Day 195 - 04 Dec 95 - Page 29
1 MR. MORRIS: I think he has dealt with all those matters then.
2 I just want to have a quick look at Frank Stanton's.
3
4 MR. JUSTICE BELL: That is divider 4.
5
6 MR. MORRIS: There are a couple of questions on Mark Davis'
7 supplementary statement.
8
9 MR. JUSTICE BELL: That follows on from 33.
10
11 THE WITNESS: I have it.
12
13 MR. MORRIS: Page 3, his comments on your statement start, but
14 over the page let us just have a look to see if I need to
15 ask any questions. Yes, he says in the middle of his
16 paragraph 9, just under halfway down: "The large freezers
17 in McDonald's restaurants did not and do not in my
18 experience break down on 'numerous occasions'". Did you
19 say they did?
20 A. I did not say actually they broke down on numerous
21 occasions. I said that meat was defrosted or defrosted
22 meat was served on numerous occasions and, as an example of
23 why it should have been defrosted, I gave the break down of
24 the freezers but there were other examples why meat was
25 defrosted before cooking.
26
27 Q. In paragraph 10 he says you allege raw meat would be sold;
28 did you say that?
29 A. Yes, raw meat in the middle, not absolutely raw, in the
30 middle of the quarter pounder.
31
32 Q. Raw in the middle?
33 A. Raw in the middle.
34
35 Q. He then says: "I am sure that I would have known of it;
36 customers would have complained". Do you have anything to
37 say about that?
38 A. I mean, generally, Mark Davies claims not to have known
39 about many things but Mark Davies to me looked as if he was
40 a Manager who was in charge, in full control of his store,
41 and he knew what was going on, and he was actually, I can
42 remember on Saturdays on very busy occasions, when he was
43 actually packaging the meat. He was actually not preparing
44 but putting the meat or the sandwiches in the production
45 box, if that is what it is called, for serving. He must
46 have known and must have felt that the meat was raw in the
47 middle, and he was actually keeping an eye on who was
48 cooking it. So, I assume with his experience he would have
49 known whether the meat is completely cooked in the middle
50 or not.
51
52 Q. How do you know that the meat he saw was under-cooked?
53 A. Because it was frequently under-cooked. On busy
54 occasions you just did not have time when you have one
55 person on the grill and one person producing quarter
56 pounders. You have basically got too much on your hands.
57 You cannot sear the meat properly and it was frequently raw
58 in the middle.
59
60 Q. "Customers would have complained", he said. Any comment on
