Day 248 - 13 May 96 - Page 22


     
     1        about the London Greenpeace libel action.  It is called
     2        'Bulletin No. 1'.  It says, "Please find attached a
     3        background briefing document on the forthcoming
     4        London Greenpeace libel action which is due to come to
     5        court on 18th April and last for approximately 12 weeks.
     6        This is a complex matter of great important to McDonald's,
     7        not just in the UK but around the world.  It is also very
     8        sensitive, particularly with regard to the press, and it is
     9        very important therefore that you treat it seriously and
    10        with the utmost confidentiality.  Please read the briefing
    11        document carefully.  We are also currently preparing a
    12        hand-out for you to use in the event of any customer
    13        inquiries.  This hand-out must not be left lying round the
    14        dining area or in the did-you-know boards.  It is to be
    15        kept securely behind the counter and only handed out in
    16        response to customer queries."
    17
    18        Then it carries on.  Then, in tab No 17 is a memo from Edi
    19        Bensilum to all supervisors, field consultants, senior
    20        field marketing executives, regional communications
    21        officers, and it is dated 14th April 1994.  It says,
    22        "Further to my memo dated 18th March we have now produced
    23        a leaflet for customers regarding the London Greenpeace
    24        trial and these have been delivered to all restaurants this
    25        week."  It says "see reverse" -- we do not appear to have
    26        the reverse, actually.  "As per the above memo restaurant
    27        managers and franchisees were advised to keep the leaflets
    28        in a secure place behind the counter, and only to use them
    29        in response to customer inquiries.  They should not be left
    30        lying round the dining area nor should they be put on the
    31        information boards".
    32
    33        Why was it that you did not want the memos -- sorry, the
    34        leaflets given out to the public or put on the did-you-know
    35        boards?
    36        A.  As I remember we made 300,000, and we gave 500 per
    37        restaurant.  We wanted to give them to people who genuinely
    38        had an interest in the case or had a question, and that was
    39        the way thought best to do it.  I myself would not have had
    40        any problem putting them in the did-you-know boards or
    41        giving them out to a wider audience if we required, but we
    42        only printed 300,000.
    43
    44   Q.   Recently, you have printed a leaflet about BSE, or
    45        basically talking about where you get your beef from which
    46        is available in the restaurants.  Do you know how many of
    47        those were printed?
    48        A.  No.
    49
    50   Q.   You have no idea at all? 
    51        A.  No. 
    52 
    53   Q.   Do you know how many of your other leaflets you usually get
    54        printed when you ----
    55        A.  Depends what the issue is.  Some we print very short
    56        runs of with the intention of reviewing the information,
    57        doing additional studies, updating the numerical contents
    58        thereof; some we do long, long print runs of.  If it is a
    59        tray map we might do several million.  If it is a nutrition
    60        guide we may do enough to last 12, 18, 24 months and start

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