Day 061 - 05 Dec 94 - Page 60


     
     1        this information came from, which document this came from?
     2        Is it part of a document?
     3
     4   Q.   I was hoping you would know.  That is why I am asking.
     5        A.  I do not know.  That is why I need to ask because it
     6        looks like it is part of something.
     7
     8   Q.   If it is for handing out if people ask, members of the
     9        public ask, if it were for that and it appears you do not
    10        know, but the point being made is, it is suggested, it is
    11        not so much a statement of McDonald's position on animal
    12        welfare and husbandry, but an attempt positively to promote
    13        McDonald's as interested in animal welfare and
    14        husbandry ----
    15        A.  I would agree that it ----
    16
    17   Q.   --- to make a public relations point?
    18        A.  I honestly do not know that it has been used for public
    19        relations purpose.
    20
    21   MR. RAMPTON:  My Lord, I think I might be able to help.  I am
    22        not going to give evidence.  I am going to make a
    23        suggestion; your Lordship may or may not find it helpful.
    24        If one looks at the wording of this typewritten document
    25        and compares it with the wording in the Fact Book which is
    26        for public consumption, that is to say, so far as page 1 of
    27        the typewritten document is concerned pages 21 to 22 of the
    28        Fact Book; so far as the succeeding pages are concerned
    29        pages 24 onwards so far as McKey and Sun Valley are
    30        concerned.  It might be, and I do not know whether it is or
    31        it is not, that this document is a draft for what is put
    32        into public circulation in the Fact Book because the
    33        wording is very similar, if not identical.  I am sure we
    34        can find out as a matter of fact whether that is right or
    35        not.  Certainly the document does not have the appearance
    36        of something that is handed out to the public, whereas of
    37        course the Fact Book does.
    38
    39   MR. JUSTICE BELL:  If you go back, Ms. Steel, to 58 line 12, now
    40        we have made some attempt to find where it comes from,
    41        would you like to put the question again?  I was trying to
    42        help you by putting your question in another way.  It
    43        seemed to me, first of all, one should try to find out,
    44        since one was looking at pages 1 and 2 and you were
    45        particularly at the moment looking at page 2, what that
    46        document was.
    47
    48   MS. STEEL:   This document would be used as the basis for
    49        answering enquiries that people might have about these
    50        various issues, is that fair to say? 
    51        A.  Yes, I think each of the individual items could be used 
    52        from time to time to answer an enquiry. 
    53
    54   Q.   I am not quite sure what you want me to do.
    55
    56   MR. JUSTICE BELL:  I am not trying to take it out of your
    57        hands.  You may have a document which sets out a company or
    58        an institution's attitude to things in order that all its
    59        employees and people working within the company or
    60        institution should know: "These are the standards we are

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