Day 009 - 08 Jul 94 - Page 25


     
     1        originally?
              A.  The most easy way for me to describe it is it is
     2        everything we put into our trash bin at the back of the
              restaurant.
     3
         Q.   Right.  But that will not include take away stuff?
     4        A.  Exactly correct.
 
     5   Q.   Right.  Did you say yesterday something about the amount
              of your custom that was take away?
     6        A.  Approximately 50 per cent.
 
     7   MR. JUSTICE BELL:  In the US?
              A.  Correct.
     8
         MISS STEEL:  You have 14,000 restaurants worldwide, do you not?
     9        A.  Today?
 
    10   Q.   Yes.
              A.  I think that number is about correct.
    11
         Q.   Each one of those produces, on average, 140 pounds of
    12        packaging on premises waste?
              A.  I cannot say that for a fact.  I can tell you that
    13        when we did that study in 1990 in the United States that
              is the figure that we arrived at.
    14
         Q.   Right.  Do you think ones elsewhere in the world would be
    15        more or less?
              A.  Can I -- if we are going to talk more in detail about
    16        this, I would like to have the study in front of me so I
              can be more familiar with the actual numbers.
    17
         Q.   I have just got your statement.
    18        A.  OK.
 
    19   MR. RAMPTON:  Are we speaking of the Environmental Defense ----
              A.  I am trying to get clear as to what you want to delve
    20        into detail on.  My testimony, just for clarification,
              related to the United States.  So if you are asking .....
    21
         MISS STEEL:  So your statement was just about the United
    22        States?
              A.  Correct.  If you are looking for input, other input,
    23        I need to ask what you are referring to.
 
    24   Q.   Right.  Do you know whether 140 pounds is likely to be the
              average for restaurants all over the world?
    25        A.  I just cannot answer that question.
  
    26   Q.   You do not know? 
              A.  It is not a matter I do not know, I would have to do a 
    27        little work on it.  I cannot answer you directly on that
              question.
    28
         Q.   OK.
    29        A.  If I can explain, we do have access to this
              information worldwide.
    30
         Q.   Right.  Do you know whether that information has been

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