Day 010 - 11 Jul 94 - Page 56


     
     1   Q.   Yes.
              A.  I do not recall having it at that time.
     2
         Q.   So, if we look, for example, at the third actual page of
     3        your report, your statement-- incidentally, I do not know
              if it helps, but I have numbered the paragraphs in this
     4        statement, so this is paragraph No. 4 that I want to refer
              to, under the subheading "Issues Surrounding Polystyrene
     5        foam Production"?
              A.  Yes.
     6
         Q.   Do you see that paragraph?
     7        A.  Yes, I do.
 
     8   Q.   It reads in your report:  "In 1987 the plastic industry
              journal Modern Plastics described McDonald's as the
     9        largest single user of polystyrene, the chemical used to
              produce foam for food packaging".  That is not what it
    10        said at all, is it, Mr. Lipsett?
              A.  Sorry, maybe you can refer me to the statement?
    11
         Q.   Sorry.  The fourth paragraph.
    12
         MR. JUSTICE BELL:  No, your actual statement ---
    13        A.  I have that.
 
    14   Q.   -- of which you faxed -----
 
    15   MR. RAMPTON:  For your convenience, could you unclip the actual
              statement leaving the documents, as it were, separate?
    16        A.  Certainly.
 
    17   Q.   Do you see that statement in the fourth paragraph?
              A.  I do.
    18
         Q.   "In 1987 the plastic industry journal Modern Plastics
    19        described McDonald's as the largest single user of
              polystyrene, the chemical used to produce foam for food
    20        packaging".  That article did not say that, did it,
              Mr. Lipsett?
    21        A.  Well, I am sorry.  My question to you was, if you
              could refer me to the actual section in the article.
    22
         Q.   Quite right.  It is in the bundles of papers which you
    23        prepared for today's hearing.  In your case it is dated
              October 1987; in our case November 1987, because we are
    24        using the international edition, Modern Plastics.  It is
              headed "McDonald's Pull Out CFCs".
    25
         MR. JUSTICE BELL:  Yes.  Which number bundle was that? 
    26 
         MR. RAMPTON:  My Lord, I am afraid I do not know. 
    27
         MR. MORRIS:  Have you got that?
    28        A.  Yes.
 
    29   MR. RAMPTON:  You have got that?
              A.  As I say, I have the version that was published in the
    30        States.
 

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