Day 043 - 01 Nov 94 - Page 62


     
     1        A.  Yes, at the time I think he was employed there.
     2
     3   Q.   Who are an independent communications agency in Chicago?
     4        A.  Yes, communications, public relations agency.
     5
     6   Q.   I would ask you kindly to do, if you will, is to read the
     7        whole of this document -- it is two and a half pages -- to
     8        yourself, then I will ask you a question.  We have all read
     9        it before, or some of us have read the whole of it,
    10        I should say.
    11        A.  OK.
    12
    13   Q.   Can you go back to the second page of the memo which is
    14        page 185 in the file and look again at (a), (b) and (c)?
    15        A.  There is a number of (b)s and (c)s on the page.
    16
    17   Q.   At the bottom of page, 4(a), (b) and (c), "McDonald's is
    18        not suggesting", that series there, do you have it?
    19        A.  Yes.
    20
    21   Q.   You will see certain words are underlined?
    22        A.  Yes.
    23
    24   Q.   In particular, at the end:  "But in balance and in
    25        moderation", underlined, "there is a place for our food and
    26        we make no apologies for that".  So far as your memory
    27        enables to you to do so, Mr. Green, can you tell us whether
    28        the position suggested in that document represents any
    29        significant change or shift in McDonald's attitude as to
    30        the place of its food in the diet of Americans?
    31        A.  No, well, I do not remember this specific document
    32        itself.  The points that are specifically in the document,
    33        (a), (b) and (c) are, in fact, the points that I believe we
    34        felt were the correct points to make in this case.  We
    35        believed in these particular points.
    36
    37   Q.   Is it, so far as you are aware, a position which McDonald's
    38        still maintains, that in balance and moderation McDonald's
    39        food is perfectly good and healthy a part of anybody's
    40        diet?
    41        A.  Yes, I believe the company believes that and I believe
    42        it.
    43
    44   Q.   Was the advertisement campaign in magazines in the early
    45        part of 1987 intended to convey any different message?
    46        A.  No, in general, that was, in fact, the message that
    47        I believe was in the majority of the ads.
    48
    49   Q.   If you pick up your original again, you can see that the
    50        very first advertisement  -- these are samples from the 
    51        McDonald's Family -- is, in fact, entitled "Balance", is it 
    52        not? 
    53        A.  Yes, it is.
    54
    55   Q.   Can you then turn to the next tab 37 on page 186A?  It is a
    56        letter written to you, apparently, on 20th November 1986
    57        from your advertising agents, Leo Burnett.  It was signed
    58        by a lady at that date called Nina Heagstedt.  Again can
    59        I ask you to read it to yourself and tell me when you have
    60        read it?

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