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

Prev Next Index