Day 084 - 07 Feb 95 - Page 11
1 complaints in respect of food safety which are recorded in
2 the incident reports form book in each restaurant. He
3 identified seven complaints in the three restaurants,
4 I believe, in his chart. There may have been more, I do
5 not know -- no, the total number of complaints was nine in
6 the three stores over different periods.
7
8 There were also memos from Head Office in relation to food
9 safety; one of them particularly was a memo detailing the
10 action to be taken by managers in relation to suspected
11 cases of viral gastroenteritis dated 14.1.1993 and any
12 other memos that were relevant to concerns by the company
13 over health issues of the cooking process. I will check
14 that again tonight.
15
16 The other thing in Mr. Jackson's statement which I have not
17 got on my list and I cannot find his statement, but he
18 referred in his statement to his Sun Valley visit. In one
19 particular section of his statement he dealt with the
20 number of birds rejected by the company or rejected as not
21 fit for consumption either because they were dead or
22 diseased. I think it was something like 1.5 per cent. If
23 we could have the documents at the time of his visit or
24 nearest available time as to that fact?
25
26 If I can leave packaging and employment to save time today,
27 but there was just one other environmental matter which is
28 soya, if I may go on to that? It is just that in
29 Mr. Cesca's affidavit -- it is his second affidavit, page
30 8, I will just read out; it is only one sentence, it is his
31 point 10 -- he says: "Soya for cattle feed". This was
32 after our application based on our restored passages which
33 obviously goes back 18 months, or something, originally,
34 our application. He says: "I repeat what I said in
35 paragraph 3 of my first affidavit". I have not got his
36 first affidavit with me, but it basically says it is being
37 dealt with by Barlow Lyde and Gilbert. He has no personal
38 knowledge of the soya in Germany. It was basically the
39 sources of soya feed for McDonald's beef in Germany. We
40 had applied for in our application entitled "Discovery
41 relating to restored passages", which is what Mr. Cesca
42 replied to, correspondence with Franz Wirtz who is a
43 witness of ours; correspondence between McDonald's Germany
44 and L&O Fleisch Waren relating to feed for their beef;
45 correspondence between McDonald's Germany and Raffeisenn
46 Kraftfaterwerck regarding this issue and internal reports
47 and memos regarding this issue. Mr. Cesca says that is
48 being dealt with by Barlow Lyde and Gilbert. That is just
49 because that was something I missed out yesterday.
50
51 If I can move back to our list, while we are on the subject
52 of documents. Again probably there is no time to go into
53 it now, but Mrs. Brinley-Codd has helpfully made up a list
54 of documents served since 12.9.1994, served in court, but I
55 do not know how this normally is dealt with. We have
56 contacted the Plaintiffs' solicitors and tried to work out
57 a system but we have not been able to really develop one by
58 agreement. This is just something that I feel if we could
59 just put down a marker that ----
60
