Day 009 - 08 Jul 94 - Page 58


     
     1   Q.   Just briefly you talked about third wave of the
              environmentalists movement.  You mentioned earlier on from
     2        that 1970 was a hallmark year in the kind of birth of
              environmental awareness, is that correct?
     3        A.  The birth in the United States.
 
     4   Q.   Yes.
              A.  A rebirth.
     5
         Q.   Whatever.  It was an important hallmark year in the
     6        development of environmental awareness?
              A.  I would say it is the most significant date in
     7        American environmental thinking.
 
     8   Q.   Yes.  Are you aware that London Greenpeace, the subject of
              the fact sheet, was formed at that time, 1970, 1971?
     9        A.  No.  I heard you say in court earlier something about
              1984, but I do not know anything further about that.
    10
         MR. JUSTICE BELL:  Was there a time, do you know, when
    11        McDonald's began to feel that it was a specific target of
              any kind of environmental movement, McDonald's itself?
    12        A.  I am not aware of that.  I know we had customer
              concerns about our use of trees in the early 70s.  I also
    13        know that we spent a lot time on energy issue.  That was
              not a customer driven issue.  As you know, in the mid 70s,
    14        that was a world issue.  But in terms of being a specific
              target  .....
    15
         Q.   Yes.  If any kind of environmental movement was directing
    16        itself particularly at McDonald's, you are not aware of
              it?
    17        A.  I am not aware and I do not think it ever happened.
              I would say if you classify the environmentalists,
    18        portions of the environmental community targeting
              McDonald's, I think you can refer to the McToxic campaign
    19        from before as being an example of that and the only
              example that I know of.
    20
         MR. MORRIS:  You are not aware of the anti-McDonald's coalition
    21        in the States in the late 80s?
              A.  No.
    22
         Q.   Of hundreds of environmental and social and community
    23        groups?
              A.  I never heard that term.
    24
         Q.   When the McDonald's Corporation was preparing legal action
    25        in this case, were you asked to provide any opinion or
              information to the company about it? 
    26        A.  There was a lot of information that are in these books 
              are information from the files that I have in my office. 
    27        Obviously, my testimony was prepared for this trial.
 
    28   Q.   I do not mean just strictly for your statement, I mean at
              the time in 1989 when there were preparations for legal
    29        action, 1989/90, you were not asked at that time?
              A.  No.
    30
         Q.   Just to come back to in store recycling, customer

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