Day 025 - 16 Sep 94 - Page 46
1 fourth line of page 101 the point you had in mind a minute
2 or two ago?
3 A. What is page 101, your Lordship?
4
5 Q. 101, under "Strategy". It is in tab 33. If you open your
6 glossy and look at the page after the letter to the
7 family, the one Mr. Rampton read to you a moment ago.
8 A. Yes, your Lordship. Are you referring to the
9 year-long advertising schedule?
10
11 Q. Yes. Do you think that is what you had in mind a few
12 minutes ago you when you said somewhere in the
13 documentation you had read reference to a year-long
14 campaign?
15 A. It may very well have been; I suspect it was.
16
17 MR. RAMPTON: I can show you an internal document which sets
18 out the scheduling of the advertisements for the first two
19 quarters of 1987, Mr. Gardner. None of these documents
20 elucidates how many pages each of these advertisements
21 were to have. We will have to return to that, perhaps, at
22 a later stage in this case, but can you turn to tab 35,
23 page 181?
24 A. 181?
25
26 Q. 181, bundle VI A, is part of a memorandum from Leo Burnett
27 to David Green at McDonald's? Before you turn over,
28 I would like you to look at the date, January 13th 1987.
29 Do you see that?
30 A. Yes.
31
32 Q. This is before any of the advertisements appeared and so
33 naturally some months before your intervention. If you
34 turn over two pages to 183, you see the schedule for the
35 first two quarters of 1987? You will see that the last
36 planned publication of any of the advertisements to which
37 you objected was in January 1987, the "Pinch of Salt"
38 advertisement in Woman's Day in June, do you see that?
39 A. I see what you are pointing to. It was not the last
40 -- on the face of it, it does not indicate that that was
41 the last planned insertion.
42
43 Q. No. Of course, I accept that. There is no express
44 statement saying: "The campaign will terminate here".
45 But you have no direct evidence, do you, to suggest that
46 it was intended to run in its full force and in every
47 particular throughout the whole of 1987, do you?
48 A. Direct evidence being a memo such as this or?
49
50 Q. Or a conversation with somebody at McDonald's?
51 A. The only evidence, other than what I have already
52 pointed to that I could provide, is what I have already
53 mentioned which was at this point a bit dim memory of our
54 conversations with McDonald's in which we certainly got
55 the impression that they had terminated the advertisements
56 after we had contacted them.
57
58 My point is that this is represented to be a schedule for
59 the second quarter. It also gives first quarter data, but
60 it does not give a schedule for the third quarter. That
