburgers time, the length of time for the cooking,
    30        occurred in 1991.  Are you saying that ever since that time
    31        you only ever  -----
    32        A.  I am saying ever since we received a memo informing us
    33        that we should no longer cook 12 pieces of meat on our
    34        model 12 grills, we cooked nine pieces of meat on them.
    35
    36   Q.   So are you saying now it may not have happened at the same
    37        time as the change over to 44?
    38        A.  I am saying, it might not have happened exactly the
    39        same time.  We are talking about an incident that happened
    40        five years ago.  I cannot remember exactly when we changed
    41        over from 38 to 42 to 40 to 44 seconds, and I cannot
    42        remember exactly when we changed over from 12 pieces of
    43        meat to nine pieces of meat.  I am saying I think they
    44        happened around the same time.
    45
    46   Q.   That was several years ago?
    47        A.  That was several years ago.
    48
    49   Q.   So you are saying that it did not happen since that time?
    50        A.  It has not happened -- since we have received in the 
    51        store a memo telling us that we are no longer to cook 12 
    52        pieces of meat on a model 12 clam, we have no longer cooked 
    53        12 pieces of meat.
    54
    55   Q.   Yesterday you did say that you recalled that being one or
    56        two years ago?
    57        A.  Well, I did not.  I said I recalled that as being more
    58        than one year ago, and you pressed me further and said:
    59         "So it is one to two years, is it?" and I said:  "It was
    60        at least one year ago".  It was several years ago.

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