Day 257 - 06 Jun 96 - Page 34


     
     1        of tables which came to you, and what has happened to those
     2        handwritten faxes?
     3        A.  They were thrown away almost as soon as they were
     4        received because they were handwritten fax.
     5
     6   MS. STEEL:  You actually said you were not sure whether it was a
     7        handwritten fax, it might not have been?
     8        A.  The way that I would nominally handle, or in my
     9        previous role I would normally handle, a request like this
    10        would be in exactly the manner I have described because it
    11        is a one-off request for information.  We have a good
    12        operating relationship with the research company and the
    13        advertising agency, there is no need for any more of a
    14        formal process than the one I have just described in my
    15        normal way of operating.
    16
    17   Q.   So there would not be a problem of getting that same
    18        information again; is what you are saying?
    19        A.  No, the information still exists on the database.
    20
    21   Q.   OK.  What is the name of the advertising agency?
    22        A.  Leo Burnett Advertising.
    23
    24   MR. JUSTICE BELL:  Amongst that information would be information
    25        which enabled you to form the view that 43 or 44 56ths of
    26        the population ate out?
    27        A.  That is correct, yes.
    28
    29   MR. MORRIS:  The sheet that Mr. Rampton has, have you seen that
    30        one before -- the draft one?
    31
    32   MR. JUSTICE BELL:   The draft one?
    33        A.  I have not (handed).
    34
    35   MR. MORRIS:  Do you know when this was done, compared to the
    36        other one that was in the bundles?
    37        A.  I have not seen this.  I do not recognise this version,
    38        it may have been--
    39
    40   Q.   It was not done by you, this version?
    41        A.  Looking at it, I do not know.  Looking at the typeface,
    42        it may well have been done by Leo Burnett Advertising.
    43        There may well have been an earlier version.  I do not
    44        really have the typeface.  It is not certainly a typeface
    45        we normally used at McDonald's.
    46
    47   Q.   Would the Plaintiffs know who did this document?
    48
    49   MR. RAMPTON:  I have absolutely no idea who did the document, I
    50        was given the document, it was then superseded by the 
    51        perfected version which Mr. Fairgrieve proposed that he 
    52        composed.  I have no idea what its source was, who made it, 
    53        or anything else apart that there was a time when I was
    54        using it as my working paper.
    55        A.  Recognising the typeface is one used characteristically
    56        by Leo Burnett, it may be I have got the original from Leo
    57        Burnett, or got the version to send to the lawyers in this
    58        format from Leo Burnett.  That would be my guess, looking
    59        at the typeface.
    60

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