Day 293 - 04 Nov 96 - Page 20


     
     1        argue anyway it is not substantially post-consumer, it is
     2        not recycled, in any event.
     3
     4   MR. JUSTICE BELL:   Very well.
     5
     6   MR. MORRIS:  Obviously, we have got much more detailed
     7        information about the European situation and the figures
     8        seem to be more reliable on the European situation.
     9
    10        And just to say that if you look at page 14 there is
    11        another chart, handwritten 14, behind the other one, there
    12        is another chart that ----
    13
    14   MR. JUSTICE BELL:   That is 350 of the bundle?
    15
    16   MR. MORRIS:   Yes, where it compares the recycled versus virgin
    17        paper content.  That accords with the first chart in terms
    18        of equivalence.  So it does seem a bit kind of confusing
    19        one way or the other as far as America is concerned.
    20
    21        Can I also say, if you look at page 347, bundle 347, this
    22        is a document which has been produced for public or some
    23        kind of, you know, formal public use, or whatever it is,
    24        presentation, not for this case, by Persico including David
    25        Kouchoucos.  If you look at the bottom of that page 347, in
    26        the middle of that last full paragraph:  In 1989 McDonald's
    27        paper packaging contained 7 percent recycled content.
    28
    29        So I don't consider that the view of that first chart is
    30        some kind of clerical error or something and it is
    31        something they have on record about in court and publicly.
    32
    33        I think that is all I have to say on that.  While we have
    34        got that tab open, if we can just note that the DJK5, which
    35        is pages 338 in that tab onwards, is a list of supply mills
    36        which I think we have put anyway to one or other of the
    37        witnesses as regards where the mills are sited and the use
    38        of chlorine bleaching and other matters.
    39
    40        You may still need to have that file out, I think, because
    41        I was going to look at what I have got as DJK4.  I don't
    42        know if it is part of his first statement or his second
    43        statement, but it is bundle page numbers 50 to 57.
    44
    45   MR. JUSTICE BELL:   Yes.
    46
    47   MR. MORRIS:   If you are making any calculations yourself,
    48        I think this is an important set of documents.  This again
    49        is not the complete story, because, as far as I can see, it
    50        does not include all the packaging.  For example, the 
    51        transport packaging for food items is not included.  On 
    52        page 2 it has got:  Corrugated containers from all of the 
    53        above items.  Again, it is not clear if it is all of the
    54        above items on the first two pages or just that one page.
    55        That is all transport and packaging for the packaging items
    56        rather than for the food items, and, as we know, that is
    57        far greater in weight.
    58
    59   MR. JUSTICE BELL:   Which is your page 2?  What has that got at
    60        the bottom?

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