Day 007 - 06 Jul 94 - Page 35


     
     1
         Q.   I had asked you to confirm, Mr. Kouchoukos, that the
     2        average cubic footage to be of trees to be found on an
              acre of timberland in the United States in 1987 was 720?
     3        A.  Correct, yes.
 
     4   Q.   We had previously calculated that it takes roughly 117
              cubic feet of a tree to make a tonne of pulp, right?
     5        A.  Yes.
 
     6   Q.   If you want to know how many tonnes of pulp one single
              acre will yield, you divide the cubic footage of the tonne
     7        into the cubic footage of the acre; is that right?
              A.  Correct.
     8
         Q.   So if we divide 720 by 117, do we get a figure of 14.7
     9        tonnes per acre?
              A.  We do.
    10
         Q.   Tonnes of pulp?
    11        A.  Correct, yes.
 
    12   Q.   As we saw earlier, the number of tonnes used by McDonald's
              for virgin tonnes of pulp was 88,761?
    13        A.  Yes.
 
    14   Q.   So, if you want to know the number of acres used by
              McDonald's paper in the United States, we divide that
    15        figure (88,761) by the number of tonnes yield per acre, do
              we not?
    16        A.  You would.
 
    17   Q.   Do we wind up with a figure of 6038- 6038 acres used to
              produce McDonald's paper on those figures?
    18        A.  Yes.
 
    19   Q.   Since we all know that there are 640 acres in a square
              mile, that results in a total usage of timberland
    20        expressed in terms of area by McDonald's for that year of
              9.4 square miles?
    21        A.  That would all be arithmetically correct.
 
    22   Q.   For the next part of what I want to ask you, please assume
              that we shall establish in this court in due course that
    23        the total square mileage of timberland used for McDonald's
              purposes in Europe for a year is roughly 1.3 square miles?
    24        A.  Okay.
 
    25   Q.   Just use that as a working hypothesis, if you will?
              A.  Yes. 
    26 
         Q.   It has been shown in court (and you need not get out the 
    27        volume) that there are in the United States 9,283
              restaurants. That is in 1993?
    28        A.  Okay.
 
    29   Q.   What I want to try to do, Mr. Kouchoukos, if it is
              possible, is to extrapolate, or calculate, from the
    30        European and the American figures (we have just
              established the American acreage in  any one year the

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