Day 007 - 06 Jul 94 - Page 42


     
     1        A.  That is the unfortunate part.  Snowflake is Arizona.
 
     2   Q.   Is that the only Arizona one?
              A.  It is.
     3
         MR. RAMPTON:  That is another recycling plant?
     4        A.  It is yes.
 
     5   Q.   Cross the R out and put a K for that?
              A.  It would be vice versa.   The AR is correct for
     6        Arizona. AK for all the others, but that is a lot of back
              tracking.
     7
         Q.   Finally we get somewhere in Ontario and somewhere  in
     8        Virginia?
              A.  Yes.
     9
         Q.   Is there any significance in the parenthetical statement
    10        that Covington, Virginia is on the Jackson River?
              A.  No, it is just further identification.  There might be
    11        several mills in Covington, Virginia.
 
    12   Q.   I am not going to ask you anying more about that topic.
              We have one matter left with which we can deal before the
    13        adjournment. For this purpose you will need the
              Defendants' first bundle of witness statements which is
    14        blue- but not the blue you have there. The pale blue?
              A.  The peacock.
    15
         MR. JUSTICE BELL:   Someone will bring it for you, Mr.
    16        Kouchoukos.
 
    17   MR. RAMPTON:  Have you got tab J?
              A.  Yes.
    18
         Q.   Can I ask you this, Mr. Kouchoukos-  do you know Mr.
    19        Lipsett - Brian Lipsett?
              A.  I have heard of him.
    20
         Q.   You have heard of him; you have not actually come across
    21        him?
              A.  I saw him speak in one industry conference- maybe a 15
    22        minute presentation several years ago.
 
    23   Q.   Do you know of the McToxics campaign?
              A.  That I certainly do know of it.
    24
         Q.   At whom was directed?
    25        A.  At McDonald's Corporation.
  
    26   Q.   How long did it last, do you know? 
              A.  It was certainly focused in 88/89, but I am not sure 
    27        if it continues now or not.
 
    28   Q.   We see if we turn over the page to the second page of Mr.
              Brian Lipsett's statement that he has a B A in History and
    29        he is currently enrolled at Pen State University (this is
              in July 1993) doing Master Programme of Administration of
    30        Justice.  Do you see that?
              A.  Yes.

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