Day 062 - 06 Dec 94 - Page 56
1 will have the cutlery in there, plastic cutlery. It is
2 basically the same cutlery, just without the extra
3 wrapping.
4
5 MR. MORRIS: We are sort of working through all the documents
6 here.
7
8 MR. JUSTICE BELL: Choose which ones are going to progress your
9 argument. There is no need to test something for the sake
10 of it. Pick out what you think assists the case you want
11 to put.
12
13 MR. MORRIS: I am on page 7.13. We have already identified
14 that, apart from the transport packaging which has now been
15 noted, there are fry bags and place mats, promotional
16 items, toilet rolls, kitchen towels, a few bits and pieces
17 from the States, Happy Meal boxes, happy hats, napkin wraps
18 which are not included in the figures and office
19 stationery. You cannot calculate that total volume missed
20 out?
21 A. Napkin wraps have been included. The bits and pieces
22 from the States have been included.
23
24 Q. Because they have gone through the DCs?
25 A. Yes, because they have gone through Perseco. They
26 come, then the supplier in this case was Perseco US instead
27 of -- and then it comes through us and goes through the DCs
28 or the sales go through, but they have been included. You
29 are quite right if you say that things like kitchen
30 towels ----
31
32 Q. Toilet rolls?
33 A. --- toilet rolls, place mats, tray liners, have not
34 gone through us.
35
36 Q. You can see where we are moving. We are trying to identify
37 the total volume. It is very difficult to do that just
38 based upon Perseco's figures.
39
40 MR. JUSTICE BELL: Can you help any more on quantifying the
41 extra? You said you have no idea when I asked you.
42 A. Sorry, I know that most of these extras do go through
43 some of the suppliers that we deal with, so there is a way
44 for me to find out several of those items. But it would be
45 a difficult one to find out for going back at all because
46 we have not dealt with them, and it would have to be
47 determined afterwards. Kitchen towels, toilet rolls which,
48 to my knowledge, are 100 per cent recycled, they come from
49 the supplier here in the UK, but we do not deal with them;
50 we do not deal with that type of product. I know tray
51 mats ----
52
53 MR. JUSTICE BELL: Leave it there. It sounds as if you cannot
54 help any further on the overall figure.
55 A. No, I cannot. As I said, most the items that he
56 mentions are recycled, so I do not know whether the virgin
57 figure would going become a lot bigger, but part of the
58 happy meal do contain -- the happy meal containers are made
59 of top colour, so they do contain or would have in 1992 if
60 that is the still figure they were based on, they would
